Snowy 2.0 - Main Works

Please find Submission attached

My family has had a lot to do with National Parks over many years, and I'm afraid this particular scheme is trying to take advantage of the romance of the original Snowy Mountains Hydro Scheme. People love a good story.
I will not be reading the many documents provided, but I am putting my trust in the NSW National Parks Association's opinion. I am not in favour of the destruction of so much of Kosciuszko National Park when I understand there are alternatives.
You will no doubt receive plenty of detailed submissions from people who are better versed in the project than I am, but I wish to add my voice to support those people and speak against the project.
Thank you for your time. 

Please find my submission attached.

The concept behind the Snowy 2.0 project - use of existing dams, with new largely underground infrastructure - to 'store' and generate electricity has some merit, providing water pumping is achieved through the use of renewable energy sources.
Like all major development proposals, Snowy 2.0 will have a number of adverse impacts. In this case, this includes adverse impacts on terrestrial and aquatic ecology, visual amenity, recreational opportunities etc.
However, a key concern is the location of the infrastructure, and consequent impacts, within Kosciuszko national park (KNP). Such infrastructure (including intensification of existing infrastructure) is generally incompatible with a national park.
While the EIS claims 'only' 0.25% of KNP will be impacted, the identified project area is much larger. The overall impacts are likely to be felt much beyond the nominal 0.25%. In any case, this represents 1680 (ha), according to the EIS, which is still a large disturbance area. These impacts would be increased by the linear nature of the proposed transmission line.
Unless it can be clearly demonstrated that there will be major environmental benefits from these works (i.e. significant reduction in greenhouse gas emissions) and that this option is clearly superior to alternatives for achieving greenhouse gas emission reductions, it should not be approved in this location. On this matter, it is noted that the consideration and dismissal of alternatives in the EIS is cursory at best. It is further noted that the EIS (appendix H) concludes more developments will be needed to meet the future needs of a decarbonised NEM. Perhaps some of these should be considered first.

I wish to register my objection to the proposed works within the Kosciuszko National Park relating to the Snowy Hydro 2.0 program.
I have several concerns.
The proposal involves large scale destruction of sensitive alpine and montane vegetation with over 1000 hectares to be cleared and with extensive widening of access roads and tracks within the project zone covering about one third of the park’s area. Additionally 2 new transmission corridors are to be cleared. Past experience with disturbed areas resulting from the construction of the original hydro scheme has shown ongoing damage due to erosion and invasion by exotic weeds such as willows and sheep sorrel.
It is also expected that pumping water from the lower dams back up to the higher ones within the park will result in these dams being colonised by exotic plants and fish of which they are currently free.
It is likely that the proposed tunnelling will lower the water table beneath streams and alpine bogs in the park and harm both the ecology of these sensitive ecosystems and their important role as regulators of water runoff.
At a time when climate change and relentless loss of biodiversity through land clearing are pressing issues, the integrity of our national parks is of great importance.
Already Kosciuszko National Park is under pressure on many fronts; invasion by feral pigs and horses, increasing demands for recreational activities such as horse riding and ski field development, cloud seeding and encroachment on its western boundary by more intensive forestry practices.
The Snowy Hydro 2.0 program would add further ecological damage.
I flew between Sydney and Melbourne recently and from the air one can appreciate that, although the park covers one million hectares, it really is a small area in the context of the Australian continent with the dry cleared land stretching away to the west making it appear as a small green treasure. Such areas can so easily be lost by a series of damaging impacts.
It is understandable that in trying to cut the use of coal for power generation schemes such as Snowy Hydro 2.0 seem superficially attractive but when this scheme will be of necessity damaging to the ecological integrity of the national park within which it is to be built, I feel it should be rejected.

1. History: environmental and cultural settings have changed dramatically since the heady post-WW2 days of the original Snowy Mountains scheme. The warming climate makes the National Park much more vulnerable to drought and fire, whilst also increasing the importance of mountain soils and ground water reserves to feed rivers. From a cultural perspective, greatly increased populations in SE Australia are putting ever greater pressure on the National Park for recreation and access to natural landscapes. For these reasons alone Snowy 2 is unrealistic and should not proceed.
2. Landscape values: visual catchment issues must be considered. Power lines, earthworks, dumped excavated materials, new roads, modified existing roads, lake shoreline variations and works depots will all compromise the visual amenity of the National Park. Heavy trucks will be moving spoil around, damaging peaceful tranquility and habitat. These impacts are not acceptable in a National Park. This is not the place for such brutal works.
3. Emissions: while hydro is an important renewable resource, what account is taken of the emissions from construction, including drilling, earth and rock movement, vehicle trips? and from fossil fuel pumping of water?
4. Pest control: what measures will be in place for pest control including weeds, aquatic weeds and feral animals, should the scheme proceed?
5. Alternatives: what assessment has been made for renewable energy alternatives? Any major project with defined aims ie in this case, to provide significant renewable energy in SE Australia, must be approached with a thorough scoping of a range of options, not simply by doggedly sticking to one apparently glamorous scheme. Designing on the run is a terrible way to run any project, let alone a hugely ambitious and costly one in a sensitive area which is a National Park, set aside for the benefit of nature not economic expansion;
6. Aboriginal history: the mountains are the setting for ancient ceremonies and meetings. What account has been taken of Aboriginal sensitivities in the Mountains; has there been any consultation with appropriate custodians and peoples from surrounding lands? Aboriginal wisdom must be integrated into any proposals for this special area should the scheme proceed.
7. Walkers, cyclists, runners, bush carers, bird watchers, students , fishing folk, skiers, artists, ecologists and many other user groups highly value the National Park as an unique environment where they can withdraw into a natural world from the maelstrom of urban activity and rural farming life. It is a tiny area compared to Australia's wide continental landmass. The National Park should not be any further violated. It is far more important to restore this landscape from the scars of the original Snowy Scheme and more recently from the excess of horses ruining natural water sources and rare vegetation. Public money supported the Soil Conservation Service efforts to recover the high ground from grazing . It is shameful to see a cycle of degradation happening all over again in the clear knowledge of the environmental impacts.
8. Snowy 2 is a wild and unreasonable scheme. The collateral damage to the National Park should be seen as offsetting any benefits to be gained from this allegedly renewable energy scheme. Many opportunities exist for renewable energy generation. Using Snowy Mountains water, such a precious resource in the driest continent on earth, should not be one of them. The project should not proceed.

I support the proposal in principle, though question whether the system capacity has been optimised (increased generation capacity given the substantial storage available), there-by providing maximum benefit for the environmental impact that will be incurred and question whether the project environmental impact can be further reduced.

Hi Anthony
Please find attached response from the EPA.
Regards
Stefan