To: Department of Planning, Housing and Infrastructure (NSW)
Our Ref: Merino Solar Farm: SSD 59155459 – Objection to Proposed Solar Farm
Name: Johnny Nasr
Address: 81 Gretta Road, Tirrannaville (R6 as identified on the EIS Scoping Map)
To Whom It May Concern,
I Johnny Nasr, write to formally object to the proposed Merino Solar Farm (SSD 59155459). Although I current reside in Sydney, our property in Tirrannaville has been a place of enjoyment that has brought us many good memories from when my parents purchased the property in the early 2000s. It is a place my own family and I go to every so often to relax, unwind and enjoy. I also attend to visit my parents and congregate with my fellow siblings and their families, a place we all regard as a retreat, connection and rural heritage that means everything to our family.
The proposal poses deep concerns for us in many ways including socially, environmentally, emotionally and culturally. Our property is seen to be a place that we grew up on as kids and would love to see our kids and the next generation of kids enjoy just like we did growing up.
I am extremely concerned with the lack of community engagement from the developers. My parents have not received any direct communication or consultation from the developers. We have not been contacted regarding visual impacts, proposals for potential agreements or for any justification opportunities. The sad reality is that we only became aware of this proposal through word of mouth from the local community who also seemed to be completely frustrated with the lack of communication. As my parents are older and find it harder to research, investigate and discuss with the local community, I have been conducting these works on their behalf and am extremely shocked to see such solar farm proposal of this scale, positioned within extremely close proximity within direct visual range of our family home, can proceed without the developers acknowledging our existence. I myself work for many Developers and do consultant to all affected even where it is a small project, but seeing something along this scale with no consultation raises a lot of red flags and concerns. The EIS process is not accessible to people unfamiliar with complex planning systems, especially parents like mine. If I have not stepped into the process myself my parents will have no understanding of what is being proposed, and along with day to day work and family commitments we are left to interpret technical documents, unfamiliarity’s, navigate portals etc all while having a short window timeframe to complete in. More should have been done to consult with my parents who are suffering mentally from the anxiety due to this proposal.
An extremely large solar farm of such close proximity to many of the community and Goulburn itself in our opinion will have significant impacts. I don’t want to list them but I am sure many others affected will get their message across. From my families perspective our property is extremely important to us whereby my parents came to Australia being born overseas to pursue a better life. What they have created at 81 Gretta Rd, Tirrannaville is a legacy, not just a house, but a home filled with culture, faith, hard work and deep respect for the land. My parents along with myself and my siblings have spent decades building a place where our entire family can return, feel connected and carry on traditions. The solar farm threatens not just the visual amenity of our land, but the very vision my father dreamed and built for all of us. Dad chose this location for its close proximity to Goulburn and because of its rural and scenic undisturbed nature.
We do not support the government’s approach to Net Zero by 2050 when it comes at the cost and expense of agricultural land, local communities and generational dreams. There is no balance, no foresight and certainly no justice.
We also believe apart from affecting local community but a development of this magnitude will have adverse effects to the local Goulburn airport which is within extremely close proximity to the proposal and suggest that this is taken into consideration. I have experienced instances with solar glare, imagine trying to land an aircraft with solar glare reflecting in the eyes of the pilot.
The proposed development will be clearly visible from our family property – a fact that has never been formally acknowledged in any engagement process which we find completely unacceptable. We expect transparency, consultation and equal treatment – none of which has occurred.
We have also seeked feedback from local real estate agencies who have confirmed such proposal will extremely devalue our property. Financial devaluation is one thing but the emotional connection is another that will never be able to be replaced. It is as if what once was a quiet rural escape is now set to become a backdrop of an industrial-scale energy infrastructure. This is not the life my father worked to build, nor the one our future wishes to inherit.
We ask that the proposed development (SSD 59155459) be rejected on the above noted grounds and ask that the department urgently review its standards for community engagement, especially with CALD (Culturally and Linguistically Diverse) families and intergenerational landholders. This is not just a planning matter. It is a human story of a family who believed in Australia, invested in the land, and now faces the prospect of losing everything to a project we were never consulted on. If this is what the road to Net Zero looks like, it is broken and we don’t appreciate the lack of vision toward solar panels. Developers should consider using the land where they are demobilising coal burning power plants and install their industrial solar panel warehouses in those locations instead, and not ruin our beautiful and natural landscape.
We urge NSW Planning to hear our voice and stand up for residents against this proposal and prevent more mistakes being made.
Sincerely,
Johnny Nasr

I am Objecting to the Merino Solar facility in Goulburn Mulwaree, NSW SSD 59155459

The reasons for my objection are as follows:

There has not been recognition of, or mitigation proposed for the fire risk for the proposed Solar Factory; panels and batteries.

I am concerned about the potential of a battery fire. A battery fire would send toxic fumes all across Goulburn. The toxic fumes from the Moss Landing Battery fire in America in January 2025 sent smoke and toxic fumes over 20 miles, with homes having to be evacuated. People are still suffering severe health issues.

There have been fires at large scale solar facilities in many countries including Australia. Recently, two solar facility fires have occurred in NSW: Jemalong and Wellington. Both fires emitted toxic smoke. The Jemalong fire destroyed infrastructure leaving glass fragments and chemicals on site. The current owner, Genex Power Limited, acquired the facility from Vast Solar LTD in 2018. Vast, and 10 of its subsidiaries entered voluntary administration on November 13th 2025. Vast has made no attempt to clean the site which is littered with glass fragments.

Premier Minns stated that the land owner would be responsible for the clean-up. What is he doing, what will any politician do, to ensure that this is actually done in a timely manner? In this case it has not been started, and the toxic waste is leaching leach into soils and water ways, contaminating water and soils for perhaps decades and across a vast area.

Something different needs to be done. Remember that this company is seeking to make money, nothing more. If the cost of fixing what they have done is too much, they fold. If it is nearing time to decommission, they will fold. And who is going to repair the damage done across this and other sites affected? Taxpayers should not.

Any company who builds such a facility as this Solar Factory must also plan for the remediation of issues that it causes, as well as its eventual end of life decommissioning: cradle to grave. This might involve insurance, as well as a fund that the company contributes to every year for the cost of the decommissioning. This money would transfer to a new owner in the case of a sale. Failure to consider these issues will eventually lead to major environmental damage, just a few years down the track.

Please note that money proposed to go to TGG is not appropriate. TGG do not represent the ideas, nor work for the majority of the community. Perhaps look towards the Landcare Groups which at least have satisfied some guidelines to be part of the Landcare umbrella.

Lynette Merino

I absolutely object to the 450 MW Merino Solar Electricity Generating Works + 450 MW / 1,800 MWh BESS, it’s associated infrastructure & totally unnecessary, sabotaging Grid Connection on the grounds of Failure of Due Diligence, Foreseeability of Toxic Harm, and Reckless Disregard for Public Safety and Intergenerational Equity.

Ag land loss during construction - 985.44 ha and operation - 767.23 ha Zoned Primary Production (RU1)
Land South Of Goulburn Aiport At Tirrannaville And Gundary, Located Between Braidwood Road, Painters Lane And Windellama Road
Applicant: The Trustee for Merino Solar Farm Trust (Developer - EDP Renewables (EDPR) Australia, which acquired the original developer, ITP Development, in December 2023)
Goulburn Mulwaree Council

1. INTRODUCTION
This submission is made in opposition to the approval of the proposed industrial-scale Solar and Battery Energy Storage System development.
It is submitted that the Developer, the Environmental Impact Statement (EIS), the NSW Department of Planning, Housing and Infrastructure (DPHI), and the Independent Planning Commission of NSW (IPCN) have collectively demonstrated a pattern of conduct that amounts to more than mere administrative oversight. The available evidence reveals:
Constructive knowledge of toxic risk
Foreseeable environmental and agricultural harm
Absence of lifecycle toxicological risk research under Australian conditions
Regulatory fragmentation and acknowledged legislative gaps
Reliance on industry assurances rather than enforceable safeguards
This cumulative conduct demonstrates a level of disregard so substantial that it constitutes a conscious violation of the community’s right to safety, environmental protection, and intergenerational equity.
2. OFFICIAL CONFIRMATION OF REGULATORY VACUUM – AUSTRALIAN BORDER FORCE
The following correspondence was received from the Environmental Goods and Product Safety Section within the Australian Border Force (ABF):
OFFICIAL
Dear ………….
Thank you for your feedback (Ref: IMMI-26-00117-1) to the Department of Home Affairs Global Feedback Unit on 3 January 2026 concerning PFAS/PFOS, Bisphenol A and asbestos contained in imported goods by Renewable Energy Companies such as; solar panels, inverters, wind turbine components, electrical wiring and lithium ion batteries – and including the contamination caused by disposal of these products. Your feedback has been forwarded to my section, the Environmental Goods and Product Safety Section within the Australian Border Force (ABF) for a response and advice.
the Department of Climate Change, Energy, the Environment and Water (DCCEEW) is Australia’s lead policy and regulatory agency for the management of hazardous industrial chemicals, which is implemented through the Industrial Chemicals Environmental Management Standard (IChEMS).
IChEMS establishes nationally consistent standards for managing the import, export, manufacture, use and disposal of industrial chemicals to reduce impacts on the environment. While PFAS chemicals, including PFOA, are not yet prohibited at the Australian Border, they are listed in IChEMS as a high risk chemical group, and are regulated domestically within Australia.
Bisphenol A is also listed in IChEMS and is being considered for scheduling by DCCEEW but is not a prohibited chemical at the Australian Border.
We have received the below advice from DCCEEW on the PFAS regulations for your consideration:
● The Australian Government expects that introducers, exporters and users of PFAS comply with the standards set out in IChEMS.
● Regulation, or enforcement, of standards is reliant on adoption by the Commonwealth, states and territories into their own environmental laws.
● Jurisdictions are at various stages of incorporating the IChEMS into their own regulatory frameworks.
● The Commonwealth is exploring its legislative options for enforcing the prohibitions and restrictions on importation and manufacture and use in Commonwealth areas as prescribed in the standards. The Commonwealth will work with introducers and users as it develops implementing legislation and considers the practicality and appropriateness of different operating models.
● Until new legislation is available there is a unique opportunity for industry to establish compliant supply arrangements and business practices without penalties applying.
For further information on what the Australian Government is doing in relation to managing and restricting the use, import, manufacture and disposal of PFAS containing products, please visit the DCCEEW website at Per- and poly-fluoroalkyl substances (PFASs) - DCCEEW. You may also wish to contact DCCEEW by email at [email protected]
In regard to your concerns for asbestos, the ABF is responsible for enforcing border controls for very high volumes of goods that cross the Australian Border every day, and every effort is made to identify and prevent goods containing asbestos from entering Australia.
● Australia is one of the few countries in the Asia-Pacific region that has a comprehensive ban on all six types of asbestos.
● In many countries, despite the known threat to human health, local standards allow manufacturers to use low levels of types of asbestos.
● Goods manufactured outside Australia might be labelled asbestos free and still contain low levels of asbestos.
● It is the responsibility of importers and exporters to ensure they do not import or export prohibited goods such as asbestos. The ABF must be assured that asbestos containing goods are not unlawfully crossing the border.
Regarding your concerns for unregulated and no accreditation body to determine the toxic public health and safety risks of renewable infrastructure and the contamination to the environment by the disposal of such renewable energy products, please also visit the DCCEEW website at the following links, for further information on how the Australian Government is managing these issues.
Home - DCCEEW
Renewable energy developments and environmental protection - DCCEEW
Exporting, importing or transiting hazardous waste - DCCEEW
Thank you for your feedback.
Joshua
Position number: 49000643
OFFICIAL

3. FORMAL ASSESSMENT OF THE ABF RESPONSE
The following assessment was prepared in response to the above letter:

letter:
“What it confirms clearly
• There is no effective border-level prohibition on PFAS/PFOA or Bisphenol A in renewable energy components.
• The system relies on voluntary industry compliance and future legislation, not enforceable controls.
• Responsibility is fragmented and deflected between agencies (ABF → DCCEEW → states/territories).
• Importers are effectively given a regulatory grace period to “establish compliant practices” without penalties.
That last point is the most damning.
What the letter unintentionally admits
• Australia is knowingly allowing high-risk chemicals into the country while acknowledging their environmental and health risks.
• Enforcement is aspirational, not operational.
• The Commonwealth currently lacks the legal tools it claims are necessary, yet continues to permit imports.
• Renewable energy infrastructure is being treated as a regulatory exception zone.
This is classic regulatory capture by delay:
“We agree it’s dangerous, but we’ll act later.”
Structural failure exposed
• No independent accreditation body for toxicological risk of renewable infrastructure.
• No lifecycle regulation (import → use → disposal).
• No precautionary principle applied, despite PFAS being globally recognised as persistent, bioaccumulative toxins.
• No mandatory disclosure requirements for chemical composition of components.
In plain terms:
The system is built to facilitate rollout first, and manage harm later, if ever.
Strategic value of this document
This is actually a strong piece of evidence for future use because:
• It documents official knowledge of risk.
• It establishes foreseeability of harm.
• It shows government awareness without enforcement.
• It weakens any future claim of “unanticipated consequences.”
That makes it useful for:
• submissions,
• complaints,
• Senate inquiries,
• judicial review groundwork,
• and cumulative impact arguments.
Bottom line
The letter is polite, procedural, and calm — but substantively it is an admission of regulatory failure.
Not incompetence.
Not ignorance.
Choice.”

4. FORESEEABILITY OF TOXIC CONTAMINATION – PROFESSOR IVAN KENNEDY
Emeritus Professor Ivan Kennedy, in his submission to the IPCN (Tallawang Solar Electricity Generating + BESS, SSD-23700028), identified two central failures of due diligence:
I. The Environmental Toxicity of the Solar Panels Employed
II. The Futility of Renewable Electrical Energy as an Effective Solution to Climate Warming
Of direct relevance to this proposal is his quantified assessment of heavy metal content:
Approximately 20–30 tonnes of metallic silver in a 500 MW installation
Additional heavy metals including lead, cadmium, tin, copper
Toxicity thresholds in soils as low as 0.1–10 mg/kg
Even 1% lifetime leaching potentially sufficient to sterilise agricultural soils
He further warned:
“The current failure to conduct risk research under Australian environmental conditions for solar farms may lead in future to legal class action claims for damages to farmlands and the environment.”
This is not speculative rhetoric. It is a professional warning grounded in toxicology, soil chemistry, meteorology, and agricultural risk science.


5. THE “GROUND TO A FINE DUST” MISINFORMATION
In prior IPC reasoning, reliance has been placed on guidance asserting that:
“To readily release contaminants into the environment, solar panels would need to be ground to a fine dust.”
This statement is demonstrably incomplete.
It fails to consider:
Hailstorms exceeding 25 mm, increasingly projected under warming conditions
Documented destruction of operational solar farms by hail events
Thermal cycling, UV degradation, acid rainfall
Fragmentation of bifacial panels with thi

Please see attachments

We vehemently object to the obnoxious 450 MW Merino Solar Electricity Generating Works + 450 MW / 1,800 MWh BESS, its associated infrastructure & useless, unwanted Grid Connecting enabler - SSD-59155459

The Environmental Impact Statement for the Merino Solar Electricity Generating Works is not a rigorous, precautionary assessment.
It is a narrative exercise in impact minimisation, economic spin and regulatory box-ticking.

The Social Impact Assessment and Agricultural Impact Assessment are framed as objective evaluations.
In reality, they repeatedly downplay permanent land-use change, deceptively minimise toxic and fire risk exposure, rely on unrealistic assumptions about “solar grazing,” and dismiss cumulative agricultural and social consequences as negligible by statistical dilution across the broader LGA.

This submission rejects the credibility of the NGH/Aspire assessments on the following grounds:

1. The “Minimal Regional Impact” Claim Is Statistically Manipulative
The AIA concludes that removing 985.44 ha during construction and 767.23 ha during operation represents only 0.74% and 0.58% of agricultural land in the LGA, therefore regional impacts are minimal.
This is a mathematical dilution tactic.
It ignores:
• The concentration of impact in a specific productive RU1 locality rather than across the entire LGA
• The industrialisation of a continuous agricultural landholding for decades with no guaranteed removal of the contaminating infrastructure and a toxic legacy that eliminates agricultural productivity forever.
• The precedent effect of approving multiple projects in the same district

Regional food production resilience is not protected by averaging losses across large geographic areas.
The Paris Agreement explicitly requires climate responses that do not threaten food production.
This project directly converts primary production land into an industrial energy estate with devastating toxic impacts for surrounding land, water, biodiversity and the public.

2. RU1 Primary Production Land Is Being Permanently Industrialised
The project footprint of 767.60 ha for operations is not a temporary disturbance. It involves:
• 870,000 photovoltaic modules
• 450 MW / 1,800 MWh lithium-ion BESS
• 32 ha substation and battery compound
• High-voltage transformers
• Security fencing and internal access tracks
Registering long-term leases on land titles fundamentally changes the planning character of the land.
The claim that land will simply “return to its existing land capability” after decommissioning is speculative and unsupported by empirical evidence from comparable large-scale removals.
No independent, risk research and long-term soil restoration has been presented.

3. “Solar Grazing” Is Being Used as a Mitigation Myth
The AIA suggests that net agricultural income may increase by $1.78 million over 33 years if grazing continues under panels.
This conclusion depends on:
• Experimental delusions about agrivoltaic performance
• No contamination events - by using PFOS Free Solar panels that contain no toxic heavy-metals - which don’t exist.
• No soil compaction legacy
• No elevated toxicity levels for livestock in order to comply with LPA Food Safety on your property Question 2.8.

There is no independent evidence demonstrating that sheep grazing under 870,000 modules won’t be contaminated, that entombment for 30 years maintains equivalent soil structure, pasture productivity, nutrient cycling or biosecurity standards.
The economic model assumes non-sensical coexistence while ignoring operational constraints, fire setbacks, access limitations, electrical hazard exclusion zones and toxic impacts.

4. Financial Compensation Is Not Agricultural Sustainability
The AIA states that landholder losses are offset by access fees from the Applicant.
Payment is not mitigation.
Replacing agricultural production with rent from poisonous infrastructure does not preserve:
• Regional food output
• Supply chain continuity
• Agricultural employment
• Soil health
• Biosecurity integrity
•Uncontaminated land/water status
This converts farming enterprises into electrical infrastructure hosts and toxic wasteland
It does not maintain agricultural capability and neglects to monumental costs of liability when surrounding land and water is contaminated by the Host’s toxic contaminating RenewaBULL Solar/BESS infrastructure.

5. Off-Farm Economic Losses Are Acknowledged but Downplayed
The AIA quantifies up to $11.91 million in reduced farm expenditure over 33 years without grazing.
This reduction impacts:
• Transport operators
• Feed suppliers
• Veterinarians
• Agricultural contractors
• Local processing industries
The report then speculates that solar-related expenditure may offset this loss, without quantifying long-term local retention of that expenditure and excluding exponential Toxic Contamination costs.
Solar/BESS Construction labour is temporary. Agricultural supply chains are permanent.

6. The Social Impact Assessment Minimises Community Harm
The SIA acknowledges:
• Community division
• Housing pressure
• Stress and anxiety
• Perceptions of unfairness
• Consultation fatigue
These are not minor psychosocial inconveniences. They are indicators of social fracture.
Describing these impacts as manageable through “communication strategies” trivialises lived impacts.
Once community trust erodes, it cannot be repaired through engagement frameworks.

7. Drafting Errors Undermine Credibility
The SIA includes the phrase:
“The Proposal location is illustrated below in Error! Reference source not found.”
This is a State Significant Development EIS.
If document integrity fails at basic referencing level, confidence in technical rigour across contamination, fire modelling, and cumulative assessment is severely undermined.

8. Biosecurity Risks Are Underestimated
The AIA identifies weed and pest introduction as the highest biosecurity risk, yet classifies risks as low to moderate after mitigation.
This assumes perfect compliance across:
• Hundreds of construction vehicles
• Soil disturbance across 985 ha
• Long-term maintenance access
The region contains sodic and dispersive soils vulnerable to erosion.
Weed establishment in disturbed solar environments is well documented in comparable developments.
Once established, invasive species will persist for decades.

9. Fire Risk Is Systemically Understated
The project includes:
• 1,800 MWh lithium-ion battery storage
• High voltage transformers
• Extensive cabling
• Large asset protection zones
The AIA describes fire risk as “relatively small with mitigation measures.”
International evidence demonstrates that grid-scale battery fires release lethal hydrogen fluoride gas and heavy metal particulates.
Fire and Rescue NSW has acknowledged gaps in guidance for emerging technologies.
No transparent worst-case plume modelling has been publicly validated for surrounding rural residences.

10. Decommissioning Is Deferred and Unfunded in Detail
The Rehabilitation and Decommissioning Plan is proposed to be prepared within five years of closure.
This is not precaution.
It ignores irreversible risks and defers accountability for:
• 870,000 panel disposal pathways
• Lithium battery recycling viability
• Heavy metal waste streams
• PFAS-containing components
• Soil contamination remediation
No binding financial security is presented demonstrating guaranteed full site remediation irrespective of corporate solvency at end of life.

11. PFAS and Toxic Chemical Risk Is Omitted from Agricultural Analysis
The AIA does not meaningfully address:
• Banned PFAS/PFOS presence in modules and components
• Heavy metal leaching from damaged panels
• Fluorinated compounds in wiring and batteries
• Long-term soil accumulation
Recent updates to Australian drinking water guidelines significantly lowered acceptable PFAS levels.
Border authorities have confirmed PFAS chemicals are irresponsibly not yet prohibited at import.
Enforcement remains fragmented across jurisdictions.
Approving long-term agricultural coexistence without independent toxicological soil/water risk research contradicts the precautionary principle.

12. Cumulative Impacts Are Artificially Segmented
The assessment treats Gundary/Merino Solar impacts as visually sequential rather than simultaneous.
This segmentation ignores:
• Housing pressure overlap
• Fire risk stacking
• Traffic congestion during concurrent construction
• Compounded agricultural land conversion
Cumulative industrialisation of the Southern Tablelands is not negligible when assessed realistically rather than geographically diluted.

13. Economic Claims Are Inflated and Internally Inconsistent
The SIA alternates between 200–300 jobs and 500 FTE during construction.
Operational employment is minimal.
The capital investment figure stated appears low relative to project scale, raising questions about reporting consistency.
Short-term construction employment does not justify permanent agricultural land conversion.

14. The ESD Principles Are Not Satisfied
Precautionary principle is not met due to absence of independent contamination risk research.
Intergenerational equity is compromised by entrenching long-lived industrial infrastructure on food-producing land.
Conservation of biological diversity is threatened by habitat fragmentation and potential contamination.
Improved valuation and pricing mechanisms are absent, with externalities inadequately internalised.

15. The NEL Objective Is Not Clearly Served
The National Electricity Law objective prioritises efficient investment in reliable electricity supply in the long-term interests of consumers.
Solar generation is intermittent.
Battery storage is finite.
Grid-strength remediation costs are obscene.
The EIS does not demonstrate at all that this development materially improves reliability relative to system-wide cost burdens because that’s impossible with the RenewaBULL SWINDLE.

Conclusion
The NGH Social and Agricultural Impact Assessment

Reputable Research proves that damaged Solar modules leach toxic elements over time.
Fractures increase exposure pathways.
Degrading and intact panels also leach toxins.
Lithium-ion BESS leak dangerous chemicals and often burn causing lethal fumes and highly toxic residue.

Detailed hydrogeological transport research facts have not been transparently provided in this EIS.

The toxic risks to our life sustaining, productive Agricultural land. essential water systems, biodiversity and the public are far too great to ever consider approving this toxic contaminating Merino Solar and BESS disaster.

Besides all the Toxic Contaminating Solar Panels and highly hazardous BESS, the galvanised steel supports will corrode over time with Zinc and associated metals mobilising into soils.

Unconscionably and unacceptably NO independent, reputable, long-term cumulative soil chemistry research or essential water testing results have ever been presented demonstrating negligible impacts to Agriculture and Public Health and Safety during the operational life and the likely abandonment of Merino Solar or any other previously Approved Solar/Wind/BESS Swindle Factory.

The behaviour of the DPIE/DPHI and IPCN has been totally unjust and obscene.