ATTN: Cameron Ashe
Department of Planning, Housing and Infrastructure
RE: Gundary Solar Farm project (SSD 48225958)

Delivered via NSW Planning Portal 12 December 2024

Gundary Solar Farm project (SSD 48225958)

I write to you to express my strong objection to the proposed building of a solar farm on the Gundary Plains. I am daughter-in-law of the owner, and the wife of the farm manager of “Bullamalita” pastoral company a 4000-acre grazing and cropping property. This property has been in the Peden family since 1923. “Bullamalita” neighbours “Rosedale”, and will be directly affected, given its proximity to the proposed development. I am also an essential services worker (registered nurse and midwife).

The first objection I make is that this proposed development is not even within the published Renewable Energy Zones (REZ) published by the NSW Government. The REZs were developed based on extensive planning, mapping, and consultation to identify areas where renewable energy projects are most suitable. Expanding outside of these zones without clear reasoning could undermine the purpose of this planning. If the REZs are to be a foundational part of the state's renewable energy strategy, it’s essential that any development outside those zones be rigorously justified and aligned with broader policy objectives.

The size of the project is substantial. Its effect on the surrounding area would be significant. This land has been farmed, both in terms of grazing and cropping, since the very early beginnings of agriculture in NSW. It has proved to be some of the best land available in NSW for the growing of fine wool, and has developed into an exceptional producer of fat lambs for slaughter. These lambs are grown for both export and domestic consumption.

“Bullamalita” is in fact, is the home of “The Big Merino” an iconic 15.2 metre, three storey concrete and steel monument that was built in 1985 as a celebration of the Goulburn and surrounding district’s fine wool industry. The life-like Ram structure was modelled on “Rambo,” stud ram that was bred by Robert Peden (owner of Bullamalita).

“Bullamalita” is run on a large successful commercial scale, by the same family, for in excess of 100 years. I do not accept the proposition that sheep are able to graze under the panels and that there is no loss of grazing area. That is a fundamentally ludicrous assertion evidently made by someone with little to no understanding of farming practices, nor by someone who understands livestock.

My second objection is that the proposal will have significant impact on native wildlife such as the South-Eastern Glossy Black Cockatoo, Spotted-tail quoll and the superb Lyrebird. These three specific endangered national treasures are local species in the area and there are existing NSW initiatives active to ensure their safety. “Bullamalita” participated in the Rivers of Carbon (ROC) / Greening Australia initiative to fence off critical habitat area and plant native vegetation to attract and house the South-Eastern Glossy Black Cockatoo. ‘Quollidor’ (NSW Saving our Species program) is an additional conservation project that is being pursued by state Government – Environment and Heritage to acknowledge and monitor the Quoll on the South Coast crossing to the Blue Mountains, NSW. Solar Farm infrastructure would have devastating impacts on these vulnerable species.

My third objection is that the proposal is less than 10 kilometres from the township of Goulburn. The area already has a significant number of residents in and around it, with the current population of Goulburn Mulwaree at 32,710, with a 0.87% population growth noted (Goulburn Mulwaree Council, 2023). The loss of amenity, not only during construction, but also during operation, would be enormous. Of additional concern, is that the same owner of the land on which the current development is proposed to be constructed has just purchased the property known as “Rosedale”. The only logical assumption that can be drawn from that purchase is clearly a longer-term plan to expand the current proposal. Though this is obviously not yet published, it is most clear that this is within frame of mind. To suggest otherwise flies in the face of commercial reason.

The transport of machinery and the solar panels to site will have a detrimental effect on the single lane carriageway of Windellama Rd. The road is already busy during the year, and particularly so during school holidays when many people use it as part of the journey to the South Coast. The potential for collisions between multiple trucks servicing and delivering to the proposed site, and domestic traffic, is a major concern. Similarly, the construction and operation of the solar farm would present an immense challenge to the operation of the surrounding farms. Naturally, the implementation of various road blocks and the like would halt the transportation of stock, sowing and harvesting machinery as between farms. To stultify the local agricultural operations in such a way for the purposes of a solar farm, which is more than likely soon to be obsolete, is not only a waste of taxpayer funds, but will have a self-evident effect on the broader community.

My fourth objection is the considerable fire risk posed by the development. Fire activity is significant in dry years, and the fire-risk presented by lithium batteries is well documented; so too is the nature of the fire that breaks out from such batteries, and the difficulty of extinguishing such a fire. Should any major fire break out in the battery storage facility, there is a very real question as to whether the local bush fire brigade, made up predominantly of volunteer local farmers, would have the equipment, and indeed know how to combat such an occurrence. I am not aware if the NSW Fire Brigade’s Goulburn station commands ability to provide trained fire fighters and the appropriate apparatuses should such a fire require their intervention. The effects of such fire on the agricultural surrounds needn’t be stated.

My fifth objection is a financial one. It is undeniable that the construction of such a facility, particularly on the scale proposed, will have a devaluing effect on surrounding properties. Persons wishing to live, or seeking a place to live in the country, are not going to choose to purchase a property whose main visual feature is a view over almost three quarters of a million solar panels. For those of us who live here, we have invested considerable capital in developing our own farms to make them as productive as they can be. That capital investment will be considerably depleted by the unarguable fact that no one will want to live next to a solar factory.
I do not accept that the proposal will provide large scale local employment. Having lived in the area for a long time, I have encountered numerous crews who have been employed to build windfarms within the shire. In my experience, these crews are made up of either foreign working visa holders, or persons who are not local area residents. Once the project is complete, they leave, and make no further contribution to the town. It is not a criticism of them, it’s just a fact. I note the proposed staffing level for the farm, once complete, is minimal. It is not right to present this benefit to the community knowing that not to be the experience in like-projects of the past.

My sixth, and in some ways most serious concern, is the lack of any detail regarding the decommissioning of the site. Solar has not proved to be a huge producer of renewable energy. It is hamstrung by the fact that it only operates during daylight hours, and battery technology has not developed to the point that all the power produced can be stored (and certainly not on a scale that can sustain base load power over the length of the night time period). Windellama is notorious for soup-like fogs for a number of days each year, and in addition is prone to hail. It is inevitable that there will be a number of days in which the contribution to the power grid from this proposal would be nil.

The panels themselves seem to have a life span of 10 years. The disposal of used panels has proved very problematic to other operators. Recycling does not appear to be an option. Of greater concern is that it is likely that Lightsource Development Services will at some stage seek to sell the development. Any agreement as to the rehabilitation or remediation of the land upon the decommissioning of the site will be made much less tenable in the very likely event that BP elect to sell the project at some stage in the future. Whilst I have no difficulty with BP making a profit from its investment, it is the indeterminacy of the enforceability of those conditions on future purchasers that concerns me. Should the solar farm become economically unviable due to a change in technology, age, or because it is outstripped by other sources of generation, it can hardly be a financially attractive option to any owner at that time to spend the millions that would be required to bring the land back to its current state.
It is for these reasons I am opposed to the development as currently proposed.

I declare that no reportable political donations have been made by me in the last two years. I acknowledge acceptance of the Department’s disclaimer and declaration.

Yours sincerely
Emma Gill Peden

Liability limited by a scheme approved under the Professional Standards Legislation

I am a neighbour of the proposed Gundary Solar Farm and will be directly affected by it.
I fully support the project on environmental and social grounds.
Directly affected neighbours should be compensated by Lightsource BP and a community fund should be established benefiting the wider community over the life of the project.

We have seen some changes in the proposed plan since Lightsource bp and UMWELT took our concerns from the community engagement sessions. Notwithstanding, the major issues haven't been addressed so far. We collated those in the attached file.
Residents and the broader community are well versed and voiced their concerns since the proposal of the solar installation. There is no “perceived inability”, MANY people spoke up, wrote, voiced, discussed. Lightsource bp was contacted many times on many occasions. It’s been shocking at the community consultation meeting to experience the missing of relevant information, competence, and engagement on behalf of the consultation firm UMWELT. With this submission we want to get concrete answers to the mentioned problems as they still stand.

ATTN: Cameron Ashe
Department of Planning, Housing and Infrastructure
RE: Gundary Solar Farm project (SSD 48225958)

Delivered via NSW Planning Portal 12 December 2024

RE: Gundary Solar Farm project (SSD 48225958)

I write to you to express my strong objection to the proposed building of a solar farm on the Gundary Plains. I am the owner of “Bullamalita” pastoral company a 4000-acre grazing and cropping property. This property has been in the Peden family since 1923. “Bullamalita” neighbours “Rosedale”, and will be directly affected, given its proximity to the proposed development.

The first objection I make is that this development is not even within the published Renewable Energy Zones (REZ) published by the NSW Government. This begs the question - why go to the trouble of publishing such zones if it is your intention to consider developments that are outside the very areas you designated?

The size of the project is substantial. Its effect on the surrounding area would be significant. This land has been farmed, both in terms of grazing and cropping, since the very early beginnings of agriculture in NSW. It has proved to be some of the best land available in NSW for the growing of fine wool, and has developed into an exceptional producer of fat lambs for slaughter. These lambs are grown for both export and domestic consumption.

“Bullamalita” in fact, is the home of “The Big Merino” an iconic 15.2 metre, three storey concrete and steel monument that was built in 1985 as a celebration of the Goulburn and surrounding district’s fine wool industry. The life-like Ram structure was modelled on “Rambo,” stud ram that was bred by Robert Peden (owner of Bullamalita).

"Bullamalita" is run on a large successful commercial scale, by the same family, for in excess of 100 years. I do not accept the proposition that sheep are able to graze under the panels and that there is no loss of grazing area. That is a fundamentally ludicrous assertion evidently made by someone with little to no understanding of farming practices, nor by someone who understands livestock.

My second objection is that the proposal will have significant impact on native wildlife such as the South-Eastern Glossy Black Cockatoo, Spotted-tail quoll and the superb Lyrebird. These three specific endangered national treasures are local species in the area and there are existing NSW initiatives active to ensure their safety. “Bullamalita” participated in the Rivers of Carbon (ROC) / Greening Australia initiative to fence off critical habitat area and plant native vegetation to attract and house the South-Eastern Glossy Black Cockatoo. ‘Quollidor’ (NSW Saving our Species program) is an additional conservation project that is being pursued by state Government – Environment and Heritage to acknowledge and monitor the Quoll on the South Coast crossing to the Blue Mountains, NSW. Solar Farm infrastructure would have devastating impacts on these vulnerable species.

My third objection is that the proposal is less than 10 kilometres from the township of Goulburn. The area already has a significant number of residents in and around it, with the current population of Goulburn Mulwaree at 32,710, with a 0.87% population growth noted (Goulburn Mulwaree Council, 2023). The loss of amenity, not only during construction, but also during operation, would be enormous. Of additional concern, is that the same owner of the land on which the current development is proposed to be constructed has just purchased the property known as “Rosedale”. The only logical assumption that can be drawn from that purchase is clearly a longer-term plan to expand the current proposal. Though this is obviously not yet published, it is most clear that this is within frame of mind. To suggest otherwise flies in the face of commercial reason.

The transport of machinery and the solar panels to site will have a detrimental effect on the single lane carriageway of Windellama Rd. The road is already busy during the year, and particularly so during school holidays when many people use it as part of the journey to the South Coast. The potential for collisions between multiple trucks servicing and delivering to the proposed site, and domestic traffic, is a major concern. Similarly, the construction and operation of the solar farm would present an immense challenge to the operation of the surrounding farms. Naturally, the implementation of various road blocks and the like would halt the transportation of stock, sowing and harvesting machinery as between farms. To stultify the local agricultural operations in such a way for the purposes of a solar farm, which is more than likely soon to be obsolete, is not only a waste of taxpayer funds, but will have a self-evident effect on the broader community.

My fourth objection is the considerable fire risk posed by the development. Fire activity is significant in dry years, and the fire-risk presented by lithium batteries is well documented; so too is the nature of the fire that breaks out from such batteries, and the difficulty of extinguishing such a fire. Should any major fire break out in the battery storage facility, there is a very real question as to whether the local bush fire brigade, made up predominantly of volunteer local farmers, would have the equipment, and indeed know how to combat such an occurrence. I am not aware if the NSW Fire Brigade’s Goulburn station commands ability to provide trained fire fighters and the appropriate apparatuses should such a fire require their intervention. The effects of such fire on the agricultural surrounds needn’t be stated.

My fifth objection is a financial one. It is undeniable that the construction of such a facility, particularly on the scale proposed, will have a devaluing effect on surrounding properties. Persons wishing to live, or seeking a place to live in the country, are not going to choose to purchase a property whose main visual feature is a view over almost three quarters of a million solar panels. For those of us who live here, we have invested considerable capital in developing our own farms to make them as productive as they can be. That capital investment will be considerably depleted by the unarguable fact that no one will want to live next to a solar factory.

I do not accept that the proposal will provide large scale local employment. Having lived in the area for a long time, I have encountered numerous crews who have been employed to build windfarms within the shire. In my experience, these crews are made up of either foreign working visa holders, or persons who are not local area residents. Once the project is complete, they leave, and make no further contribution to the town. It is not a criticism of them, it’s just a fact. I note the proposed staffing level for the farm, once complete, is minimal. It is not right to present this benefit to the community knowing that not to be the experience in like-projects of the past.

My sixth, and in some ways most serious concern, is the lack of any detail regarding the decommissioning of the site. Solar has not proved to be a huge producer of renewable energy. It is hamstrung by the fact that it only operates during daylight hours, and battery technology has not developed to the point that all the power produced can be stored (and certainly not on a scale that can sustain base load power over the length of the night time period). Windellama is notorious for soup-like fogs for a number of days each year, and in addition is prone to hail. It is inevitable that there will be a number of days in which the contribution to the power grid from this proposal would be nil.

The panels themselves seem to have a life span of 10 years. The disposal of used panels has proved very problematic to other operators. Recycling does not appear to be an option. Of greater concern is that it is likely that Lightsource Development Services will at some stage seek to sell the development. Any agreement as to the rehabilitation or remediation of the land upon the decommissioning of the site will be made much less tenable in the very likely event that BP elect to sell the project at some stage in the future. Whilst I have no difficulty with BP making a profit from its investment, it is the indeterminacy of the enforceability of those conditions on future purchasers that concerns me. Should the solar farm become economically unviable due to a change in technology, age, or because it is outstripped by other sources of generation, it can hardly be a financially attractive option to any owner at that time to spend the millions that would be required to bring the land back to its current state.
It is for these reasons I am opposed to the development as currently proposed.

I declare that no reportable political donations have been made by me in the last two years. I acknowledge acceptance of the Department’s disclaimer and declaration.

Yours sincerely
Maree T Peden

Liability limited by a scheme approved under the Professional Standards Legislation

ATTN: Cameron Ashe
Department of Planning, Housing and Infrastructure
RE: Gundary Solar Farm project (SSD 48225958)

Delivered via NSW Planning Portal 12 December 2024
Gundary Solar Farm project (SSD 48225958)

I write to you to express my strong objection to the proposed building of a solar farm on the Gundary Plains. I am the farm manager of “Bullamalita” pastoral company a 4000-acre grazing and cropping property. This property has been in the Peden family since 1923. “Bullamalita” neighbours “Rosedale”, will be directly affected, given its proximity to the proposed development.

The first objection I make is that this development is not even within the published Renewable Energy Zones (REZ) published by the NSW Government. This begs the question - why go to the trouble of publishing such zones if it is your intention to consider developments that are outside the very areas you designated?

The size of the project is substantial. Its effect on the surrounding area would be significant. This land has been farmed, both in terms of grazing and cropping, since the very early beginnings of agriculture in NSW. It has proved to be some of the best land available in NSW for the growing of fine wool, and has developed into an exceptional producer of fat lambs for slaughter. These lambs are grown for both export and domestic consumption.

“Bullamalita” in fact, is the home of “The Big Merino” an iconic 15.2 metre, three storey concrete and steel monument that was built in 1985 as a celebration of the Goulburn and surrounding district’s fine wool industry. The life-like Ram structure was modelled on “Rambo,” stud ram that was bred by Robert Peden (owner of Bullamalita).

"Bullamalita" is run on a large successful commercial scale, by the same family, for in excess of 100 years. I do not accept the proposition that sheep are able to graze under the panels and that there is no loss of grazing area. That is a fundamentally ludicrous assertion evidently made by someone with little to no understanding of farming practices, nor by someone who understands livestock.

My second objection is that the proposal will have significant impact on native wildlife such as the South-Eastern Glossy Black Cockatoo, Spotted-tail quoll and the superb Lyrebird. These three specific endangered national treasures are local species in the area and there are existing NSW initiatives active to ensure their safety. “Bullamalita” participated in the Rivers of Carbon (ROC) / Greening Australia initiative to fence off critical habitat area and plant native vegetation to attract and house the South-Eastern Glossy Black Cockatoo. ‘Quollidor’ (NSW Saving our Species program) is an additional conservation project that is being pursued by state Government – Environment and Heritage to acknowledge and monitor the Quoll on the South Coast crossing to the Blue Mountains, NSW. Solar Farm infrastructure would have devastating impacts on these vulnerable species.

My third objection is that the proposal is less than 10 kilometres from the township of Goulburn. The area already has a significant number of residents in and around it, with the current population of Goulburn Mulwaree at 32,710, with a 0.87% population growth noted (Goulburn Mulwaree Council, 2023). The loss of amenity, not only during construction, but also during operation, would be enormous. Of additional concern, is that the same owner of the land on which the current development is proposed to be constructed has just purchased the property known as “Rosedale”. The only logical assumption that can be drawn from that purchase is clearly a longer-term plan to expand the current proposal. Though this is obviously not yet published, it is most clear that this is within frame of mind. To suggest otherwise flies in the face of commercial reason.

The transport of machinery and the solar panels to site will have a detrimental effect on the single lane carriageway of Windellama Rd. The road is already busy during the year, and particularly so during school holidays when many people use it as part of the journey to the South Coast. The potential for collisions between multiple trucks servicing and delivering to the proposed site, and domestic traffic, is a major concern. Similarly, the construction and operation of the solar farm would present an immense challenge to the operation of the surrounding farms. Naturally, the implementation of various road blocks and the like would halt the transportation of stock, sowing and harvesting machinery as between farms. To stultify the local agricultural operations in such a way for the purposes of a solar farm, which is more than likely soon to be obsolete, is not only a waste of taxpayer funds, but will have a self-evident effect on the broader community.

My fourth objection is the considerable fire risk posed by the development. Fire activity is significant in dry years, and the fire-risk presented by lithium batteries is well documented; so too is the nature of the fire that breaks out from such batteries, and the difficulty of extinguishing such a fire. Should any major fire break out in the battery storage facility, there is a very real question as to whether the local bush fire brigade, made up predominantly of volunteer local farmers, would have the equipment, and indeed know how to combat such an occurrence. I am not aware if the NSW Fire Brigade’s Goulburn station commands ability to provide trained fire fighters and the appropriate apparatuses should such a fire require their intervention. The effects of such fire on the agricultural surrounds needn’t be stated.

My fifth objection is a financial one. It is undeniable that the construction of such a facility, particularly on the scale proposed, will have a devaluing effect on surrounding properties. Persons wishing to live, or seeking a place to live in the country, are not going to choose to purchase a property whose main visual feature is a view over almost three quarters of a million solar panels. For those of us who live here, we have invested considerable capital in developing our own farms to make them as productive as they can be. That capital investment will be considerably depleted by the unarguable fact that no one will want to live next to a solar factory.

I do not accept that the proposal will provide large scale local employment. Having lived in the area for a long time, I have encountered numerous crews who have been employed to build windfarms within the shire. In my experience, these crews are made up of either foreign working visa holders, or persons who are not local area residents. Once the project is complete, they leave, and make no further contribution to the town. It is not a criticism of them, it’s just a fact. I note the proposed staffing level for the farm, once complete, is minimal. It is not right to present this benefit to the community knowing that not to be the experience in like-projects of the past.

My sixth, and in some ways most serious concern, is the lack of any detail regarding the decommissioning of the site. Solar has not proved to be a huge producer of renewable energy. It is hamstrung by the fact that it only operates during daylight hours, and battery technology has not developed to the point that all the power produced can be stored (and certainly not on a scale that can sustain base load power over the length of the night time period). Windellama is notorious for soup-like fogs for a number of days each year, and in addition is prone to hail. It is inevitable that there will be a number of days in which the contribution to the power grid from this proposal would be nil.

The panels themselves seem to have a life span of 10 years. The disposal of used panels has proved very problematic to other operators. Recycling does not appear to be an option. Of greater concern is that it is likely that Lightsource Development Services will at some stage seek to sell the development. Any agreement as to the rehabilitation or remediation of the land upon the decommissioning of the site will be made much less tenable in the very likely event that BP elect to sell the project at some stage in the future. Whilst I have no difficulty with BP making a profit from its investment, it is the indeterminacy of the enforceability of those conditions on future purchasers that concerns me. Should the solar farm become economically unviable due to a change in technology, age, or because it is outstripped by other sources of generation, it can hardly be a financially attractive option to any owner at that time to spend the millions that would be required to bring the land back to its current state.
It is for these reasons I am opposed to the development as currently proposed.

I declare that no reportable political donations have been made by me in the last two years. I acknowledge acceptance of the Department’s disclaimer and declaration.

Yours sincerely
Michael Scott Peden

See attached objection.