Upper Hunter Battery Energy Storage System

WHY AM I ONLY FINDING OUT ABOUT THIS PROJECT TODAY???
WHERE IS MY PHONE CALL FROM THIS COMPANY TO NOTIFY ME OF THIS LIVING ACROSS THE RD FROM THE ENTRANCE OF WELLS GULLY RD???
I’ve treated “Upper Hunter Best Battery System” as the Upper Hunter Battery Energy Storage System (BESS), SSD-61707209, at Aberdeen. It is currently on public exhibition, with submissions closing 9 October 2026. The current proposal is for a lithium-ion BESS of up to 400 MW / 920 MWh, with a high-voltage substation and grid-connection infrastructure. �
Planning Portal +1
Here is a formal submission you can use:
Writing
To:
NSW Department of Planning, Housing and Infrastructure
Major Projects Assessment
Re: FORMAL OBJECTION AND DISPUTE OF ENVIRONMENTAL IMPACT STATEMENT
Upper Hunter Battery Energy Storage System
SSD-61707209
Campbell Street, Aberdeen, NSW
Dear Sir/Madam,
I write to lodge a formal objection to the Upper Hunter Battery Energy Storage System (SSD-61707209) and to dispute the adequacy of the Environmental Impact Statement submitted in support of the development.
I request that the Department carefully examine whether the EIS provides a sufficiently complete, accurate and precautionary assessment of the environmental, safety, social and cumulative impacts of this development before any determination is made.
The scale and nature of this proposal require a particularly rigorous assessment. A utility-scale lithium-ion battery installation, together with its substation, transformers, transmission infrastructure, access arrangements and associated works, has the potential to create impacts extending considerably beyond the immediate development footprint.
1. ADEQUACY OF THE ENVIRONMENTAL IMPACT STATEMENT
My fundamental concern is whether the EIS has adequately identified, assessed and disclosed the full consequences of the project.
The Secretary's Environmental Assessment Requirements require the EIS to comply with Part 8 of the Environmental Planning and Assessment Regulation 2021 and to address the physical development, environmental and land-use constraints and impacts associated with the proposal.
I request that DPHI independently scrutinise the assumptions, modelling, methodology, baseline information and mitigation measures relied upon by the proponent rather than accepting conclusions simply because they appear in the EIS.
Where information is incomplete, uncertain or dependent upon future detailed design, I submit that the matter should be resolved before determination where it is material to assessing the project's environmental consequences.
2. BATTERY FIRE AND EMERGENCY RISK
Battery fire and emergency response must be treated as a major planning consideration.
A large lithium-ion BESS creates hazards that differ from those associated with ordinary industrial development. The assessment should properly consider credible emergency scenarios, including battery failure, thermal runaway, propagation between battery units, prolonged fires, re-ignition, smoke generation and emergency access.
The Department should require clear evidence regarding:
separation distances between battery units and other infrastructure;
fire detection and suppression systems;
prevention of propagation between battery units;
emergency vehicle access;
firefighting water availability;
containment of contaminated firefighting water;
smoke and potentially hazardous combustion products;
evacuation and emergency response procedures;
potential consequences for neighbouring properties and road users;
management of an incident lasting many hours or days; and
post-fire monitoring, cleanup and disposal.
The assessment should not rely merely upon statements that the facility will comply with relevant standards. DPHI should be satisfied that the actual project design demonstrates an acceptable level of risk for this particular location.
3. CONTAMINATED FIREWATER AND WATER MANAGEMENT
I am particularly concerned about the management of water generated during a major battery fire or other emergency.
The EIS should demonstrate how potentially contaminated firefighting water would be prevented from leaving the development site and entering surrounding drainage lines, waterways, groundwater or neighbouring land.
This requires more than identifying detention or containment infrastructure on a plan.
The Department should establish the capacity of containment systems under a credible major fire scenario, including concurrent rainfall, and determine what would occur if the available containment capacity were exceeded.
The EIS should clearly explain where contaminated water would be stored, tested, treated and ultimately disposed of.
No approval should rely upon an assumption that these matters can simply be resolved after construction or through a future management plan if they are material to determining whether the site is suitable for the development.
4. NOISE
The project has the potential to generate operational noise from battery cooling equipment, inverters, transformers, substations and other electrical and mechanical equipment.
Unlike temporary construction noise, operational noise could continue throughout the life of the development.
The Department should independently examine whether the noise assessment adequately considers the most affected residences and other sensitive receivers, night-time conditions, temperature inversions and other weather conditions capable of increasing noise propagation.
The cumulative effect of multiple noise sources operating simultaneously should also be assessed.
Where compliance depends upon particular equipment specifications, acoustic barriers or operational restrictions, those measures should be clearly identified and capable of being incorporated into enforceable conditions.
5. VISUAL AND LANDSCAPE IMPACT
The visual consequences of large-scale energy infrastructure should not be dismissed merely because the project is situated in a rural or semi-rural landscape.
The BESS, substation, transformers, transmission infrastructure, fencing, lighting and associated infrastructure will alter the existing landscape.
The visual assessment should consider views from surrounding properties, public roads and other relevant viewpoints and should represent the development realistically at construction, commencement of operation and after proposed landscaping has matured.
Photomontages should not depend upon vegetation screening that does not presently exist without clearly showing the period during which the development would remain visible.
The Department should also examine whether proposed vegetation screening can realistically achieve the screening claimed by the proponent and whether that vegetation can be maintained for the operational life of the project.
6. BIODIVERSITY AND COMMONWEALTH ENVIRONMENTAL SIGNIFICANCE
The project has also been identified as a controlled action under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999.
Accordingly, biodiversity impacts warrant careful scrutiny.
I request that the Department ensure that avoidance of environmental impacts is genuinely prioritised ahead of mitigation or offsets and that the assessment accounts for direct and indirect impacts associated with the entire development footprint and associated infrastructure.
7. TRAFFIC AND ROAD SAFETY
Construction of a development of this scale will involve heavy vehicles, construction workers, delivery vehicles and potentially oversized components.
The Department should consider the cumulative impact of this traffic alongside other major energy, mining and infrastructure projects occurring within the broader Upper Hunter and Muswellbrook region.
The assessment should address road capacity, intersection safety, heavy-vehicle movements, school and commuter traffic, emergency access, road deterioration and the cumulative effect of simultaneous construction projects.
8. CUMULATIVE DEVELOPMENT
This proposal must not be assessed as though it exists in isolation.
The Upper Hunter and Muswellbrook region is experiencing substantial development associated with energy infrastructure and other major projects.
The cumulative assessment should therefore consider overlapping construction periods, heavy vehicle movements, workforce demand, accommodation pressures, noise, landscape change, biodiversity impacts and pressure on emergency services.
The relevant question is not merely whether this project, viewed individually, satisfies a particular criterion. DPHI should consider the environmental and social consequences of adding this project to the developments already operating, approved or credibly proposed in the surrounding region.
9. COMMUNITY AND SOCIAL IMPACTS
The people who live near major infrastructure bear impacts that are not necessarily captured by technical modelling alone.
The Department should consider effects upon rural amenity, residents' enjoyment of their properties, perceived and actual safety concerns, landscape character, traffic, noise, community cohesion and the cumulative industrialisation of rural areas.
Community consultation should not be treated as evidence that an impact has been resolved simply because residents were informed about the development.
10. REQUEST FOR FURTHER INFORMATION AND INDEPENDENT REVIEW
Where substantive uncertainties remain, I request that DPHI require the proponent to provide further information before determination.
In particular, I request independent scrutiny of:
battery fire and thermal-runaway risk;
emergency response capability;
contaminated firefighting-water containment;
stormwater and water-quality impacts;
operational and night-time noise;
visual impacts and screening assumptions;
biodiversity impacts;
traffic and cumulative construction impacts;
cumulative impacts from other major projects; and
the effectiveness and enforceability of proposed mitigation measures.
Where supplementary information materially changes the environmental assessment or reveals impacts

FIRST IVE HEARD OF THIS PROJECT IS TODAY??? WHY???
FORMAL OBJECTION – UPPER HUNTER BATTERY ENERGY STORAGE SYSTEM
To: NSW Department of Planning, Housing and Infrastructure
Re: Upper Hunter Battery Energy Storage System – Environmental Impact Statement
Submission: OBJECTION
I formally object to the proposed Upper Hunter Battery Energy Storage System (BESS).
My objection is based on concerns regarding the adequacy of the Environmental Impact Statement (EIS), particularly the assessment of impacts on neighbouring properties, bushfire and battery fire risk, visual amenity, noise, water quality, biodiversity, emergency management and cumulative impacts.
1. Battery Fire and Emergency Risk
A large-scale lithium-ion battery facility introduces a fundamentally different fire and emergency risk into a rural environment.
Battery fires can involve thermal runaway, prolonged fire events, toxic smoke and contaminated firefighting water. The EIS must demonstrate that credible worst-case incidents have been adequately assessed, including fire propagation between battery units and the consequences of an incident occurring during extreme fire-weather conditions.
The Department should require clear evidence that emergency services can safely access, contain and manage a major incident without creating unacceptable risks to neighbouring residents, livestock, property or the surrounding environment.
2. Water Contamination and Firewater
I am particularly concerned about contaminated water leaving the development site.
The assessment should demonstrate how stormwater, firefighting water and potentially contaminated runoff will be contained during a significant battery incident.
There should be no reliance on assumptions that contamination will remain within the development footprint. The consequences of contaminated water entering drainage lines, creeks, groundwater or neighbouring properties require proper assessment.
The project should not be approved unless the Department is satisfied that adequate containment capacity and emergency procedures are in place for credible worst-case events.
3. Visual Impact and Rural Character
A utility-scale BESS is an industrial development containing battery enclosures, electrical infrastructure, substations, security fencing, lighting and associated equipment.
These structures can significantly alter the visual character of a rural landscape.
The Department should carefully consider views from surrounding residences, roads and properties rather than relying principally on landscaping or screening assumptions.
Vegetation screening takes years to establish, can fail during drought and may itself be affected by bushfire management requirements.
Existing residents should not be expected to bear substantial loss of rural amenity because an industrial-scale development has been introduced into their landscape.
4. Noise
The project has the potential to generate continuous and intermittent noise from inverters, transformers, cooling systems and other electrical infrastructure.
Particular attention should be given to night-time noise, low background noise levels typical of rural areas and cumulative noise from all project components.
Compliance modelling should not replace consideration of the actual experience of nearby residents.
Independent post-construction noise monitoring and enforceable operating limits should be required if the project is approved.
5. Biodiversity and Environmental Impacts
Construction and operation may affect vegetation, wildlife habitat, waterways and ecological connectivity.
The Department should be satisfied that the EIS has properly identified direct and indirect impacts rather than relying excessively on mitigation measures proposed after impacts have occurred.
Potential impacts from fire, contaminated runoff, vegetation clearing, fencing, lighting and ongoing maintenance should also be considered.
6. Cumulative Development
This project should not be assessed as though it exists in isolation.
The Upper Hunter is experiencing substantial development associated with renewable energy, transmission infrastructure, battery storage and other industrial projects.
The cumulative consequences for rural residents, landscape character, roads, emergency services, biodiversity and agricultural land need meaningful assessment.
Individually acceptable impacts can become unacceptable when multiple developments are concentrated within the same district.
7. Protection of Surrounding Residents
The interests of people living around the proposed development must receive substantial weight.
The assessment should properly identify residences and other sensitive receivers potentially affected by noise, visual impacts, lighting, traffic, fire risk and environmental impacts.
Where uncertainty exists, the precautionary approach should favour additional assessment rather than assuming an impact will be insignificant.
Conclusion
For the reasons outlined above, I object to the Upper Hunter Battery Energy Storage System in its presently proposed form.
I request that the Department carefully scrutinise the EIS and require the proponent to adequately address outstanding issues concerning:
battery fire and emergency response;
contaminated firewater and stormwater;
impacts on waterways and biodiversity;
noise and night-time disturbance;
visual impacts and rural landscape character;
impacts on neighbouring residents and properties; and
cumulative impacts of major energy and infrastructure development across the Upper Hunter.
Where the available information does not demonstrate that these impacts can be appropriately avoided, mitigated and managed, the Department should require further assessment and project modifications before determining the application.
I request that this submission be formally recorded as an OBJECTION to the project.

SWITCHING STATION SITE SELECTION, RELOCATION AND STRATEGIC SUITABILITY
This submission relates specifically to the proposed Wells Gully Switching Station forming part of SSD 61707209. The issue is whether the permanent Switching Station proposed on Lot 27 DP752485 at Wells Gully has been demonstrated to be an appropriate site after its own impacts are considered. Campbell Street is relevant here only because the 2023 Scoping Report showed the substation or switching station function within the original Campbell Street project area, while the exhibited EIS places the permanent Switching Station approximately 3 km away on Lot 27 beside Wells Gully Road. That change is evidence about the history of the Switching Station itself and requires the final Wells Gully location to be assessed on its own residential, road, catchment, visual, agricultural, biodiversity, bushfire and emergency access conditions.
The location history should therefore be explained directly. The Department should be able to identify when the Wells Gully location became the preferred Switching Station site, why it was selected, what alternatives were considered, and how the impacts introduced by that location were weighed.
Lot 27 and the Wells Gully Switching Station are on RU1 Primary Production land under Muswellbrook LEP 2009. The RU1 objectives include maintaining rural landscape character, protecting agricultural potential and minimising land use conflict. Those provisions do not automatically prevent the infrastructure, but they make the reasoning for selecting this particular rural site a material assessment issue.
The Hunter Regional Plan 2041 supports renewable energy and infrastructure development while also recognising rural landscapes, biodiversity, agriculture and community amenity. A grid connection advantage or commercially available parcel may be relevant, but commercial feasibility is not the same question as environmental or planning superiority.
The Department should therefore require a chronological alternatives record that answers these matters:
1. What location and function for the Switching Station was shown in the 2023 Scoping Report?
2. When and why did Lot 27 at Wells Gully become the preferred permanent Switching Station site?
3. What alternative Switching Station locations were considered?
4. What technical, grid, tenure, commercial, environmental and planning reasons were used to reject or prefer each alternative?
5. How were proximity to 322 and 376 Wells Gully Road, RU1 zoning, visual impact, noise, road constraints, bushfire, drainage, agriculture and biodiversity weighed?
6. What evidence records that comparison?
These questions require direct answers. It would not be sufficient to respond that the site was selected because it is near existing transmission infrastructure or is technically feasible. The assessment should show why Wells Gully was selected over the actual alternatives and what weight was given to the new impacts created by relocating the permanent station.
REQUIRED DETERMINATION RESPONSE
The site suitability assessment should also address the broader cadastral context surrounding the Wells Gully Switching Station. The project material identifies Lots 130, 75 and 27 DP752485 among the transmission and switching parcels, with the selected Switching Station located on Lot 27 DP752485. The nearby residence at 322 Wells Gully Road is on Lot 76 DP752485 and is not identified as a project parcel. The assessment should therefore clearly explain the proposed function of Lots 75 and 130 within the final project, the infrastructure or disturbance proposed on those parcels, and their relationship to the Switching Station on Lot 27 and nearby residential land.
Before determination, DPHI should publish or require a station specific alternatives and site selection assessment that answers the six matters above and identifies the evidence relied upon. If no documented comparative assessment was undertaken, that should be stated expressly rather than reconstructed after exhibition.
Identify the present and proposed project function of Lots 75 and 130 DP752485, including any transmission infrastructure, access, easements, disturbance areas or other project infrastructure proposed on those parcels, and show their relationship to the final Switching Station footprint on Lot 27 DP752485 and the adjoining residential context.
If the final station location or footprint changes materially as a result of that work, the revised proposal should be assessed against the same environmental disciplines and affected residents should have an appropriate opportunity to comment.

REFERENCES
SSD 61707209 Scoping Report (2023), original Campbell Street substation/switching station concept
Main EIS Rev 2, 6 August 2026
Appendix H, land use/planning assessment
Muswellbrook Local Environmental Plan 2009, RU1 Primary Production objectives and LEP aims
Hunter Regional Plan 2041
Planning Secretary’s Environmental Assessment Requirements (SEARs), issued 16 July 2025
• EPBC 2025/10353 referral material, project cadastral set identifying transmission and switching parcels including Lots 130, 75 and 27 DP752485.
NSW State Significant Development EIS Guidelines (March 2026)

SWITCHING STATION APPROVAL ENVELOPE, DOCUMENT CONSISTENCY, VISUAL IMPACT AND LIGHTING
Information concerning the detailed design of the Wells Gully Switching Station has been the subject of separate confidential discussions. This submission does not rely upon or disclose any information subject to those confidentiality arrangements. The issue raised here is based solely upon the publicly exhibited assessment material.
The public assessment record must itself establish the development for which approval is sought and the maximum physical and operational envelope against which its environmental impacts have been assessed. Where the publicly exhibited material leaves elements of the Switching Station subject to detailed design, the Department should require those elements to be defined or capped before determination.
The Department should therefore require the applicant to identify on the public assessment record the maximum Switching Station footprint and disturbance area, including the relationship of the approved infrastructure and corridor envelope to Lots 75 and 130 DP752485, platform dimensions and levels, maximum equipment and structure heights, transformer and switchgear envelope, lighting, access, drainage infrastructure and any other parameter capable of materially affecting the environmental assessment or neighbouring residences.
The adequacy of the public EIS should stand on the public assessment material. Information provided privately to individual affected landholders should not be necessary to determine what development SSD 61707209 would actually authorise.
The existing review identified that the final station footprint, platform, equipment, heights, lighting, drainage, noise source inventory and capacity/expansion parameters are not fixed consistently across the EIS and specialist appendices. Several specialist reports also pre date later civil/access drawing revisions. This creates a straightforward assessment question: what exact maximum Switching Station is the Department being asked to approve?
The answer should be consolidated in one controlling schedule. At minimum it should state the maximum station footprint and disturbed area; platform level and dimensions; gantry, pole/mast, buswork and equipment heights; control building dimensions; transformer/switchgear equipment and oil inventory; lighting type, height, location and operating regime; drainage/containment works; operational noise source inventory; access/parking areas; transmission/cable interfaces; and any physical/electrical allowance for future expansion.
VISUAL IMPACT
The Wells Gully Switching Station is a permanent high voltage facility on rural land beside existing homes. Its visual impact must therefore be assessed and controlled by the dimensions, equipment, lighting and mitigation actually approved at Wells Gully.
Those modelled dimensions and mitigation assumptions must therefore be approval limits if they are relied upon to support the visual conclusion. If the final gantries, poles, equipment, platform or lighting can be higher, larger or differently positioned, the visual assessment must be rerun before that change is accepted.
Night lighting also requires a defined envelope. The Department should require maximum pole/light heights, luminaire type/direction, hours and circumstances of operation, spill controls and the emergency/security lighting case assessed at the nearest residences.
DOCUMENT LINEAGE
The Department should require a design lineage matrix listing each final controlling Switching Station drawing and revision and identifying which version was used by the visual, noise, traffic, biodiversity, water, bushfire, hazard and social impact assessments. For every later design revision, the applicant should state whether the change remains within the specialist assessment envelope and provide the basis for that conclusion.
REQUIRED DETERMINATION RESPONSE
1. One maximum Switching Station development schedule.
2. One set of controlling final or maximum drawings.
3. A cross discipline design lineage matrix.
4. Receptor specific confirmation that 322 and 376 Wells Gully Road were assessed using those same maximum parameters.
5. Binding maximum height, footprint and lighting limits.
6. An objective change control trigger requiring reassessment where detailed design exceeds any assessed parameter.
A response that these matters will be resolved at detailed design would not answer the issue. Detailed design may refine how an approved station is built; it should not establish the environmental envelope after consent.

POLICY / REFERENCES SSD 61707209 SEARs, issued 16 July 2025, project description, impacts, mitigation and consistency requirements. Main EIS Rev 2, 6 August 2026. Appendix B, project/civil design drawings, including later revisions such as PB 0003/PB 0004 where applicable. Visual Impact Assessment and Landscape Plan. NSW State Significant Development EIS Guidelines (March 2026). DPHI Guideline for drafting conditions for State significant projects, conditions should be certain, final, clear and measurable. Muswellbrook LEP 2009 and Hunter Regional Plan 2041.

SWITCHING STATION NOISE, DUST, ROAD NOISE AND CUMULATIVE RESIDENTIAL IMPACT
This submission concerns the actual construction and operational impacts of the Wells Gully Switching Station at the nearest residences, particularly 322 and 376 Wells Gully Road.
The exhibited material assesses construction noise in the Wells Gully area, but the adequacy review has not located a clear final equipment operational Switching Station prediction for 322 and 376 using a complete worst case station source inventory. That distinction matters. Construction noise and operational transformer/switchgear noise are different assessment questions.
Before determination, the applicant should identify every material operational Switching Station source: power transformers and cooling fans/pumps, auxiliary transformers, switchgear where acoustically relevant, control building HVAC, emergency/backup plant and other fixed mechanical/electrical sources. It should provide source sound power/spectral data, operating duty and a receptor specific prediction at 322 and 376 Wells Gully Road under the applicable NSW EPA meteorological and modifying factor assumptions.
If the final transformer make/model and sound power data are not yet known, the consent should set a maximum source envelope that the final equipment must meet. The applicant should not be able to select louder equipment after consent merely because the EIS used a representative source.
ROAD NOISE CONSISTENCY
A separate inconsistency requires a direct response. Appendix J describes substantial Switching Station construction/heavy vehicle movements on Wells Gully Road, while the adequacy review identified that Appendix I's Wells Gully road noise worst case hour uses zero project heavy vehicles and relies on a Graeme Street surrogate baseline.
The Department should require the applicant to answer:
1. What is the maximum hourly and daily Switching Station traffic schedule on Wells Gully Road?
2. How many of those movements are heavy vehicles?
3. Why does the Wells Gully road noise worst case hour use zero project heavy vehicles?
4. Why was Graeme Street used as the surrogate baseline, and is it acoustically representative of Wells Gully Road?
5. What is the resulting road noise prediction when the actual maximum Switching Station fleet is modelled?
DUST AND COMBINED RESIDENTIAL EFFECTS
The Switching Station cannot be assessed only as separate technical silos. During construction, nearby residents may experience road/trenching works, traffic control, heavy vehicles, dust, noise, worker activity, lighting and access restrictions at the same time. Appendix O recognises way of life, accessibility, surroundings and cumulative social effects.
The Department should therefore require a receptor based schedule for 322 and 376 showing the predicted construction noise, operational station noise, road traffic, dust controls, lighting, duration and overlapping work periods.
POLICY / REQUIRED RESPONSE
The NSW EPA Noise Policy for Industry 2017 is the relevant framework for operational industrial noise. Construction noise should be addressed under the applicable NSW construction noise guidance and the project SEARs. The SSD EIS Guidelines and Cumulative Impact Assessment Guidelines require impacts and cumulative effects to be transparently assessed.
Before determination, DPHI should require the operational station noise model and the corrected Wells Gully road noise assessment described above. Any consent should then bind the final station to the assessed acoustic source envelope and require commissioning verification and corrective action if limits are not achieved.
REFERENCES
Appendix I, Noise and Vibration Impact Assessment
Appendix J, Traffic Impact Assessment
Appendix O, Social Impact Assessment
SSD 61707209 SEARs, issued 16 July 2025
NSW EPA Noise Policy for Industry 2017
NSW State Significant Development EIS Guidelines and Cumulative Impact Assessment Guidelines (March 2026)

WELLS GULLY ROAD, CABLE/TRENCHING WORKS, CONSTRUCTION TRAFFIC AND RESIDENT ACCESS
This submission concerns Wells Gully Road as the access and construction interface for the proposed Switching Station under SSD 61707209.
The issue is not simply the number of project vehicles. Wells Gully Road is a constrained rural road used by existing residents. The project adds Switching Station construction traffic, workforce movements, underground cable/trenching works and potentially large/heavy deliveries while residents must continue to use the same road for ordinary access and emergency egress.
Appendix J identifies High traffic risks requiring controls. The exhibited material should therefore state the actual road conditions and the final construction method rather than leave the practical consequences to a future Traffic Management Plan.
The Department should require a field verified road schedule showing carriageway width, usable shoulder/edge, blind corners/crests, grades, drainage/culverts, pavement condition, passing opportunities, property accesses and the locations where two project/resident vehicles or a fire appliance can safely pass.
UNDERGROUND CABLE / TRENCHING
Where cable or other project works occur within or beside Wells Gully Road, the applicant should identify the exact work length, trench/boring method, work zone width, lane restrictions, duration, temporary surfacing, traffic control arrangements and how each residence retains access.
A general commitment to traffic management does not answer whether a resident can physically leave or return home while the road is trenched, occupied by plant or controlled for heavy movements.
HEAVY / OSOM MOVEMENTS
Appendix K assesses heavy/OSOM transport for the project, but the Switching Station should have its own final delivery schedule. If future detailed design introduces an OSOM or transformer movement on Wells Gully Road not assessed in the exhibited route case, the Department should require route and road impact reassessment before that movement is authorised.
The applicant should state unequivocally whether any transformer, reactor, switchgear or other Switching Station component is expected to require OSOM access via Wells Gully Road. If the answer is no, that should be recorded as an approval assumption. If yes or potentially yes, the maximum vehicle/load envelope and required road works should be assessed now.
ROADS ACT / AUTHORITY
The SSD application identifies a Roads Act section 138 consent requirement. The applicant should identify the road authority for each Wells Gully access/road work and specify exactly which works require section 138 consent. This should not be left as an undefined future approval interface.
REQUIRED DETERMINATION RESPONSE
Before determination, DPHI should require direct answers to:
1. What is the maximum Switching Station construction and heavy vehicle schedule?
2. What is the final cable or trenching work zone and resident access method?
3. What are the field verified passing and fire appliance constraints?
4. Is any Switching Station OSOM movement proposed or permitted?
5. What physical road or access upgrades are required?
6. Which road authority is responsible for each section 138 approval and what is the exact scope?
7. What enforceable method will maintain resident and emergency access throughout construction?
If road widening, culverts, passing bays or other works extend beyond the environmentally assessed footprint, the biodiversity, drainage, heritage, noise and visual effects of those works should be assessed before construction.
REFERENCES
Appendix J, Traffic Impact Assessment
Appendix K, Heavy/OSOM transport assessment
Appendix I, Noise and Vibration Impact Assessment
Main EIS and SSD application, Roads Act s138 approval interface
SSD 61707209 SEARs, issued 16 July 2025
Final Switching Station civil/access drawings

SWITCHING STATION EMERGENCY ACCESS, BUSHFIRE, FIREFIGHTING WATER, FLOODING AND DRAINAGE
This submission concerns emergency performance of the Wells Gully Switching Station itself. The answer must be station specific. Fire, access, water, flooding and evacuation arrangements described for other parts of SSD 61707209 do not by themselves establish that the Wells Gully Switching Station has an adequate emergency response.
Appendix M identifies project firefighting water arrangements at the BESS, but the review has not identified an equivalent dedicated firefighting water supply for the separate Wells Gully Switching Station. That comparison is relevant only because it exposes a station specific question that must be answered for Wells Gully.
Those differences require a station specific answer.
Wells Gully Road is also the only practical access for the closest residence at 322 Wells Gully Road. The southern route/causeway cannot simply be described as an alternative emergency route unless its availability during the relevant flood, storm and bushfire conditions is demonstrated.
The Department should require the applicant to answer:
1. What maximum BAL or radiant heat outcome is the final Switching Station designed to achieve?
2. What defendable space width is required and how will it be maintained?
3. What dedicated firefighting water source is available at the Switching Station, with what capacity, location and maintenance responsibility?
4. What fire appliance width, load, turning and passing requirements apply to the station access?
5. Can a fully loaded fire appliance reach, turn and leave the station while construction or cable works are occurring?
6. How can residents at 322 Wells Gully Road evacuate if project works, an accident, bushfire or flood obstructs Wells Gully Road?
7. What is the demonstrated flood immunity of the southern route or causeway, and for how long can it be unavailable?
8. What priority arrangements ensure resident egress and emergency service access during a concurrent project incident?
DRAINAGE AND WELL GULLY
Appendix L models Wells Gully in the pre development condition but the review identified no equivalent station specific post development model using the final platform, access and drainage layout. The 2025 SEARs require pre and post development flood modelling and assessment of changes to overland flows.
Appendix G also identifies moderate to high dispersion risk in disturbed sodic soils and states that earthworks for the BESS and Switching Station are very likely to increase dispersive behaviour when soils are remoulded, compacted or pulverised.
The final station design should therefore show post development flows, culverts, outlets, cross drainage, erosion protection, dispersive soil treatment and the pathway to Well Gully.
The drainage system must also be capable of isolation during a transformer oil spill or transformer fire so oil or contaminated firefighting water cannot simply follow the stormwater pathway off site.
REQUIRED DETERMINATION RESPONSE
These matters should be answered in a station specific emergency/civil schedule before determination. A future Emergency Plan or CEMP should implement the solution, not be the first document to identify what the solution is.
REFERENCES
Appendix M, Bushfire Assessment, including pp.17 to 25 and Figure 3c
Appendix L, hydrology/water assessment, including pp.21 to 25, 37 to 41 and 51 to 55
Appendix G, Preliminary Site Investigation/LUCRA, including dispersive soil findings
Appendix J, Traffic Impact Assessment
SSD 61707209 SEARs, issued 16 July 2025, including flood/water requirements
Final Switching Station civil/access drawings including PB 0004 where applicable
NSW RFS Planning for Bush Fire Protection and relevant emergency access requirements

SWITCHING STATION HAZARDS: TRANSFORMERS, OIL/PCBs, LIGHTNING, EARTHING, BIODIVERSITY AND CHANGE CONTROL
This submission concerns hazards originating at the Wells Gully Switching Station itself. The project wide Preliminary Hazard Analysis should not be treated as proof that those station originating hazards have been assessed merely because the Switching Station is part of SSD 61707209.
Appendix N states that its scope includes project infrastructure but has a primary focus on the BESS. It then treats the Switching Station as an off site receptor approximately 3,125 m from the nearest battery unit. The detailed transformer fire work concerns BESS side transformers. On the material reviewed, Appendix N does not provide an equivalent station specific consequence assessment for transformer/switchgear/oil fire/electrical/lightning hazards originating at Wells Gully toward the nearby residences.
That is a definable gap and requires a station specific PHA addendum.
TRANSFORMER OIL AND PCBs
Appendix N confirms transformer oil is used and records that the make/model of the substation transformer and quantity of transformer oil were unavailable when the PHA was prepared. The final Wells Gully design should therefore state the type and total volume of insulating oil in every transformer and other material oil filled item.
Appendix G already identifies PCBs as contaminants of potential concern and identifies soil, surface water and groundwater as potentially affected media, with transport pathways including groundwater, overland flow and sediment discharge. The Main EIS also defines PCB as polychlorinated biphenyl.
New equipment should not be treated as sufficient proof of PCB status. Before energisation, manufacturer certification and supply chain documentation should confirm the PCB status of insulating oils and oil filled equipment. If adequate certification is unavailable, representative laboratory testing should be required. The same requirement should apply to replacement oil, replacement transformers and reused/refurbished oil filled plant.
The final design should demonstrate bunding, spill containment, drainage isolation and containment/management of oil contaminated firefighting water for credible leak, rupture and fire scenarios.
LIGHTNING / ELECTRICAL HAZARDS
The station is a 330 kV installation. The final station specific hazard assessment should state the lightning design basis and demonstrate surge protection, insulation coordination and earthing performance, including step and touch potential. It should identify the standards/design criteria used and confirm that the final layout/equipment remain within those assumptions.
A generic statement that the station will comply with applicable standards is not a substitute for identifying the design basis relied upon to conclude that off site consequences are acceptable.
BIODIVERSITY / EPBC FOOTPRINT
The Commonwealth decision for EPBC 2025/10353 made the project a controlled action under listed threatened species and communities provisions (ss18 and 18A). The final Switching Station, access tracks, transmission alignment and ancillary disturbance must therefore remain within the action/impact envelope assessed by the BDAR and Commonwealth material.
The final July 2026 layout and late access/civil changes should be reconciled with the Hunter Valley Delma survey basis and other MNES assessment. If final station works extend beyond the assessed disturbance footprint or relevant survey/impact assumptions, the biodiversity/EPBC assessment and credits must be updated before determination or before the change is accepted.
REQUIRED DETERMINATION RESPONSE
DPHI should require, before determination:
1. A Wells Gully Switching Station PHA addendum.
2. Final or maximum transformer and oil inventories.
3. Station originating transformer fire, oil release and relevant electrical consequence assessment toward 322 and 376 Wells Gully Road.
4. PCB certification and testing requirements.
5. Oil and contaminated firefighting water bunding and drainage isolation performance.
6. Lightning, surge, insulation coordination and earthing design criteria.
7. Confirmation that every final station, access and transmission disturbance is within the BDAR and EPBC assessed envelope.
8. An objective consent trigger requiring reassessment for any material station expansion, equipment or inventory increase, or footprint change.
These are specific questions. They should be answered by evidence against the Wells Gully Switching Station, not by a general statement that project wide management plans will be prepared later.
REFERENCES
Appendix N, Preliminary Hazard Analysis, particularly scope, transformer oil and consequence sections
Appendix G, Preliminary Site Investigation/LUCRA, PCB media/pathway and soil findings
Appendix L, water/drainage assessment
Appendix D, Biodiversity Development Assessment Report
Commonwealth DCCEEW decision EPBC 2025/10353, 8 December 2025, controlled action, ss18 and 18A
Supplementary SEARs and Appendix A
Australian Government DCCEEW, Polychlorinated Biphenyls (PCBs), updated 3 June 2026
NSW EPA, Polychlorinated Biphenyl Chemical Control Order 1997
Comparative high voltage design references identified in the project review: Ausgrid NS264 and Transgrid major substation lightning protection guidance
SSD 61707209 | Wells Gully Switching Station

SSD 61707209 - CAMPBELL STREET BESS
FINAL DESIGN, OPERATING ENVELOPE AND CONSENT CERTAINTY
This submission concerns the Campbell Street BESS only and is separate from concerns regarding the Wells Gully Switching Station.
The issue is whether the publicly exhibited EIS defines the maximum development and operating envelope that would actually be authorised. Where environmental conclusions depend on equipment configuration, layout, operating assumptions or mitigation, those matters should be fixed by consent or subject to measurable maximum limits and objective reassessment triggers.
Under sections 4.15 and 4.40 of the Environmental Planning and Assessment Act 1979, the consent authority must consider relevant planning controls, likely environmental impacts, site suitability, submissions and the public interest. The project SEARs and NSW SSD/EIS assessment framework provide the project assessment requirements. The questions below go directly to whether the development and its impacts have been adequately defined before determination.
1. Maximum BESS configuration
State the maximum number of battery enclosures, PCS/inverters, transformers and other principal plant authorised by the proposed consent. Reconcile any different equipment figures in the EIS and identify the maximum assessed configuration. If numbers can change during detailed design, state the maximum number, dimensions, capacity and disturbance envelope permitted without further assessment.
2. Maximum operating envelope
State the maximum electrical capacity, energy storage capacity, charging and discharging rates and operating/cycling regime. Identify any technical assessment relying on particular loading, charging, discharging or simultaneous operation assumptions and explain how operation will be kept within those assessed limits.
3. Operational noise
Identify the equipment schedule and sound power data used in the final noise model and confirm it represents the maximum permitted configuration, including cooling equipment and transformers. If OEM equipment is not final, specify maximum permissible sound power and spectral characteristics and require compliance to be demonstrated before installation. Relevant framework: EP&A Act s4.15, project SEARs and NSW Noise Policy for Industry.
4. Acoustic barriers and heat
Demonstrate that the proposed acoustic barriers will not impede ventilation, recirculate heated discharge air or increase equipment inlet temperatures under the worst assessed operating and ambient temperature condition. State the ambient temperature, heat rejection and operating duty assessed. If final equipment remains unresolved, specify enforceable thermal performance criteria.
5. Fire design
Identify the battery technology, enclosure arrangement, separation distances, fire access, firefighting water, isolation strategy and emergency assumptions forming the assessed design. Distinguish fixed measures from matters deferred to detailed design. Explain how a later equipment change with materially different fire behaviour would trigger reassessment. Relevant framework: project SEARs and FRNSW Large scale external LiBESS Technical Information Sheet, Version 03, 3 July 2026.
6. Transformers and insulating oil
Identify the maximum number of oil filled transformers and maximum insulating oil inventory authorised. State the corresponding bunding, spill containment, drainage isolation and contaminated firewater containment capacity. If transformer make, model or oil quantity is unresolved, identify the maximum inventory actually assessed.
7. Biodiversity and final footprint
Confirm that the BDAR and Commonwealth assessment cover the complete disturbance envelope capable of approval, including BESS, access, transmission infrastructure, fire access and defendable space, drainage and construction areas. Provide one reconciliation drawing or schedule showing every approvable disturbance area is within the biodiversity and EPBC assessment footprints. EPBC 2025/10353 was determined a controlled action under EPBC Act s75, with ss18 and 18A controlling provisions.
8. Detailed design change control
Identify every parameter that is fixed and every parameter capable of changing after determination. Consent limits should cover equipment numbers, footprint, dimensions and heights, capacity, noise, thermal performance, fire separation, oil inventory, vegetation disturbance and associated infrastructure. State the objective threshold requiring further assessment if detailed design exceeds an assessed maximum or produces a materially different impact. Detailed design should refine the approved development, not determine retrospectively what was assessed.
REQUESTED OUTCOME
Before determination, require a Campbell Street BESS Design and Environmental Assessment Reconciliation Schedule identifying: (1) the final or maximum approved configuration; (2) every parameter subject to detailed design; (3) the maximum assessed limit for each variable; (4) the technical assessment relying on it; (5) the corresponding consent control; and (6) the objective trigger for further assessment.
REFERENCES
Environmental Planning and Assessment Act 1979 (NSW), ss 4.15 and 4.40.
SSD 61707209 Secretary's Environmental Assessment Requirements.
NSW State Significant Development Guidelines / EIS guidance.
FRNSW Large scale external LiBESS Technical Information Sheet, Version 03, 3 July 2026.
EPBC Act 1999 (Cth), ss 18, 18A and 75; EPBC 2025/10353 controlled action decision.
NSW EPA Noise Policy for Industry.

I am writing this submission to voice my concerns over the construction of the proposed Upper Hunter Battery Energy Storage System located at the bottom of Campbell Street in Aberdeen NSW.

I live approximately 100 meters from the proposed construction site and as such believe I will be significantly subjected to a number of concerning impacts to my wellbeing and safety.

1. Noise pollution from the cooling fans, HVAC units, inverters and transformers that run 24/7. I acknowledge that the noise levels will increase significantly during the summer months as temperatures can reach upwards of 40 degrees from early January through to March and the fans must increase in their velocity to try and keep the systems cool.

2. I am a shift worker and need to be able to sleep through out the night and more importantly through the day. the noise levels from these fans will not only deprive me of sleep, they will affect my ability to perform work safely and effectively.

3. The visual outlook will be destroyed by the large number of batteries being placed in the area and will significantly impact the wellbeing of the local kangaroo population, and also other bird and wildlife that live in the foothills behind Perth Street.

4. I am concerned about the safety and emergency risks that will impact myself and my neighbours, should a lithium battery overheat and combust. The thermal and fire runaway could put my home and my person at risk should a fire break out as there is no way Fire and Emergency Services can put these fires out.

5. The added risks of toxic smoke and gasses that are be released into the atmosphere can impede residents trying to get to safety and as my partner is an asthmatic her life could be seriously in danger from the fumes.

6. Research shows that there have been a number of explosions from similar battery energy systems globally, including one in Germany this years that took over 250 fire fighters to monitor and keep the outlying areas safe.

7. The devaluation of my property which will significantly impact my financial situation and reduce my retirement opportunities in the future because of lower selling rates due to noise pollution, environmental hazards and safety risks caused by lithium batteries, which the full extent of their impact is not evident from a historical data base. This and the lower house prices will affect my retirement ability.

In summary, I believe the location chosen is far too close to residential properties and researching similar projects, note that Balranald, Temora, East Maitland and Dubbo have all been built away from populated areas and often next to solar farms.

The decision by the developer to choose a built up area close to homes is baffling to say the least and should a catastrophic incident occur, will the government stand up to scrutiny of how this plan was accepted and the welfare of residents put to the bottom of the risk ratings register.

Thank you for taking the time to read my objections to this project. I trust that someone will see the importance of human life and wellbeing and make the judgement call, to move the site to an area away from homes and children.

I object to the Upper Hunter Battery Energy Storage System, SSD-61707209, in its current form.

I own 560 Sandy Creek Road, McCullys Gap. My property immediately adjoins the separately proposed McCullys Gap BESS. I am concerned about the cumulative effect of multiple large battery and energy projects on local roads, emergency services, housing, rural amenity, biodiversity and the wider Upper Hunter region.

My attached submission identifies a number of deficiencies in the EIS, including incomplete biodiversity surveys, impacts on threatened ecological communities, inadequate consideration of alternative sites, unresolved Aboriginal cultural heritage impacts, flooding and emergency access concerns, and reliance on hazard, fire, noise and equipment details that will not be finalised until after approval.

I am particularly concerned about the proposed switching station on Wells Gully Road. The visual assessment provides photographs of the existing road views but no public road-level photomontage showing the switching station, access road, earthworks, fencing, lighting and transmission infrastructure. I also disagree with the low scenic-quality rating applied to the northwest-facing view. Despite the existing transmission lines, Wells Gully Road retains an attractive rural outlook. The road is also known locally to flood, but the EIS does not demonstrate that the full access route would remain safely passable during flood and emergency events.

I ask the Department not to determine the project until the deficiencies identified in my attached submission have been properly addressed. Any material new surveys, revised designs or technical assessments should be publicly exhibited before a decision is made.
Whilst I am not opposed to renewable energy projectes in general I feel they should be situated much further away from residential and rural residential areas due to issues regarding safety along with visual and noise concerns. Locations such as the old Liddell power station area or the land associated with the BHP mine once it closes would be much more suitable alternatives. these location would have little to no impact on local residents in regards to noise, visual and saftey. Impacts on local housing and accomodation would still require an appropriate plan however. As would traffic etc, but such locations would completely avoid impacting the local residential and shopping areas.

Please treat this submission and its attachment as a formal objection.

Upper Hunter BESS Submission SummaryState Significant Development SSD-61707209We object to the Upper Hunter BESS, SSD-61707209, in its current form. Our principal concern is the proposed permanent 330 kV Switching Station beside Wells Gully Road and existing rural residences, including our home at 322 Wells Gully Road.
We are not opposed to battery storage or renewable energy generally. Our concern is the stark difference between the detailed assessment of the BESS facility at Aberdeen and the limited, inconsistent and open-ended information provided for the separate Wells Gully Switching Station.
This is a State Significant Development with an estimated development cost of approximately $329.3 million, including about $290.2 million in construction costs. For a project of this scale and permanence, it is deeply concerning that the final Switching Station equipment, layout, maximum structure heights, operational noise, lighting, drainage, bushfire performance, hazards, road access and impacts on the closest residences have not been clearly established and assessed before approval is sought.
The Switching Station is not a minor ancillary structure. It is an essential part of the project’s connection to the electricity grid. Without an approved and constructible Switching Station, the BESS cannot import and export electricity as proposed. Deficiencies in the assessment of the Switching Station therefore affect the Department’s ability to properly assess the project as a whole.
The exhibited material also raises substantial questions under the issued SEARs, the NSW State Significant Development EIS Guidelines, the Hunter Regional Plan 2041 and the Muswellbrook Local Environmental Plan 2009. Muswellbrook Shire Council’s Local Transport Forum minutes independently record existing concerns about the bends, narrow sections and safety of Wells Gully Road and confirm that traffic monitoring was commissioned before this EIS was exhibited.
We recognise that public exhibition forms part of DPHI’s assessment process and does not indicate that the Department has accepted the conclusions of the EIS or determined that the project should be approved. We appreciate the opportunity to identify these issues and respectfully ask DPHI to use the assessment process to require the applicant to provide a consolidated and sufficiently detailed assessment of the Switching Station before the application is determined.
We are also concerned that any Commonwealth or NSW Government financial support, revenue underwriting, concessional finance or other public funding associated with the project should be transparently disclosed. If the project is receiving, seeking or expects to rely on mechanisms such as the Capacity Investment Scheme, a Long-Term Energy Service Agreement, ARENA or CEFC support, that involvement must not reduce the rigor of the environmental assessment or allow unresolved impacts to be deferred. Government policy or financial support should not diminish the need for an independent and rigorous assessment of the Wells Gully Switching Station and its impacts on nearby residents.
If the additional information results in a material change to the location, design or assessed impacts of the Switching Station, affected residents should be given a further opportunity to review and comment on the amended proposal.Our detailed attached submission identifies the relevant EIS documents, NSW Government requirements, Council records and property-specific impacts. We ask that the Wells Gully Switching Station not be approved on an open-ended detailed-design basis and that the project not be determined until this essential component has been properly defined and assessed.

This submission relates specifically to the Battery Energy Storage System component of SSD-61707209. A separate submission has been made regarding the proposed Wells Gully Switching Station.

We are not opposed to battery energy storage or renewable energy infrastructure in principle. Our concern is whether the exhibited Environmental Impact Statement provides a sufficiently complete and reliable basis for determining the environmental and safety impacts of the particular BESS proposed at Aberdeen.

The central issue is that several important conclusions in the EIS rely on a concept design rather than a fully defined project. The final battery manufacturer and model have not been selected, large scale fire testing remains incomplete, some fire and explosion assumptions are based on expected product performance, noise compliance depends on concept equipment and major acoustic barriers yet to be finalised, and important emergency access, firefighting water, firewater containment and detailed design matters remain unresolved.

These are not minor design details. They directly affect the hazard, noise, fire, emergency response and pollution outcomes relied upon in concluding that the project is acceptable.

We recognise that Fire Safety Studies, Emergency Plans, commissioning verification and some detailed engineering appropriately occur after development consent. However, detailed design should refine and verify an environmental envelope that has already been assessed. It should not become the process by which material aspects of fire behaviour, explosion risk, acoustic performance, emergency access, firefighting water demand or pollution containment are first established.

The Preliminary Hazard Assessment is expressly based on a concept battery product because the final OEM has not been selected. It also records that unit level UL9540A testing was unavailable and that large scale fire testing was still in progress. The assessment therefore relies in part on assumed safety performance, including assumptions regarding propagation, debris, gas release and external flaming. The PHA also identifies flammable gas explosion as a credible scenario but does not separately model that consequence in the same way as other hazards. Before installation or energisation, the final battery product should be identified and supported by completed product specific fire and explosion evidence, with the PHA updated where necessary.

Noise is another major concern. The acoustic assessment models a specific combination of Fluence batteries, Power Electronics inverters, transformers, attenuation kits and substantial noise walls. Final equipment remains subject to change. Predicted night noise at the most affected receiver is only marginally below the applicable criterion, and the model assumes particular fan duty and temperature conditions. Final equipment should therefore be required to meet defined sound power and spectral limits, with verification under realistic worst case summer cooling conditions and relevant stable night conditions. If operational testing identifies exceedances or unacceptable tonal, low frequency, intermittent or sleep disturbance characteristics, source and transmission mitigation should be required. Where residual project noise cannot reasonably be controlled at source, proponent funded residential treatment, mechanical ventilation or air conditioning should remain available.

Emergency access also requires particular attention. The Surface Water Assessment states that the Railway Street access will become impassable during major storm events, with predicted flood depths of approximately 0.95 m in the 1% AEP event and 1.73 m in the 1 in 500 event. The Bushfire Assessment identifies a possible southern alternative route through land not owned or managed by the proponent, but does not clearly demonstrate a continuous, legally secured and all weather route to a public road. Given the need for emergency service access and occupant egress, the continuity, legal availability and physical suitability of any alternate route should be confirmed before the relevant stage of the project proceeds.

Firefighting water and firewater containment also remain dependent on later design. The final firefighting water demand is to be informed by the Fire Safety Study, while the stormwater assessment proposes retaining contaminated firewater within site drainage infrastructure by operational controls. The final design should demonstrate adequate water volume, flow, duration, redundancy, appliance access, containment capacity, rainfall allowance and freeboard before energisation.

The project is also capable of future repowering and technological upgrade. Any future repowering should only occur without further approval where it remains within the hazard, acoustic, firewater, capacity and environmental envelope assessed and approved for SSD-61707209. Material increases in installed energy, hazard consequence, noise, firewater demand or other environmental impacts should require further assessment or modification approval.

A broader concern is the cumulative amount of safety critical information deferred until after determination. Final battery selection, fire testing, acoustic wall design, Fire Safety Study, Emergency Plan, internal fire protection, firefighting water, firewater containment and other important matters are all to be refined later. Individually, some of these matters may reasonably be addressed after consent. Collectively, they create a risk that the environmental performance of the final development will differ materially from the concept assessed in the EIS.

For that reason, any consent should adopt a clear stage gated verification approach. Matters necessary to define the approved environmental envelope should be resolved at determination. Final battery and inverter selection, completed fire testing, updated hazard assessment and final acoustic modelling should be completed before equipment installation. Fire Safety Study, Emergency Plan, firefighting water, emergency access and final design consistency should be verified before commissioning or energisation. Operational noise and other performance outcomes should then be verified after commissioning, with enforceable corrective action where required.

The principle is straightforward: if a matter can be verified, it should be verified; if it requires engineering, the mitigation should be engineered; if it requires a design decision, that decision should be made. Evidence should then be provided before the relevant stage of the project proceeds.

The controls sought in this submission are grounded in established NSW planning, hazardous industry, pollution control, fire safety, bushfire, flood risk and post approval compliance frameworks. They are intended to ensure that the development ultimately constructed is the development whose impacts have actually been assessed.

It is also difficult to understand why members of the surrounding community should be required to devote substantial personal time to identifying and cross checking matters of this significance in the environmental assessment for a project valued at approximately $330 million. Residents should be able to rely on the exhibited EIS to clearly identify the project, its material risks and the safeguards relied upon to demonstrate acceptable impacts. The need for community members to work across numerous technical appendices to identify unresolved fire testing, equipment assumptions, emergency access limitations, acoustic dependencies and other matters raises a broader concern about the adequacy and accessibility of the assessment itself. Community consultation should allow residents to respond to a clearly assessed proposal; it should not require them to effectively undertake part of the proponent’s quality assurance process.

It is particularly concerning that, within a relatively short period of reviewing the exhibited material, a member of the surrounding community has been able to identify multiple unresolved matters involving fire testing, equipment assumptions, acoustic performance, emergency access, firefighting water, firewater containment and future design change. These are not obscure or peripheral issues. They sit directly within the technical disciplines that have been examined over many months by the proponent and its consultant team.

That raises a legitimate question about the quality assurance applied to the assessment before exhibition. Community participation should provide an additional layer of scrutiny, not become the process by which significant gaps in a major project’s environmental assessment are first identified. For a project of this scale and value, the Department should be able to expect that these matters have already been clearly identified, reconciled and bounded before the EIS is placed before the public.

North Harbour Clean Energy is supported by senior planning personnel with substantial experience in the NSW planning system, including previous senior and director level roles within the Department of Planning. Against that background, the unresolved matters identified in this submission are difficult to characterise simply as matters arising from unfamiliarity with the State Significant Development process. They are matters that should be capable of being clearly defined, bounded and resolved through the assessment and consent framework before the relevant stages of construction, installation or operation proceed.

We therefore request that the Department ensure the final approval, if granted, does not rely on broad commitments to resolve material environmental and safety matters later. The consent should clearly define the approved project envelope, the evidence required at each stage, the performance standards to be met, and the consequences where verification shows that the final design falls outside the impacts assessed in the EIS.

Option 2 runs directly through my property and my neighbours property according to the plans provided. The project is intrusive, it will cause major disruption to my livestock not to mention decrease property value. There are no guarantees the WATER pipes and underground water supply to our properties will be safe. I strongly object to this project. Other areas of this project have been rejected by land holders in my area and further afield. This project must not go ahead.

FORMAL OBJECTION – SSD-61707209
Upper Hunter Battery Energy Storage System
To: NSW Department of Planning, Housing and Infrastructure
Re: State Significant Development Application SSD-61707209 – Upper Hunter Battery Energy Storage System
Property: 210 Wells Gully Road, Muswellbrook NSW
From: B Cameron and J Cameron.

I am writing to formally object to the proposed Upper Hunter Battery Energy Storage System (SSD-61707209) and, in particular, to the proposed switching station and associated infrastructure immediately adjoining our property at 210 Wells Gully Road, Muswellbrook. The switching station is planned to be 1.1km from our house.
We have spoken to North Harbour Clean Energy regarding impacts and what they are taking into consideration and have been told, as we are over 1km away, the external audit didn’t consider us to have major impact, as local residents/ primary producers. We have direct visual from our house across undulating land, with no current infrastructure (no obstruction). We are situated on a rural property and we enjoy the quiet environment it currently is. We would like to stress that if that the industrial workplace was to move into McCullys Gap, we would like to see jobs for local residents and businesses. We do not see this happening. The business has taken no undertakings into proper observation of our property/ business impacts. We have had interaction with North Harbour Clean Energy where they can not confirm exact location or impact of the switching station. Consultation should not simply be a general community process. There needs to be meaningful engagement with the landholders who will actually live beside the infrastructure.

We are also concerned about the additional amount of traffic for construction that will cause more dust, especially during dry hot summers, safety and noise. We are a rural dirt road used by the local residents. We will be affected by:
• Dust entering and settling around home
• Additionally cleaning indoor and outdoor
• Settling on roof and entering the rain water tanks we drink from
• Deterioration of existing road
• More vehicles driving up Wells Gully Road will cause more noise
• It is narrow in sections and heavy vehicles coming in will be a safety concern for the local traffic
Dust management measures will need to be imposed and monitored including speed restrictions, road watering and maintenance and dust monitors.

Construction and operation will introduce machinery, trucks, earthworks and industrial noises into what is currently a rural environment. Noise is a significant concern due to our proximity to the proposed switching station. It will need to be monitored during construction and in operation.

We are also concerned about artificial lighting associated with the switching station. Our property has limited artificial lighting surrounding us at night. Lighting could result in light spill onto our property and change the character of our rural surroundings. We request that all lighting be designed to minimise light spill, including downward-facing and shielded fittings and switched off when not required. Any lighting that is required to remain operational overnight should be specifically assessed for its impact on immediately adjoining residences.

We understand that vegetation screening is proposed around the development. While we support appropriate landscaping, vegetation cannot simply be relied upon to eliminate the visual impact of infrastructure of this scale, when the towers are nearly as high as the transmission towers. Even once the proposed vegetation reaches maturity, infrastructure is likely to remain visible from our property and surrounding land. Planting vegetation around the base of a large switching station does not necessarily mean that the infrastructure will be screened from a neighbouring property. We request that the Department assess the visual impact specifically from 210 Wells Gully Road, including views from the house, outdoor living areas and other areas where the infrastructure will be visible. The BESS will change the rural charm of McCullys Gap. We live here to be removed from industrial and town life.

We are also concerned about the extent to which local residents and businesses will actually benefit from the project. If local residents are expected to live with the construction impacts and the permanent change to their rural surroundings, there should be meaningful commitments to local employment and local businesses. We would like to see clear commitments regarding:
• employment of local workers;
• use of local contractors;
• use of local suppliers and businesses;
• local spending during construction; and
• longer-term employment opportunities where available.
The local community should not simply carry the impacts of a major infrastructure project while the economic benefits are largely taken elsewhere.

We are also concerned that there has been no clear information provided to us regarding compensation or other arrangements for directly affected neighbouring landholders. The fact that a project may provide broader community benefits does not necessarily address the individual impacts suffered by a property immediately adjoining the switching station.
I respectfully request that the Department give significant weight to the fact that 210 Wells Gully Road will be immediately adjacent to the proposed switching station part of the Upper Hunter Battery Storage System. We will be living immediately beside large-scale electrical infrastructure, with associated traffic, dust, construction activity, lighting, noise and permanent visual impacts. We do not believe that the impacts on our property and our existing rural amenity have been adequately addressed. For these reasons, I formally object to SSD-61707209 in its current form and request that the Department carefully consider the concerns raised in this submission before making a determination.

Jennifer Cameron and Brad Cameron
210 Wells Gully Road, Muswellbrook NSW

This Project , shows no advantage to all to our small town ( said by 2 separate representative that visited my home - the power it stores is not for our area, will not guarantee better reliable power) it will be a visual eye sore and a potential danger to our community. There is also the effect on the Tawny frog mouth owls, black cockatoos and many parrots and other birds and animal life in the area. I personally will be highly impacted by the visual aspects of this sightly project. The photo used in the information is not a true representation of the true impact. The noise , is also a great concern and I don't believe has been accurately predicted. Noise in the valley can travel differently in the valley and would definitely not be contained to the area noted in information given by North Harbour. This project could be done outside of our town. I feel this was a money grab by our uncaring, low performing council . Who has never had consideration for Aberdeen township. My home is situated on the hill beside the sight , the visual impact is substantial and would be highly effect by fumes and toxins in the event of a battery fire. My property value will drop due to the eye sore this project will be. We were to have someone from NH do a visual prediction, the day the wanted to come was not suitable and were to call with another time . This never happened.
We have spoken for with North Harbour , they have photos from my home the representative took whilst visiting my home , They where also unable to guarantee safety in event of fire , unable to guarantee I wouldn't be able to hear the buzzing . Admitted the visual impact is substantial. And that Aberdeen doesn't benefit at all from this project. Not even power reliability. But none of this is demonstrate in there information. They speak of low probables and donations to charities. This is short lived and questionable. I feel our township, Aberdeen is being used as a dumping ground for a short lived (high waste) , high cost , under performing , environmental experiments that would be a risk to the community and the abundant wildlife only for a couple of hours stored power that isn't for our town. Please consider the impact on our area , the wild life and the health and well being of our town. Consider would you want to see , hear and potentially be a risk from this project? Would you want to see our amazing bird life disappear because of power line and noise ? Would you want to see our beautiful wildlife scared away ? Would you want to see in future years , useless infrastructure , that probably costs more to manufacture environmentally, than it will ever save - going to ruin? Do you want to see after a fire event, the numerous cases of lung and cancerous diseases this project has caused because its to close to residents and situated in a bowl? The fog sits over our town a lot imagine if it held toxins from the Lithium etc. In a world were we know ' highly unlikely' is 'very probable' . I object to this project . There is many areas eg old power station sites - mine sites - waste lands - far from residential areas that could be used for this project - Not within our town or our farm lands.
PLEASE SEE ATTACHED PHOTOS OF VISUAL IMPACT - And we are not the only ones - home down Graeme Bedford and mcleod would also be effected. No tree is going to hide it.

FORMAL OBJECTION – SSD-61707209
Upper Hunter Battery Energy Storage System
To: NSW Department of Planning, Housing and Infrastructure
Re: State Significant Development Application SSD-61707209 – Upper Hunter Battery Energy Storage System
Property: 210 Wells Gully Road, Muswellbrook NSW
From: B Cameron and J Cameron.

I am writing to formally object to the proposed Upper Hunter Battery Energy Storage System (SSD-61707209) and, in particular, to the proposed switching station and associated infrastructure immediately adjoining our property at 210 Wells Gully Road, Muswellbrook. The switching station is planned to be 1.1km from our house.
We have spoken to North Harbour Clean Energy regarding impacts and what they are taking into consideration and have been told, as we are over 1km away, the external audit didn’t consider us to have major impact, as local residents/ primary producers. We have direct visual from our house across undulating land, with no current infrastructure (no obstruction). We are situated on a rural property and we enjoy the quiet environment it currently is. We would like to stress that if that the industrial workplace was to move into McCullys Gap, we would like to see jobs for local residents and businesses. We do not see this happening. The business has taken no undertakings into proper observation of our property/ business impacts. We have had interaction with North Harbour Clean Energy where they can not confirm exact location or impact of the switching station. Consultation should not simply be a general community process. There needs to be meaningful engagement with the landholders who will actually live beside the infrastructure.

We are also concerned about the additional amount of traffic for construction that will cause more dust, especially during dry hot summers, safety and noise. We are a rural dirt road used by the local residents. We will be affected by:
• Dust entering and settling around home
• Additionally cleaning indoor and outdoor
• Settling on roof and entering the rain water tanks we drink from
• Deterioration of existing road
• More vehicles driving up Wells Gully Road will cause more noise
• It is narrow in sections and heavy vehicles coming in will be a safety concern for the local traffic
Dust management measures will need to be imposed and monitored including speed restrictions, road watering and maintenance and dust monitors.
Construction and operation will introduce machinery, trucks, earthworks and industrial noises into what is currently a rural environment. Noise is a significant concern due to our proximity to the proposed switching station. It will need to be monitored during construction and in operation.
We are also concerned about artificial lighting associated with the switching station. Our property has limited artificial lighting surrounding us at night. Lighting could result in light spill onto our property and change the character of our rural surroundings. We request that all lighting be designed to minimise light spill, including downward-facing and shielded fittings and switched off when not required. Any lighting that is required to remain operational overnight should be specifically assessed for its impact on immediately adjoining residences.

We understand that vegetation screening is proposed around the development. While we support appropriate landscaping, vegetation cannot simply be relied upon to eliminate the visual impact of infrastructure of this scale, when the towers are nearly as high as the transmission towers. Even once the proposed vegetation reaches maturity, infrastructure is likely to remain visible from our property and surrounding land. Planting vegetation around the base of a large switching station does not necessarily mean that the infrastructure will be screened from a neighbouring property. We request that the Department assess the visual impact specifically from 210 Wells Gully Road, including views from the house, outdoor living areas and other areas where the infrastructure will be visible. The BESS will change the rural charm of McCullys Gap. We live here to be removed from industrial and town life.

We are also concerned about the extent to which local residents and businesses will actually benefit from the project. If local residents are expected to live with the construction impacts and the permanent change to their rural surroundings, there should be meaningful commitments to local employment and local businesses. We would like to see clear commitments regarding:
• employment of local workers;
• use of local contractors;
• use of local suppliers and businesses;
• local spending during construction; and
• longer-term employment opportunities where available.
The local community should not simply carry the impacts of a major infrastructure project while the economic benefits are largely taken elsewhere.

We are also concerned that there has been no clear information provided to us regarding compensation or other arrangements for directly affected neighbouring landholders. The fact that a project may provide broader community benefits does not necessarily address the individual impacts suffered by a property immediately adjoining the switching station.

I respectfully request that the Department give significant weight to the fact that 210 Wells Gully Road will be immediately adjacent to the proposed switching station part of the Upper Hunter Battery Storage System. We will be living immediately beside large-scale electrical infrastructure, with associated traffic, dust, construction activity, lighting, noise and permanent visual impacts. We do not believe that the impacts on our property and our existing rural amenity have been adequately addressed. For these reasons, I formally object to SSD-61707209 in its current form and request that the Department carefully consider the concerns raised in this submission before making a determination.

Jennifer Cameron and Brad Cameron
210 Wells Gully Road
Muswellbrook NSW

As the owner and occupier of a property adjacent to the proposed switching station I wish to express my strong objection to the development as proposed.
For over 50 years I have enjoyed an uninterrupted view from my residence looking down the Hunter Valley. When deciding on a site for the house the view was a major deciding factor. The farm infrastructure constructed over the years is based around the position of the house. During daylight hours (and dependant on air quality) I can see over the township of Muswellbrook; and once Bayswater Power Station was built can see the steam coming from the top of the cooling stacks. At night the lights of Muswellbrook twinkle in the distance, and the darkness around me gives the starry sky great clarity. I consider myself fortunate, even taking into account the additional development over the years of houses and power lines, to live and work in such surrounds.
The placement of the switching station 500 metres from my house will massively impact my visual amenity.
If I ever need to sell my property, long and uninterrupted views of farmland and bushland would be a purchasers preference if they considering purchasing out of town. Having a switching station 500 metres from the residence, in view from the house and when driving in and out of the property will have a negative effect on any sale price.
Whilst landscaping with trees is proposed to help mitigate the visual effect, my concern is that the amount of trees required will greatly add to any bushfire fuel load in the near vicinity of my house and the majority of my farm infrastructure. The proposed 10m asset protection zone for fire purposes would have next to no effect on the reduction of bushfire severity should a fire occur in the area of the switching station.
In the lodged documents, when referencing the visual impact of the switching station, comparisons have been made between the switching station and existing transmission lines in terms of both types of structures fading into background views. I fail to see the similarity between a large structure surrounded by security fencing and lit at nighttime and doubt that it has the same ability to fade into the background scenery as single transmission poles spaced across the area. I believe that the switching station would be far more obtrusive in the landscape than a transmission pole.
While reading the EIS and appendixes I saw many references to the current scenic value of the land surrounding the project, and the evaluations of the effect that the project would have on the scenic quality. Whilst I do understand the need to standardise terms for the purpose of evaluation I take exception to the land surrounding the switching station being rated as low scenic value, and therefore reaching a conclusion that adding substantial infrastructure would have minimal (sometimes moderate) effect. Judging the beauty of anything is a subjective exercise, and so despite those who prepared the reports deeming where I live to have minimal scenic quality, I have always thought that that the views I have, and the landscape surrounding me are magnificent, and it will deeply sadden me to lose them.

The proposed site of the switching station is on a natural rise in the landscape. If the rise was flattened and the switching station built at a lower level, this would substantially reduce the negative effect the switching station would have of my visual amenity, as would an assurance that any lighting that is required be as low wattage as practicable and pointed down to avoid lighting up the night sky.

I totally object to the proposed 400MW / 920MWh Upper Hunter Battery Energy Storage System (SSD-61707209) as the unconscionable approval of this facility would have extremely serious public health, environmental, economic, and national security hazards for the Upper Hunter and Muswellbrook Shires, and the broader NSW/Australian public.

Instead of continuing down a path of volatile, incapable, astronomically costly, taxpayer-subsidised, and foreign-reliant experimental junk, the NSW Government must stop its torturous policies that the Coalition instigated and instead prioritise a secure, safe, reliable, and affordable Australian energy grid built on solid baseload coal-fired power and a future sovereign nuclear energy industry.

The dodgy Department must do their due diligence and essential risk research for once which would reject this application in its entirety.

Catastrophic Public Health & Safety Hazards (Thermal Runaway and Fire)
Lithium-ion Battery Energy Storage Systems (BESS) at this "mega-scale" are unprecedented concentrations of unstable energy that present catastrophic safety risks.
Uncontrollable Thermal Runaway: According to structural fire safety data, there is a severe lack of engineering standards to prevent thermal runaway. Once a single cell fails, it cascades instantly, creating explosions and fires that are fundamentally beyond the containment capabilities of local Fire and Rescue Services.

Fire Service Limitations: Fire and Rescue NSW explicitly acknowledges a lack of legislative guidance and building code provisions regarding emerging battery technologies, stating that we "do not yet know enough about their probability of failure... and potential consequences" (FRNSW Lithium-Ion Battery Safety Guidelines). Furthermore, the CSIRO ActivFire® Advisory Note AN-004 explicitly states it has not and will not certify that any standard fire extinguisher can effectively put out a lithium-ion battery fire.

Lethal Toxic Gas Plumes: Should a thermal runaway event occur at Campbell St, Aberdeen, it will release immense plumes of lethal Hydrogen Fluoride gas and create Hydrofluoric Acid runoff.
This poses an immediate, fatal threat to the local public, including infants and young children.

Irreparable Environmental Contamination: The Global Precedent
The Department cannot ignore the devastating real-world precedent set by the catastrophic fires at the world's largest BESS facility in Moss Landing, California.
Toxic Metal Fallout: Independent peer-reviewed research published in Scientific Reports(2025) documented that the Moss Landing BESS fire blanketed adjacent ecosystems in toxic cathode heavy metals, causing surface soil concentrations of nickel, manganese, and cobalt to spike by orders of magnitude.
This fallout is vastly more difficult to manage than a radioactivity spill, as these transition metals cannot be easily tracked with a simple Geiger counter.

Long-Term Ecosystem Poisoning: Community and state tests following the Moss Landing disasters revealed that heavy metals leached into local life-sustaining water sources and agricultural zones, leaving residents suffering from persistent respiratory failure, metallic tastes, rashes, and headaches.
To approve a 920MWh facility in the Upper Hunter agricultural and breeding heartland—knowing it will inevitably poison our soil and waterways through rain and atmospheric transport—is pure negligence.

“Forever Chemicals" (PFAS): Peer-reviewed research published in The Guardian (July 2024) confirms that the clean energy transition is heavily reliant on an unregulated subclass of toxic PFAS compounds called bis-FASI used explicitly in lithium-ion batteries. These "forever chemicals" do not break down, move effortlessly through the atmosphere, and are heavily linked to cancers, liver disease, and birth defects.

National Security Threats and Foreign Coercion
A grid reliant on industrial BESS is a grid exposed to critical national security vulnerabilities.
Supply Chain Dependency: The manufacturing of these mega-scale battery systems is completely monopolised by hostile foreign entities, specifically supply chains tied to the Chinese Communist Party (CCP).

Asymmetric Infrastructure Risks: Entrusting our domestic electricity supply to hardware manufactured by foreign adversaries exposes Australia to systemic coercion.
These battery systems utilise closed-source digital management networks that can be targeted, disabled, or manipulated to overheat remotely, giving hostile foreign actors the ability to sabotage our domestic power supply or threaten local populations with weaponised infrastructure fires.
The United States has moved to aggressively restrict and ban infrastructure linked to hostile foreign regimes; Australia must immediately follow suit.

Unethical Global Supply Chains ("Blood Cobalt")
The underlying supply chain for the lithium-ion batteries intended for this project is highly unethical.
The procurement of the required raw materials relies directly on blood cobalt extracted by over 40,000 children—some as young as six years old—in the Democratic Republic of the Congo. These children mine toxic materials with their bare hands in slave-like, lethal conditions to satisfy the unconscionable corporate demand of green energy developers.
Approving such unethical plans makes NSW complicit in egregious, international human rights abuses and child labour exploitation.

Grid De-stabilisation, Market Manipulation, and Economic Ruin
The entire economic framework supporting grid-scale BESS is a predatory swindle designed to strip wealth from ordinary Australian taxpayers.
Artificial Economics & Taxpayer Subsidies: As demonstrated by energy market analysts Aidan Morrison and Paul Miskelly, these projects are entirely unviable without massive, distortive taxpayer subsidies that cannibalise our state budget.
BESS operators survive by inflating consumer power bills and manipulating the spot market—arbitrarily buying electricity cheap when it is in oversupply and selling it back at extortionate prices when demand peaks.

Costs of the "RenewaBULL" Scam
The latest comprehensive data regarding true, whole-of-system generation costs proves that traditional coal-fired power remains substantially cheaper and infinitely more secure than intermittent ‘renewables’ backed by short-lifespan, bankruptingly costly batteries.

Conclusion: The Sovereign Energy Alternative
Australia is a nation built on abundant, rich energy resources.
True grid reliability, safety, and economic affordability can only be guaranteed by sustaining a robust, secure base-load coal network.
Developing a safe, sovereign nuclear power industry would also ensure decades of Australian benefiting energy security without the toxic, explosive liabilities of inferior, short-term, pathetically intermittent, lithium junk.

The Upper Hunter Battery Energy Storage System (SSD-61707209) is a public safety crisis waiting to happen.
It is dangerous, un-Australian, ethically bankrupt, and an absolute threat to our national security.
The untrustworthy, Department of Planning, Housing and Infrastructure Dictatorship must reject this application and safeguard public health and safety, our life-sustaining food resource land and water sources, our economic prosperity, energy security and national security.

1. Executive Summary
We represent deeply concerned residents, farmers, and business owners who refuse to be sacrificed for astronomically costly ideological idiocy and corporate experimentation.
We absolutely and unconditionally oppose the Upper Hunter BESS proposal.

This project is not a step forward; it is an unregulated, dangerous hazard that introduces severe safety, environmental, economic, and national security threats to the region and Australia.

The protection of the people and biodiversity of the Hunter Valley must be prioritised by the hapless and irresponsible NSW Government who keep lying about minimal impacts of extremely hazardous BESS.
Advocating instead for the expansion of reliable, safe, and cost-effective baseload HELE coal infrastructure and the deployment of an Australian nuclear energy industry - with minimal environmental footprint - is essential - to safeguard our energy security, food security, protection of biodiversity, economic prosperity and national security.

2. Public Safety Hazards: Unmasking the Toxic Fire Threat
The sheer volume of chemical storage proposed for Campbell Street represents an unacceptable hazard to the town centres.
* The Reality of Thermal Runaway: Industry data confirms that giant lithium-ion battery blocks are vulnerable to cascading thermal runaway events. If a single microcell shorts or cracks, it sets off an explosive domino effect that cannot be stopped.
* Our Fire Services are Unequipped: Fire and Rescue NSW explicitly warns in their operational guidelines that there is a dangerous "lack of guidance and provisions in building codes" regarding these massive facilities, noting that the long-term consequences of failure are still fundamentally unknown. Local emergency crews do not have the specialised capacity to handle a toxic lithium inferno. Furthermore, the CSIRO’s ActivFire® Advisory Note AN-004 clearly reveals that the agency refuses to certify any fire extinguisher as capable of putting out a lithium-ion battery fire.
* Lethal Plumes Over Aberdeen: If this facility ignites, families, babies, and elderly residents will be exposed to massive clouds of Hydrogen Fluoride Gas.
* When mixed with moisture, this forms highly corrosive Hydrofluoric Acid, creating a deadly atmospheric hazard and permanently poisoning the local air and soil. Approving this project is a catastrophic gamble with public health.

3. Environmental Devastation: Learning from the Moss Landing Catastrophe
The DPHI must stop
Ignoring the grim reality of what happens when these industrial battery sites fail.
* The Moss Landing Precedent: In California, the world's largest lithium-ion battery storage plant has repeatedly erupted in major chemical fires. Peer-reviewed research published in Scientific Reports (2025) confirmed that the smoke plumes coated the surrounding landscape in thick fallout layers of toxic cathode metals, including nickel, manganese, and cobalt.
* Poisoned Water and Soils: Following the American disasters, independent testing revealed heavy metal concentrations rose by up to 1,000 times background levels, leaving local families battling chronic respiratory issues, skin rashes, and systemic chemical toxicity. This transition metal fallout cannot be traced with standard tools like a handheld Geiger counter, meaning tracking and cleaning the pollution is an operational nightmare. We cannot possibly allow the agricultural and equine breeding heartland of the Hunter Valley to be contaminated by toxic dust and chemical runoff.
* "Forever Chemical" Seepage: A landmark 2024 study published in The Guardian detailed that lithium-ion batteries are heavily reliant on an unregulated class of PFAS known as bis-FASI. These human-made "forever chemicals" do not break down, travel effortlessly through weather systems, and are closely linked to cancers, reproductive disorders, and severe birth defects.

4. National Security Vulnerabilities and Sovereign Risk
Handing over the keys of our regional electricity transmission framework to hostile, CCP reliant hardware is an active threat to Australia’s national security.
* Foreign Coercion and Sabotage: The supply chains for lithium-ion battery packs and software are monopolised by state-backed entities connected directly to the Chinese Communist Party (CCP).
* Weaponised Infrastructure: These giant battery arrays rely on integrated digital management platforms that are highly vulnerable to cyber-attacks and remote back-door manipulation. Hostile foreign actors possess the capability to remotely trigger over-charging protocols to induce systemic grid collapse or manipulate the batteries to overheat and explode. The United States has already banned infrastructure linked to hostile foreign adversaries on national security grounds; the NSW Government should be blocking this dangerous junk, not approving it.

5. Complicity in Global Child Exploitation
The corporate push for "green energy" masks a horrific humanitarian crisis that we refuse to ignore. The manufacturing of lithium-ion batteries relies heavily on blood cobalt yanked out of the ground in the Democratic Republic of the Congo. Over 40,000 children, some as young as six years old, are forced to dig these toxic minerals out of unstable pits with their bare hands for minimal pay. This project is built on child slavery and severe human rights abuses. Unlike the unethical NSW Government who have Power Purchase Agreements with unethical, industrialised Solar like dodgy Clean Peak Energy for Barangaroo - we will not stay silent while corporate developers enrich themselves off the exploitation of cruelly tortured, vulnerable children.

6. The RUIN-A-BULL Swindle: Economic Deception
This project is an artificial, subsidised market scam designed to bleed money from everyday consumers to enrich corporate entities like North Harbour Clean Energy.
* Taxpayer-Funded Exploitation: As detailed by reputable, independent energy analysts, these BESS projects are entirely unviable without continuous, heavy taxpayer subsidies. They survive by manipulating the energy spot market—buying up power artificially cheap during oversupply, hoarding it, and selling it back at extortionate premium rates when the grid is under stress.
* The Coal Reality: The federal government’s own whole-of-system cost evaluations prove that traditional baseload coal-fired power is substantially cheaper, more reliable, and safer than intermittent renewable projects backed by volatile, short-lifespan chemical batteries. The entire framework is an economic scam that drives up inflation and threatens energy security and national security.

7. A Secure Nuclear Future
Our community group requires real energy security, absolute safety, and long-term affordability. This can only be achieved by backing our traditional baseload coal assets as well as supporting a future Australian nuclear power industry.
Nuclear reactors offer an incredibly small physical footprint, run consistently for decades regardless of the weather, and present zero toxic atmospheric smoke or explosive fire risks to surrounding towns.

We will not stand by and let our regions be turned into high-risk chemical dumps by this despicable Government.
The NSW Government must stop harming us and fulfil its primary duty to protect - not sacrifice - its citizens by rejecting the Upper Hunter BESS application (SSD-61707209) in its entirety.