Sunshine Estate Battery Energy Storage System

Subject: Objection –
• Rothbury Battery Energy Storage System (SSD-85939708)
• Sunshine Estate Battery Energy Storage System (SSD-92914712)
Property: 35 Crown Line Drive, Rothbury

Dear Sir/Madam,
I am the owner and future resident of 35 Crown Line Drive, Rothbury, located to the north of both the proposed Sunshine Estate BESS and the Rothbury BESS developments.
I have reviewed the Environmental Impact Statements (EIS), SEARs and supporting technical documentation for both projects. While I recognise the strategic importance of battery storage infrastructure, I object to the proposals in their current form due to unresolved cumulative impacts, uncertainty regarding associated transmission infrastructure, and reliance on non finalised or non committed visual mitigation measures.
This submission is intended to assist the consent authority in determining whether the proposals satisfy the requirements of the SEARs and whether the environmental impacts have been adequately identified, assessed and mitigated. At present, the documentation does not provide sufficient certainty regarding key infrastructure elements, nor does it demonstrate that the proposed mitigation measures will be effective, enforceable or timely. As a result, I consider that the environmental impacts of both developments have not been comprehensively or reliably assessed.

1. BASIS OF OBJECTION
My objection is based on the following key issues:
• Inadequate assessment of cumulative impacts across both projects
• Reliance on mitigation rather than inherent design compliance
• Insufficient certainty regarding long term environmental and visual outcomes
• Lack of defined transmission infrastructure alignment and form
• Dependence on conceptual landscape screening that is not fixed or immediately effective

2. TRANSMISSION INFRASTRUCTURE – CRITICAL GAP
The EIS confirms that both projects require connection to the existing Rothbury Substation, with transmission infrastructure potentially comprising overhead or underground lines. However:
• The final alignment of transmission connections is not defined
• The method of connection (overhead vs underground) remains unresolved
• It is unclear whether transmission infrastructure will extend north of the site or beyond the immediate development footprint
While existing transmission lines run broadly north–south along Wine Country Drive, the documentation does not establish whether additional overhead lines will be constructed outside the defined development area.
Concern
This creates a significant gap in understanding the full extent of impacts, including:
• Visual and landscape impacts beyond the site
• Potential impacts on additional rural properties
• Incremental infrastructure intensification within the locality
Without defined transmission infrastructure, the full impact of the developments has not been adequately assessed.
Request
• Transmission alignment must be clearly defined prior to determination
• A firm position must be provided on overhead versus underground infrastructure
• All associated transmission infrastructure, including any potential extensions, must be fully assessed

3. VISUAL AND LANDSCAPE IMPACT – RELIANCE ON UNCERTAIN MITIGATION
The Landscape Plan relies on:
• 10 metre wide buffer planting along parts of the site
• Windbreak style planting in selected areas
• Fragmentation of views rather than full screening
Concern
• Landscaping is identified as indicative only and not construction detail
• Species selection, density and layout remain subject to future design
• Screening is intended to reduce visibility, not eliminate it
• Effectiveness depends on long term vegetation establishment
In practical terms:
• Early years following construction will have limited screening
• Full mitigation will take many years to develop
• Short to medium term visual impacts will be greater than assessed
Additional Concern – Transmission Link
The lack of defined transmission infrastructure compounds this issue. Any additional overhead lines:
• Would not benefit from comparable screening
• Could extend into areas not currently assessed as sensitive receivers
Request
• Visual assessment must account for realistic vegetation establishment timeframes
• Greater weighting should be given to short and medium term impacts
• Landscape mitigation must be clearly defined, enforceable and performance based
• Transmission infrastructure must be assessed independently of assumed screening

4. CUMULATIVE IMPACT
Both projects:
• Are located in immediate proximity
• Share infrastructure corridors
• May be constructed concurrently
• Introduce overlapping environmental impacts
Concern
There is limited evidence of:
• Integrated modelling of concurrent impacts
• Assessment of worst case combined scenarios
Request
• Full cumulative modelling across both developments
• Assessment of concurrent construction and operation

5. NOISE
The assessments identify that:
• Construction noise may exceed criteria under worst case conditions
• Compliance relies on mitigation and staging
Concern
• Noise impacts may intensify with overlapping construction
• Combined worst case noise has not been clearly assessed
Request
• Modelling of cumulative noise under concurrent conditions
• Post construction compliance testing under cumulative scenarios

6. CONSTRUCTION AND TRAFFIC
Construction impacts include:
• Short duration but high intensity activities
• Reliance on management measures such as notification
Concern
If construction overlaps between projects, impacts may be:
• More frequent
• More prolonged
• More disruptive to local amenity
Request
• Coordinated staging across both developments
• Limits on cumulative construction traffic

7. BIODIVERSITY
The assessments confirm:
• Clearing of native vegetation, including threatened ecological communities
• Reliance on offsets to address residual impacts
Concern
• Impacts are not fully avoided
• Outcomes depend on long term offset success
• Cumulative biodiversity impacts remain unclear
Request
• Clear demonstration of offset effectiveness
• Assessment of cumulative biodiversity impacts

8. COMPLIANCE AND ENFORCEMENT
The assessments rely on assumed:
• Staging
• Operational behaviour
• Mitigation effectiveness
Concern
There is insufficient clarity regarding:
• Compliance enforcement
• Long term monitoring of cumulative impacts
Request
• Independent auditing
• Defined compliance triggers
• Public reporting

9. CONCLUSION
While each development may appear manageable in isolation, the combination of undefined transmission infrastructure and reliance on non finalised and long term landscape screening means that the true impacts of the developments remain uncertain and have not been fully assessed.
FINAL POSITION
For these reasons, I object to the projects in their current form.
I request that consent not be granted unless:
• Transmission infrastructure is fully defined and assessed
• Landscape mitigation is finalised, enforceable and realistically assessed over time
• Cumulative impacts across both developments are comprehensively modelled
• All associated infrastructure impacts are clearly resolved

Yours sincerely,
Gregory Stuart,
35 Crown Line Drive, Rothbury

Declaration of Objection:
I am writing to register my strong objection to the proposed Sunshine Estate (SDD-92914712)/ Rothbury Battery Energy
Storage System (SSD-85939708). As a local community stakeholder, I request that the Department of Planning, Housing
and Infrastructure refuse consent for this development based on the critical deficiencies in the proponent's Environmental
Impact Statement (EIS)
Technical Grounds for Objection:
• Inadequate Bushfire and Thermal Runaway Risk Management: The proposed installation of 140 lithium-ion battery
containers represents a catastrophic hazard profile for the immediate Rothbury area.
Thermal Runaway and Toxic Gas Outgassing: Lithium-ion BESS facilities carry an inherent risk of thermal runaway, which
releases highly toxic gases including Hydrogen Fluoride (HF), Carbon Monoxide (CO), and volatile organic compounds. The
EIS fails to demonstrate an adequate air-quality dispersion model detailing how these toxic plumes would impact nearby
residential properties and vineyards under dominant local wind conditions.
Overburdening of Local Emergency Services: The Rothbury and broader Cessnock area relies heavily on the Volunteer
Rural Fire Service (RFS). The EIS does not present a comprehensive Fire and Emergency Response Plan developed in
direct concurrence with Fire and Rescue NSW and the RFS. A major BESS fire requires millions of liters of water to cool
over several days; the EIS has not identified a sustainable, onsite water supply that does not compromise the local
domestic water network or sensitive rural water tables.
• Substantial Impacts on the Existing Local Road Network: The construction phase is slated to introduce heavy vehicle
traffic, ranging up to 26-meter B-Double transport trucks, onto Wine Country Drive and surrounding local feeder roads over
an 18-month period.
Cumulative Damage to Road Infrastructure: The current pavement design of local access roads is completely unsuited to
sustain the heavy axle loads associated with moving massive high-voltage transformers and utility-scale battery
enclosures. The EIS significantly downplays the physical wear and tear on the road network.
Traffic Disruption on Wine Country Drive: Wine Country Drive is a critical tourism and commuter artery for the Hunter
Region. Introducing heavy vehicle movements at the proposed upgrade access points will create severe congestion,
decrease road safety, and disrupt local businesses that rely on seamless tourist access. The mitigation measures proposed
in the traffic assessment are entirely inadequate.
• Destruction of Critical Local Biodiversity & Threatened Species Habitat: The project area spans approximately 50
hectares, with a massive direct disturbance footprint.
Impact on Matters of National Environmental Significance (MNES): The clearing of native vegetation directly threatens
known habitats for critical local species, including foraging structures for threatened Black Cockatoos and core habitat for
vulnerable local fauna.
Flawed Avoidance and Offset Logic: The proponent's claim that a "worst-case scenario" footprint will be reduced post
approval is unacceptable. The Department must assess the actual, definitive footprint now. The proposed biodiversity
offsets do not compensate for the immediate, localized loss of ecosystem connectivity and mature canopy clearing within
the Rothbury area.
• Severe Visual Amenity and Noise Impacts on a Rural-Tourism Zone: The scale of the industrial infrastructure
proposed—including 140 containers, 42 inverters, high-voltage substations, 132kV sub-transmission lines, and 7-meter
wide access roads—is fundamentally incompatible with the rural, landscape-tourism character of Rothbury.
Inadequate Visual Screening: The current tree-line shielding is insufficient to hide 3-meter-high industrial containers and
high-voltage grid infrastructure from neighboring properties and key transport corridors. The proposed landscape
buffering will take years to mature, leaving an industrial scar in a prominent rural area.
Operational Inverter Noise: The continuous low-frequency hum generated by 42 Power Conversion Systems (inverters)
and cooling fans operating 24/7 will severely degrade the acoustic amenity of the surrounding rural environment. This
continuous background noise has been poorly modeled and will heavily impact the quality of life for nearby residents.
Anthony Poole

Submission Objecting to SSD-92914712 – Avenis Sunshine Estate Battery Energy Storage System, Rothbury
To the Department of Planning, Housing and Infrastructure,
I wish to lodge a formal objection to State Significant Development Application SSD-92914712 for the proposed Avenis Sunshine Estate Battery Energy Storage System at Rothbury.

I respectfully request that consent not be granted unless the Department is satisfied that the environmental, safety and community impacts have been fully assessed and demonstrated to be acceptable. Based on the Environmental Impact Statement, I believe there remain significant unresolved concerns.

My concerns include the following.

Bushfire, battery fire and emergency response
Large-scale lithium-ion battery storage facilities present risks that differ significantly from conventional industrial developments. Although the EIS discusses fire management, I do not believe it adequately demonstrates how a major battery fire or thermal runaway event could be safely managed within this location.

The assessment should provide greater detail regarding:
emergency response procedures developed in consultation with Fire and Rescue NSW and the NSW Rural Fire Service;
the availability of sufficient onsite water supplies for prolonged fire suppression without affecting local water resources;
management of toxic gases that may be released during a thermal runaway event; and
potential impacts on nearby residents, agricultural properties and businesses under varying weather conditions.

These matters require greater certainty before approval is considered.

Traffic and road impacts
Construction will require significant heavy vehicle movements over an extended period.

Wine Country Drive is an important regional transport corridor serving residents, tourists, vineyards and local businesses. Additional heavy vehicle traffic has the potential to:

reduce road safety;
increase congestion;
accelerate deterioration of local roads; and
affect tourism and local economic activity.

The proposed mitigation measures do not appear to fully address these cumulative impacts.

Biodiversity
The proposal would disturb a substantial area of land and native vegetation.

The EIS should provide greater certainty regarding:

impacts on threatened species and their habitat;
fragmentation of wildlife corridors;
cumulative biodiversity impacts in the Rothbury area; and
whether proposed offsets genuinely compensate for permanent habitat loss.

Offsetting should not replace the avoidance of impacts where practical alternatives exist.

Visual character
Rothbury is recognised for its rural landscape, vineyards and tourism appeal.

The introduction of extensive battery infrastructure, substations, fencing, lighting and associated electrical equipment represents a substantial industrial development that may permanently alter the visual character of the area.

Landscape screening vegetation will require many years to establish and may not adequately mitigate these impacts.

Noise
Continuous operation of battery cooling systems, transformers and inverters has the potential to generate ongoing background noise.

Further independent assessment should be undertaken to demonstrate that nearby residents and rural properties will not experience unacceptable noise impacts during both day and night.

Cumulative impacts
This proposal should not be assessed in isolation.

The Department should carefully consider the cumulative impacts of this project together with the adjacent proposed battery energy storage development, particularly regarding:

bushfire risk;
emergency management;
traffic generation;
landscape character;
biodiversity;
infrastructure demand; and
the combined industrialisation of the Rothbury locality.

These cumulative effects appear to have received insufficient consideration.

For these reasons, I respectfully request that the Department refuse SSD-92914712 unless these significant issues can be satisfactorily resolved through additional independent assessment.

Thank you for considering my submission.

Declaration of Objection
I am writing to register my strong objection to the proposed Sunshine Estate [SSD-92914712] Rothbury Battery Energy Storage System [SSD-85939708]. As a local community stakeholder, I request that the department of planning, Housing and Infrastructure refuse consent for this development based on the critical deficiencies in the proponent’s Environmental Impact Statement [EIS]
Technical Grounds for Objection
. Inadequate Bushfire and thermal Runaway Risk Management: The proposed installation of 140 lithium-ion battery containers represents a catastrophic hazard profile for the immediate Rothbury area.
Thermal Runaway and Toxic Gas Outgassing Lithium-ion BESS facilities carry an inherent risk of thermal runaway, which releases highly toxic gases including Hydrogen Fluoride [HF], carbon Monoxide [CO] , and volatile organic compounds. The EIS fails to demonstrate an adequate air-quality dispersion model detailing how these toxic plumes would impact nearby residential properties and vineyards under dominant local wind conditions.
Overburdening of Local Emergency Services: The Rothbury and broader Cessnock area relies heavily on the Volunteer Rural Fire Service [RFS]. The EIS does not present a comprehensive Fire and Emergency response plan developed in direct concurrence with Fire and Rescue NSW and the RFS. A major BESS fire requires millions of litres of water to cool over several days; the EIS has not identified a sustainable, onsite water supply that does not compromise the local domestic water network or sensitive rural water tables.
. Sustainable Impacts on the Existing Local Road Network; The construction phase is slated to introduce heavy vehicle traffic, ranging up to 26-metre B-Double transport trucks, into wine country drive and surrounding local feeder roads over an 18-month period.
Cumulative Damage to Road Infrastructure; The current pavement design of local access roads is completely unsuited to sustain the heavy axle loads associated with moving massive high-voltage transformers and utility scale battery enclosures. The EIS significantly downplays the physical wear and tear on the road network.
Traffic disruption on wine Country Drive. Wine Country drive is a critical tourism and commuter artery for the Hunter Region. Introducing heavy vehicle movements at the proposed upgraded access points will create severe congestion, decrease road safety, and disrupt local businesses that rely on seamless tourist access. The mitigation measures proposed in the traffic assessment are entirely inadequate.
. Destruction of Critical local Biodiversity& Threatened Species Habitat; The Project area spans approximately 50 hectares, with a massive direct disturbance footprint.
Impact on Matters of National Environmental Significance [MNES]; The clearing of native vegetation directly threatens known habitats for critical local species, including foraging structures for threatened Black Cockatoos and core habitat for vulnerable local fauna.
Flawed Avoidance and offset logic; The proponent’s claim that a “worst case scenario” footprint will be reduced post-approval is unacceptable. The department must assess the actual, definitive footprint now. The proposed biodiversity offsets do not compensate for the immediate, localised loss of ecosystem connectivity and mature canopy clearing within the Rothbury area.
. Severe Visual Amenity and Noise Impacts on a Rural-Tourism Zone; The scale of the industrial infrastructure proposed-including 140 containers,42 inverters, high voltage substations,132kV sub-transmission lines, and 7-metre-wide access roads-is fundamentality incompatible with the rural, landscape-tourism character of Rothbury.
Inadequate Visual Screening. The current tree line shielding is insufficient to hide 3-metre-high industrial containers high-voltage grid infrastructure from neighbouring properties and key transport corridors. The proposed landscape buffering will take years to mature, leaving an industrial scar in a prominent rural area.
Operational Inverter Noise: The continuous low frequency hum generated by 4 Power Conversion Systems [inverters] and cooling fans operating 24/7 will severely degrade the acoustic amenity of the surrounding rural environment. This continuous background noise has been poorly modelled and will heavily impact the quality of life for nearby residents.

I object to this proposal and I ask the Department to refuse it.

I live in the Cessnock area and I know this landscape. A 120 MW / 480 MWh lithium battery plant does not belong in a rural, agricultural and tourism valley like Rothbury, and the material on exhibition does not come close to proving it is safe here. My objection is unconditional. The points below are all planning matters the Department has to weigh under section 4.15 of the EP&A Act, in particular whether this is in the public interest.

The fire risk is real and it cannot be put out.
A battery fire of this kind is not fought and extinguished. The accepted approach is to cool everything around it and let the batteries burn themselves out over hours or days. The Victorian Big Battery at Moorabool burned for about three days in 2021 and was left to burn out. Moss Landing in California burned over several days in January 2025 and then reignited 33 days later from energy still trapped in the cells. Both of Australia's grid-scale battery fires so far, Moorabool in 2021 and Bouldercombe in 2023, happened during commissioning. Industry incident data shows most failures happen during construction, commissioning or the first couple of years of operation, and that around one in four operating systems inspected had fire-suppression faults. This is a hazard that arrives early and lingers.

A battery fire poisons the air, and our valley traps it.
When these cells burn they release hydrogen fluoride, hydrogen cyanide, carbon monoxide and a load of volatile organic compounds. Measured studies put hydrogen fluoride output at a level that, for a plant this size, runs into tens of tonnes under a full burn. Hydrogen fluoride is both a corrosive acid and a systemic poison, and its cruelty is the delay: a person can feel fine and then develop life-threatening fluid on the lungs 12 to 48 hours later. The exhibited material contains no proper dispersion model showing where that plume goes over our homes and vineyards. That matters here more than most places. The Hunter is channelled by strong north-westerly winds that on hot days push south-east, straight toward Cessnock and the housing. The summer sea breeze pushes the other way, into the Pokolbin vineyards. The Brokenback Range traps smoke and drains it back down into the valley, which is exactly why up to 90% of the 2020 Hunter vintage was lost to smoke taint. On a still night a toxic plume would just sit here. None of that is modelled.

The people sent to it get hurt, even when they only contain it.
"Containment" does not mean the crew is safe. At McMicken in Arizona in 2019, accumulated gas from a battery unit deflagrated when firefighters opened it to assess it. They were not even fighting the fire. Nine responders were caught, four career firefighters were seriously injured, two with traumatic brain injury, and one was thrown more than 70 feet by the blast. Out here the response is our volunteer Rural Fire Service, and longer response times mean more gas builds up before anyone arrives, which makes that exact failure more likely, not less. The material on exhibition does not include a fire and emergency response plan agreed with Fire and Rescue NSW and the RFS, and it does not identify a real, independent water supply for a fire that needs enormous volumes of water over many hours without draining the town supply or the local water table. Firefighting is already classed by the World Health Organisation's cancer agency as a Group 1 carcinogen for the people who do it, and a battery fire piles a concentrated load of toxic metals on top of that.

This is bushfire country, and summer is when it burns.
The site sits on mapped bush-fire-prone land, and the danger runs both ways. A bushfire front reaching this plant can drive the cells into thermal runaway, and it does not even take a flame touching the plant to do it. These cells go into thermal runaway at around 150 to 190 degrees, and a fire front radiates heat at levels that rate a building as flame zone from tens of metres away. A steel battery enclosure with its cooling knocked out, which is exactly what happens when a bushfire takes the site power, behaves like a closed oven and can be driven to that runaway temperature by radiant heat alone, with no flame ever touching it. Going the other way, a battery fire that burns for hours or days and throws intense radiant heat can start a grassfire around it. Summer is the sharp end of this, and summer is also harvest and peak tourist season, so the window of worst fire weather is the same window when the vineyards are hanging fruit and the region is full of visitors. This exact area has a hard fire record. In the 2019-20 Black Summer a major blaze ran near Laguna and Cessnock and our local brigades fought fires across Cessnock, Wollombi and Laguna; the 154,000 hectare Little L Complex to the west forced backburning around Broke-Fordwich that threatened the Hunter vintage, and up to 90% of the 2020 Hunter crop was lost to smoke taint. In December 2023 three fast-moving fires broke out in a single afternoon and put Abermain, Kurri Kurri, South Weston and Pelaw Main under emergency leave-now warnings, with flames reaching fences. Pokolbin itself has had a major bushfire on Halls Road that forced residents to evacuate. Dropping a fire source that cannot be extinguished into that landscape, and then relying on a volunteer brigade to hold it under those summer conditions, is exactly the scenario the exhibited assessment fails to deal with in either direction. It does not model a bushfire heating the cells into runaway by radiation alone, it does not show the separation distance needed to keep the cells below their runaway temperature during a flame-zone front with the site power lost, and it identifies no passive fire barrier that still works once the cooling is dead.

The site holds species that exist nowhere else, and the report that assesses the damage was never put on exhibition.
The proponent's own federal referral confirms the Hunter Valley Delma, an endangered legless lizard, on the site, and names it as the trigger that makes this a controlled action needing Commonwealth approval, with a conceded potential for significant impact. The site sits in the range of the North Rothbury Persoonia, a critically endangered plant whose entire world population is in this small locality, and in Regent Honeyeater and Swift Parrot habitat. Yet the biodiversity report, the document that actually measures the damage and tests it for serious and irreversible impact, had not been done at the time of the referral. The disturbance footprint on exhibition is called a worst case to be trimmed later. So the Department is being asked to approve the biodiversity impact without the final footprint and without the report that assesses it. For a plant that lives nowhere else on earth, that is not a detail to sort out after approval.

A battery fire is worse for vineyards than a bushfire.
Its smoke carries hydrogen fluoride and metal particles, and a fire in the pre-harvest or harvest window could wipe out entire crops across the surrounding vineyards. The water used to fight it runs off carrying nickel, cobalt, manganese and fluoride into a catchment that drains to the Hunter River and the groundwater the vineyards irrigate from. The surrounding wine and tourism economy is worth around $557 million a year, and the 2019-20 smoke-taint season alone cost roughly $160 million. The exhibited material does not properly assess either the smoke or the runoff pathway.

The roads, the two-plant load, and the clean-up bill.
Construction runs heavy vehicles, transformers and battery units over Wine Country Drive, a tourism and commuter road not built for that load, and the traffic study ignores that a second battery plant next door (SSD-85939708) would be doing the same thing at the same time. Together these two proposals put roughly 255 MW and 1,020 MWh of storage into one small locality, and neither assessment looks at the combined fire, water, traffic and noise burden. On top of that, the material secures no real money for the clean-up. Retired batteries of the chemistry now used cost money to recycle rather than being worth anything, and if the operator folds, the community is left with a hazardous, contaminated site and no funds to clear it.

What I ask.
These are not things a few conditions can fix after approval. They go to whether this is a proper use of this land in the public interest, and on what has been put on exhibition, it is not. I ask the Department to refuse SSD-92914712. If it will not refuse, I ask that it defer the decision and re-exhibit only after a full hazard and toxic-plume assessment tied to our actual weather, a fire and emergency response plan agreed with Fire and Rescue NSW and the RFS with a secured independent water supply, a human-health risk assessment, a genuine combined assessment of both battery plants together, a final biodiversity footprint tested for serious and irreversible impact, an assessment of the smoke-taint and firewater pathways to the vineyards and catchment, and secured funding for decommissioning.

If you unpack every part and the toxicity it holds, I cannot believe these projects get approval.
Let alone the slave like conditions these international companies put their workers in.
The cost to the taxpayer and environment far outweighs the overall impact that people like to sell about BESS's.
Money blinds the common sense and critical thinking for these projects.

I would like to begin by acknowledging the farmers of the land within our great nation of Australia today. I pay my respects to Australia’s past, present and future farmers who have and will continue to battle setbacks such as renewable energy destruction, drought, floods, vermin plagues, diseases, and government policy, all so they can provide Australia with food and fibre. I acknowledge that these setbacks come at a high price of mental health, and many have taken their lives as a result due to such pressures. I extend this respect and am thankful for the sacrifices those within the agricultural industry make in order to provide Australia with the essentials; I acknowledge the agricultural industry as the backbone of our nation
We need to unite and fight these developers and the Australian government for forcing this upon us.
CONFIDENTIAL:
I object because BESS projects are too damaging to the communities, landscapes, environment and animals. what happens when they catch fire? How will the noise from BESS impact livestock and native wildlife? Not only are they dangerous, they are an absolute eye-sore. Let's put these closer to the cities so all the NIMBYs can marvel at what their vote has given them. Leave our landscapes alone and our government needs to do better.
Noting the Livestock Producer Assurance accreditation application, they recognise and acknowledge that agricultural land WILL BE POISONED by batteries and solar panels. Given this significant fact, these projects should NOT go ahead as they compromise our food security and environmental safety.

This infrastructure is too dangerous to the neighbouring properties and communities. BESS factories and overhead transmission lines are a significant fire risk. BESS factories cause significant noise pollution. Stop destroying rural land and landscapes with these toxic and destructive projects. I object to this project.

I object to the Sunshine Estate BESS project.
Why is our government forcing FIRE HAZARDOUS infrastructure and UNRELIABLE energy on our nation at the expense of rural Australia?!?
Save the land that supports and produces food and fibre for Australia. Put these elsewhere! Stop bowing down and bending over to the EVIL powers of the WEF.
These projects are destroying rural Australia and will send future generations broke!!

I would like to begin by acknowledging the farmers of the land within our great nation of Australia today. I pay my respects to Australia’s past, present and future farmers who have and will continue to battle setbacks such as renewable energy destruction, drought, floods, vermin plagues, diseases, and government policy, all so they can provide Australia with food and fibre. I acknowledge that these setbacks come at a high price of mental health, and many have taken their lives as a result due to such pressures. I extend this respect and am thankful for the sacrifices those within the agricultural industry make in order to provide Australia with the essentials; I acknowledge the agricultural industry as the backbone of our nation
We need to unite and fight these developers and the Australian government for forcing this upon us.
I object because this project will cause permanent toxic damage to the natural environment and impact those around it. There will be too many toxic chemicals and EMF entering the landscapes and environment as a result of this project.

CONFIDENTIAL:
I would like to begin by acknowledging the farmers of the land within our great nation of Australia today. I pay my respects to Australia’s past, present and future farmers who have and will continue to battle setbacks such as renewable energy destruction, drought, floods, vermin plagues, diseases, and government policy, all so they can provide Australia with food and fibre. I acknowledge that these setbacks come at a high price of mental health, and many have taken their lives as a result due to such pressures. I extend this respect and am thankful for the sacrifices those within the agricultural industry make in order to provide Australia with the essentials; I acknowledge the agricultural industry as the backbone of our nation
This battery energy storage system and related infrastructure are a major fire risk and will put significant strain on local and rural firefighting services. These local firefighting services are not equipped with the resources or man-power to manage emergency fires for when they do break out at this site. Why should the broader community risk their lives and step up to fight fires for infrastructure that they never wanted there in the first place?

I object. I am an 4th generation farmer and agricultural land should not be permanently destroyed to host/house/harbour these projects. I fear for our agricultural industry should all these projects go ahead. Where do those in the cities who agree to/design and develop these projects think their food comes from? Their woke, unreliable ideologies have no place on primary farming land.
What happens when this BESS catches fire? What about toxic run-off from this? What about the toxic chemicals that enter our soil? What about toxic run-off into water systems?
This projects needs to be cancelled due to the disastrous environmental and health impacts.

BESS is dangerous and brings hazards to the project and community.
The noises from this BESS project will have negative impacts on the nearby livestock and wildlife. These impacts will be evident in not only everyday life for the animals, but also during breeding and birthing cycles. BESS carries significant fire risk. The proposal of new transmission lines bring significant EMF hazards and as such, should not go ahead.

BESS factories are destroying the landscapes and significantly devaluing residential, agricultural and commercial properties within rural communities. Nobody would want to live anywhere near this heap of fire-causing garbage.
Nuclear MUST be explored. I OBJECT to the BESS and ALL renewable projects that are proposed for Australia. I object to the Sunshine Estate BESS and related infrastructure. Leave rural Australia ALONE!

Border Force admit that imported BESS, Solar Panels and Wind Turbines are unregulated - with banned substances that they contain like PFAS/PFOS and Asbestos being ignored.

There is no supply chain transparency for unethically sourced components - where the origin, manufacturing standards and environmental practices require far greater scrutiny.

Imported infrastructure should be subject to rigorous verification of safety, security, environmental and ethical standards.

Why does the dodgy NSW Government and NON-independent IPCN keep ignoring these essential facts?

This project is an environmental disaster. Building this on flood prone land in a bush fire zone is nothing short of environmental vandalism. The local community will be covered in toxic smoke if there is a thermal runaway event at this BESS. A fire on this scale has to burn out, it cannot be extinguished. This is a waste of taxpayer funds and will only supply unaffordable unreliable electricty for consumers. No ability to recycle spent batteries. Too much slave labour used to mine the resources for the batteries. We want 24/7 affordable electricity. This project is NOT in the public interest.

UNclean, UNregulated, UNreliable, UNsafe, UNethical, UNeconmical Sunshine BESS fails to apply the Precautionary Principle.

Significant uncertainties remain regarding life-threatening, large-scale lithium-ion battery risks, environmental consequences and emergency management requirements as the irresponsible and underhanded DPHI and complicit IPCN continually fail to do diligent risk research prior to their inhumane, ecocidal approvals.

Where serious or potentially irreversible harm cannot be ruled out, the precautionary principle requires decision-makers to demand stronger evidence before proceeding.

We fiercely object to this filthy Sunshine Estate BESS scam as we are extremely alarmed about lethal gas plumes, toxic hydrofluoric acid, accidental releases, firewater runoff, damaged equipment and long-term degradation and leakage that will create contamination pathways affecting soil, waterways, surrounding land uses and the public.

The assessment of this toxic disaster must require prior independent risk research and only after that proof of public health and safety as well as demonstrating robust prevention, monitoring and remediation measures as contamination pathways have not even been addressed.

HVWTA is not opposed to additional power infrastructure in the Hunter region. Power reliability has a direct and material impact on our members' businesses. Outages and point-in-time restoration delays contribute to significant annual income losses for tourism operators and require additional resourcing and equipment to manage. On that basis, we would welcome investment that improves power reliability for the region. We acknowledge that battery energy storage infrastructure can be appropriate where it is compatible with surrounding land uses. Our concern with this proposal is that it is located within one of Australia's most recognised wine tourism landscapes rather than within an established industrial area.

Hunter Valley Wine Country is not simply a rural landscape. It is an internationally recognised wine and tourism destination whose economy depends upon the preservation of its landscape character and visitor experience. Land-use compatibility should therefore be assessed not only against adjoining land uses, but also against the strategic role this precinct plays within the regional visitor economy. Unlike projects located within established industrial estates, this proposal introduces industrial-scale infrastructure into a tourism-defined landscape containing vineyards, cellar doors, accommodation, restaurants and visitor attractions.

The proposal should also be assessed against the long-term planning vision for the Cessnock Vineyard District, which seeks to protect the landscape values that underpin tourism, wine production and investment confidence.

Cumulative Impact
We note that two projects are being assessed separately and as isolated projects, these being the Rothbury BESS at 1309 Wine Country Drive (Ausgrid) and the Sunshine Estate BESS at 1337 Wine Country Drive (Avenis) but note that we are providing feedback in respect of both. With two BESS proposals in close proximity, sharing a connection point and overlapping impact areas, we are concerned the cumulative effect on visual amenity, noise, traffic and the broader character of this stretch of Wine Country Drive has not been adequately assessed from a tourism perspective.

While each project is assessed individually, visitors experience the landscape cumulatively. The relevant question is therefore not whether each individual project is acceptable in isolation, but whether the combined effect of multiple infrastructure projects materially alters the character of this section of Wine Country Drive.
We ask for consideration on how many similar developments this corridor could reasonably absorb before visitor experience and destination identity are materially affected, and what long-term vision exists for infrastructure development within this precinct, noting the project's expected 50-year operational life.

Visual Impact and Destination Character
Wine Country Drive is the primary arrival corridor into Hunter Valley Wine Country, and visitor first impressions are formed travelling this route. These sites currently have open acreage, horses, neighbouring vineyards and accommodation. The EIS itself acknowledges that visual impact was one of the most raised community concerns, with assessments undertaken from Wine Country Drive, Scarborough Cottage accommodation, the Black Creek Farm wine tasting deck, and nearby residences. We would add that the site sits opposite Greenacres, a large group accommodation property and private residence at the Old North Road corner, further underscoring the sensitivity of this location to visual and amenity impacts. We ask whether proposed landscaping and screening are genuinely sufficient to maintain the visual standard expected of Australia's oldest wine region, and whether this development sets an undesirable precedent for industrial-scale energy infrastructure within a tourism-defined precinct.

Construction Traffic and Visitor Access
Wine Country Drive access for tourism, accommodation and cellar door operators must be protected throughout construction. We request firm conditions restricting major construction activity and traffic disruption during peak visitation periods, including long weekends, school holidays and major regional events.

Noise, Fire Risk and Visitor Perception
While the EIS concludes noise and fire risk impacts are manageable, we note that perception matters significantly in a visitor economy, particularly given proximity to vineyards, accommodation providers and outdoor dining and tasting experiences. We ask that emergency response planning explicitly account for nearby tourism accommodation and visitor activity, and that this be communicated clearly to operators in the area, including those at Black Creek, where tourism operators and managers reside on site. We note that noise was raised as a concern, including from the cumulative effects from two BESS. We seek confirmation that any proposed noise wall does not create any additional visual impacts.

Economic Assessment
We ask that the economic assessment more fully accounts for the value of tourism expenditure, wine industry output, destination brand value, and accommodation and property investment in this precinct, alongside the stated benefits of construction employment and energy reliability.

Community Benefit
Should either project proceed, HVWTA requests that a meaningful share of the proposed Community Benefit Fund be directed toward visitor-economy and landscape improvements, in recognition of the precinct most directly affected.

Should consent ultimately be granted, HVWTA requests that conditions of consent include:
-coordinated cumulative monitoring with the neighbouring Rothbury BESS;
-strengthened landscape screening requirements, including establishment targets across both sites;
-restrictions on construction during major tourism periods;
-ongoing consultation with nearby tourism operators;
-periodic review of visual screening effectiveness throughout the operational life of the project; and
-clear decommissioning obligations to ensure the site can be restored at the end of its operational life.

We would welcome the opportunity to discuss these matters further and to be consulted on any conditions of consent.

Much Greater Independent Scrutiny is required for this Battery Energy Storage System (BESS) at Wine Country Drive, Rothbury as it represents one of the most significant public health and safety risks associated with this State Significant Development.

The proposal involves an industrial-scale lithium-ion battery installation that introduces hazards fundamentally different from and far more dangerous than those associated with conventional electrical infrastructure. These include:
* thermal runaway;
* prolonged battery fires;
* release of highly toxic combustion products, including hydrogen fluoride;
* lethal smoke and airborne contaminants;
* complex emergency response requirements;
* contaminated firefighting water;
* hazardous battery transport and disposal at end of life.

The Applicant claims to have various management measures to address these hazards. However, reliance upon unproven, experimental technology and proposed controls is not equivalent to demonstrating that worst-case events have been comprehensively assessed or that their consequences are acceptable.
For a development of this scale and hazard profile, independent expert assessment of catastrophic failure scenarios is essential.

Compliance With Standards Is Not Sufficient
Throughout the Environmental Impact Statement, the Applicant relies heavily upon compliance with engineering standards, manufacturer specifications and future management plans.
Compliance with standards is necessary but it is not sufficient.
The Department must be satisfied that reasonably foreseeable catastrophic failure scenarios have been independently evaluated and that the resulting consequences are not harmful in any way to the public or hazardous to our soil heritage, vital water sources and precious biodiversity.
That evidentiary threshold has not been met.

Large-scale lithium-ion battery systems remain an evolving technology. International experience continues to identify new failure mechanisms, operational challenges and emergency response issues despite claimed compliance with engineering standards.

Numerous international incidents have demonstrated that utility-scale battery failures can involve prolonged fires, thermal runaway, toxic gas releases, explosions during emergency response and lengthy site closures.
These events demonstrate that catastrophic failure is a credible planning consideration requiring rigorous independent expert assessment rather than reassurance through management plans alone.

Thermal Runaway Cannot Be Eliminated
No lithium-ion Battery Energy Storage System can eliminate the possibility of thermal runaway.
International investigations have identified numerous initiating mechanisms, including:
* manufacturing defects;
* internal cell failures;
* electrical faults;
* mechanical damage;
* overheating;
* water ingress;
* installation defects;
* maintenance failures;
* software or control system malfunction;
* external fire exposure.

Once initiated, thermal runaway may rapidly propagate between cells, modules or containers despite sophisticated battery management systems.

The relevant planning question is therefore not whether thermal runaway is unlikely.
It is whether the Applicant has demonstrated, through independent evidence, that the consequences of a worst-case thermal runaway event will not pose dangerous public health and safety risks to nearby residents and emergency responders or poisonous impacts for agricultural land, groundwater, biodiversity or surrounding communities.
The Environmental Impact Statement does not adequately demonstrate this.

Fire Behaviour Has Been Underestimated
Lithium-ion battery fires differ fundamentally from conventional fires.
International experience demonstrates that such fires are extremely hazardous and usually:
* burn for many hours or days;
* repeatedly reignite after apparent extinguishment;
* require prolonged cooling operations;
* generate contaminated firefighting water;
* release hazardous combustion products;
* require extensive exclusion zones.

Emergency services have, in numerous overseas incidents, adopted defensive strategies because extinguishment was considered impractical or unsafe.
The Applicant states that emergency procedures will be developed. They themselves need to be present on site to fight these fires themselves instead of poisoning the RFS.
The existence of procedures does not establish that sufficient emergency capability exists to safely manage a prolonged utility-scale battery fire within a rural setting.

Rural Emergency Response Has Not Been Demonstrated
The proposal is located within a rural district where specialist emergency response resources are inherently more limited than those available within metropolitan areas.
The Environmental Impact Statement provides insufficient analysis of:
* hazardous materials response times;
* availability of specialist firefighting resources;
* prolonged deployment capability;
* firefighter fatigue;
* respiratory protection requirements;
* contaminated runoff management;
* inter-agency coordination;
* water availability during drought.

These are practical operational issues rather than theoretical considerations.
The Applicant has not demonstrated that regional emergency services possess the personnel, equipment and specialist training necessary to safely manage a multi-day utility-scale, highly toxic battery incident.
Without that evidence, assertions regarding acceptable residual risk remain unsubstantiated.

Toxic Emissions Require Much Greater Assessment
Thermal decomposition of lithium-ion batteries generates complex mixtures of hazardous gases, including:
* hydrogen fluoride;
* hydrogen chloride;
* carbon monoxide;
* volatile organic compounds;
* particulate matter;
* metal-containing aerosols.

Some of these substances present acute and lethal risks to emergency responders and nearby communities.
The Environmental Impact Statement provides limited assessment of atmospheric dispersion modelling for catastrophic battery failure and gives insufficient consideration to:
* livestock exposure;
* contamination of pasture;
* impacts on agricultural production;
* contamination of water storages;
* deposition of hazardous substances onto soils and vegetation;
* long-term environmental monitoring following major fires.

These omissions represent significant failures in the environmental assessment.

Bushfire Interaction Has Not Been Adequately Addressed
New South Wales regularly experiences severe bushfire conditions.
The proposal therefore requires assessment of interactions between external bushfires and the Battery Energy Storage System itself.
Important questions remain unanswered, including:
* whether radiant heat could initiate battery failure;
* emergency access during simultaneous bushfire events;
* impacts of heavy smoke on electrical systems;
* contingency arrangements if evacuation prevents active management of the facility.

Given Australia's bushfire risk, these matters warrant detailed independent expert assessment.

Water Requirements Have Not Been Properly Evaluated
Utility-scale battery fires may require substantial quantities of water depending upon emergency response strategy.
The Environmental Impact Statement does not adequately address:
* availability of sufficient water during drought;
* onsite emergency water storage capacity;
* capture of contaminated runoff;
* disposal of contaminated firefighting water;
* protection of creeks, farm dams and groundwater.

Routine construction water assessments cannot substitute for comprehensive evaluation of emergency water requirements associated with a prolonged battery fire.

Decommissioning and Financial Liability Remain Uncertain
The proposal assumes battery systems will be safely removed and recycled at the conclusion of operations.
However, significant uncertainties remain regarding:
* ultimate responsibility for removal;
* long-term financial security;
* potential insolvency of future operators;
* availability of domestic recycling capacity;
* hazardous waste transport and disposal.

The absence of a guaranteed rehabilitation/decommissioning bond is totally unacceptable with no
certainty regarding future environmental liabilities.

Independent Verification Is Essential
Throughout the Environmental Impact Statement, confidence is sought through engineering standards, management plans and future operational procedures.
These measures are important.
However, they cannot substitute for independent verification of worst-case public safety and environmental consequences.
Complex industrial systems can and do fail despite compliance with recognised standards.
Responsible planning requires rigorous assessment of credible failure scenarios rather than reliance upon assumptions that all engineering controls will perform as intended throughout the project's operational life.

Residual Risk Has Not Been Adequately Quantified
The Applicant asks the Department to conclude that the residual risks associated with the Battery Energy Storage System are acceptable.
That conclusion has not been justified.
Significant uncertainty remains regarding:
* catastrophic fire behaviour;
* thermal runaway propagation;
* toxic emissions;
* emergency response capability;
* contamination pathways;
* long-term environmental impacts;
* financial liability;
* end-of-life management.

Where substantial uncertainty exists regarding severe, life-threatening consequences, the precautionary principle requires a higher standard of proof via diligent risk research prior to any further plans or approvals being granted.

Conclusion
As the Applicant has not demonstrated, through independent, peer-reviewed evidence, that the proposed BESS can operate throughout its life without exposing nearby communities, emergency responders, agricultural land and the environment to unacceptable risks under reasonably foreseeable worst-case conditions - it must be rejected.