Objection details withheld due to sensitive information.

I deeply believe in the need for a rapid energy transition to end our dependence on fossil fuels and mitigate the escalating impacts of climate change. I equally believe that everyone must be empowered by this transition as much as possible, which can only be achieved through meaningful community consultation and risk assessment. This is especially the case for the Sundown Solar Farm project, which will adversely affect local residents if the current plan goes ahead. This includes impacts on human health and safety, as well as significant noise, dust pollution, and loss of amenity.
I believe development sites for renewable energy farms and transmission lines should occur on agricultural land as it is already cleared and does not impede on biodiversity. However, just as it is important to balance energy and biodiversity values, it is important to assess the likely human and social costs of this project, and provide compensation where it is due. Further, changing the "Western Road" to be the alternative means of access would mitigate the most severe of the impacts as there are no Swan Vale residents on this road. It would also provide a shorter access route from the Sundown project to the Gwydir Highway. I truly believe that by listening to the voices of local residents, a solution can be reached that supports energy development, as well as the local community and agricultural practices that makes this region so valuable to NSW and Australia.

From the information I have gathered this project should not go ahead because the developers and the Inverell Council have ignored requests from Mrs Frazier and her family to use a different route for supplies and staff to access and deliver infrastructure.
There is an alternate route which is well away from Mrs Frazier's home and gardens where there are few houses and where the dust caused by all the traffic would not effect residents health.
Mrs. Frazier is an elderly lady living on her own and is a long term resident. Others in her district have confirmed the road chosen by the developers and the council would be very obtrusive of her home, gardens and lifestyle.
There have been other solar plants established in New England where the developers have altered the site plans of their projects, built alternate routes, bitumened the road surface and taken care of their new neighbours.
One of the simple solutions in this case is for the developers be told to build a new turnoff from the Gwydir Highway so that their trucks and staff use the alternate route well away from Mrs Frazier's house and gardens. This turnoff should be constructed to government specifications and paid for by the developers before they are allowed to start work.
Yours sincerely,
Richard Croft,
Executive Councillor,
NSW Farmers Association Region 2 (New England)

Objection to Application No.SSD-8911 by Sundown Solar Pty Ltd
To whom it may concern,
As a rural landowner, I am writing to object to this proposed development for a number of reasons.
- I am concerned about the environmental impact that increased traffic will cause to the local wildlife and ecosystems.
- This project may also cause water contamination and use vital water supply in an already draught affected area.
- Reports also indicate that there will be a 960% increase in daily traffic in the area, which will prevent landowners from being able to manage and transport their livestock in neighboring farms. In particular, this project will detrimentally affect traffic via Spring Mountain Road and Sturmans Road.
- This project will greatly affect the health of livestock and in turn will financially impact local businesses.
- There has been a lack of community consultation at a grassroots level to determine the impacts on local farmers and residents.
For these reasons, I would like the project halted until there has been further consultation with the affected communites.

SSD-8911
I object in the strongest possible terms to the proposed development and construction by
Sundown Solar Pty Ltd (the “applicant”), application No. SSD-8911 (the “proposed
development”). In particular, we object to the proposed access via Spring Mountain Road and
Sturmans Road to the proposed development.
Dust
Another safety implication is the dust which would be generated from the use of Spring
Mountain Road and Sturmans Road from such frequent heavy traffic so close to our homes
and primary production businesses. Paragraph 6.11.4 of the EIS at page 225 refers to “
reduced rural amenity” due to dust and asserts that “dust generation will be mitigated
using standard construction techniques such as the use of water carts and screens”. It is
not just a matter of loss of amenity, serious though that is. Increased levels of dust due to
the heavy traffic on Spring Mountain Road and Sturmans Road will be dangerous to the
health of residents, stock and farm animals. The use of water carts and screens will plainly
not eliminate the adverse health effects of dust on these public roads.
Appendix J to the EIS at paragraph ES3 states that during the construction phase of 21
months, it has been estimated that 75 megalitres of water is required, principally for water
carts to reduce dust. This seems a relatively small amount of water to ameliorate the
effects of dust over the two proposed access roads for such a long period. The distance
from the intersection of the Gwydir Highway to the closest access to the proposed
development on Sturmans Road is 10.23 kilometres (Appendix I Traffic Impact Study). So
far as we can tell, nowhere in the EIS is the basis for the calculation of 75 megalitres
provided.
The EIS does not appear to address at all the adverse health impacts to people and stock
due to dust and certainly has not attempted to measure these risks. For example, in
relation to stock, it is well known that stress and dust cause Bovine respiratory disease
(https://www.mla.com.au/research-and-development/animal-health-welfare-andbiosecurity/diseases/infectious/bovine-respiratory-disease). However, there is not a word
addressing this critical issue in the EIS.
In short, the use of Spring Mountain Road and Sturmans Road as access roads to the
proposed development is wholly unsuitable and approving the proposed development
access would endanger the lives and well-being of residents and their stock and farm
animals.
Noise and Vibration
Noise
The area of Spring Mountain is an extremely quiet rural environment. To use the language
of the Noise Policy for Industry 2017, the properties are in an area with an acoustical
environment that is dominated by natural sounds, having little or no traffic noise and
generally characterised by low background noise levels.
Table 6.26 at pages 162-163 of the EIS assesses the noise impact of the construction phase
of the proposed development at 21 sites, including “Menari’ at R15 and “ Warrawee” at R14
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which are the worst affected by construction noise of all the sites. Predicted construction
noise levels for “ Menari” are 66dB in Stage 1 of construction and 67 dB in Stage 2 of
construction. These levels do not comply with Noise Management Levels set by the Interim
Construction Noise Guideline. These breaches of the Guideline are said to be due to the
upgrade of the access roads for heavy trucks and machinery.
Using assumptions including that the existing traffic movements on Spring Mountain
Road and Sturmans Road are “less than 50” movements per day (it is in fact currently only
about 10 movements) and that projected traffic would travel along these roads at the
speed limit of 100 kilometres per hour, the EIS at Appendix H predicts traffic noise due to
construction to increase from 39 dB at present to 50 dB on Spring Mountain Road and
from 20 dB at present to 30 dB on Sturmans Road. These are significant increases but it is
unclear to us what the true quantitative impact would be if more realistic assumptions
were used.
Table 7.3 of Appendix H to the EIS states that “Menari” and “Warrawee” will suffer “highly
intrusive noise”.
Vibration
“Menari” homestead (R15) and “Warrawee” homestead ( R14) are the worst affected sites
assessed in the EIS for adverse impacts from vibration. At paragraph 6.6.3 on page 164, the
EIS states that vibration levels at “Menari” (R15) and “Warrawee” ( R14) during Stage 1 of
construction “may exceed the levels for human comfort if the
The area is zoned for primary production. The following properties are directly adversely
impacted by the proposed development and the proposed use of Spring Mountain Road and
Sturmans Road:
- “Menari” 489 Spring Mountain Road, Spring Mountain
- “Numeralla” 1071 Spring Mountain Road, Spring Mountain
- “Kokoda” 934 Spring Mountain Road, Spring Mountain
- “Warrawee” 155 Spring Mountain Road, Spring Mountain
- “Lockmore” 170 Northcotts Rd, Spring Mountain
To take “Menari” as an example of a property particularly adversely affected, it is the dwelling
described as R15 on various maps in the Environmental Impact Statement (“EIS”) for the
proposed development. “Menari” borders and is immediately adjacent to the project area for
the proposed development. The site of the proposed development is, at its closest point,
approximately 2 kilometres from the “Menari” homestead. The “Menari” homestead is
approximately 45 metres from Spring Mountain Road and its vegetable garden is
approximately 4 metres from Spring Mountain Road at its closest point. “Menari” is intersected
by both Spring Mountain Road and Sturmans Road, the proposed public roads to be used for
access to the proposed development.
Spring Mountain Road and Sturmans Road are currently 4-metre-wide unsealed roads. They
are both no through roads. On average approximately 10 vehicles (primarily local residents)
drive on these roads daily. Spring Mountain Road and Sturmans Road are our only access
point to travel to and from Inverell and Glen Innes. Spring Mountain Road is also used to
connect with school buses and the Black and White bus that make daily deliveries to enable
us to carry out our daily business operations. Critically, it is the only access road for residents to
reach medical services.
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Similarly, both Spring Mountain Road and Sturmans Road are used by pedestrians and are
critical in the movement of stock between paddocks, stockyards and the loading ramp that is
divided by the existing road network. Farm dogs are used to muster stock along both roads.
In summary, we object to the application on the following grounds:
• Health and Safety
• Noise and Vibration
• Loss of amenity
• Adverse business impacts and financial loss
• Use of public access roads
Health and Safety
Traffic
The EIS refers to a proposal by the applicant to widen Spring Mountain Road and Sturmans
Road to a width of 8.76 metres and for the roads to be compacted and gravelled. In Appendix
I to the EIS , Traffic Impact Statement, Table 3.6 states the Austroads design for rural roads 150-
500 design standard is minimum 7.2m wide seal.
At paragraph 3.4.1 the EIS states that the purpose of widening these roads is to accommodate
26-metre B-double trucks. Table 6.37 at page 182 of the EIS states that the daily baseline and
development traffic volume is expected to be 478 vehicles per day on Spring Mountain Road.
The construction phase, during which there will be the heaviest traffic volumes, is expected to
last for 21 months: see paragraph 6.6.3 of the EIS.
As well as the frequent movement of heavy trucks there would also be heavy traffic due to
construction and operating workers travelling to and from the proposed development.
According to paragraph ES.5.6 of the EIS, construction works are scheduled to occur from 7
am to 6 pm Monday to Friday and from 8 am to 6 pm on Saturday. There would be a peak
construction workforce of about 400 people (Appendix H, paragraph 2.1.1). Peak project
construction workforce traffic is predicted to consist of 14 shuttle buses and 100 light
vehicles each day (Appendix I, table 5.1). If workers are required to start work at 7 am and
finish at 6 pm it can be expected that this traffic will commence on the local road network
from about 6:30 am and will continue until about 6:30 pm each day. This extends the true
period of traffic movement by about 1 hour each day beyond the assumptions in the EIS.
Other assumptions used in the EIS (e.g., in Appendix H, Noise and Vibration Impact
Assessment) include that vehicular traffic associated with the proposed development will
travel along Spring Mountain Road and Sturmans Road at the default speed limit of 100 kmh.
This huge volume of heavy vehicle traffic travelling at high speeds and carrying hazardous
materials greatly increases the risk of accidents and will expose the local residents and our
employees to dangers having an impact on the safety of motorists, pedestrians and graziers
mustering stock along these roads. Local residents, including the elderly and school children,
have no option but to use Spring Mountain Road and Sturmans Road to purchase supplies,
attend school and access services from Inverell and Glen Innes.
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We are concerned about the risks to the health from the stress of living and working so close
to these extreme traffic movements along the proposed access roads.
Despite these obvious safety and health risks and the profound adverse impact on local
residents from this increased traffic, the EIS contains no risk assessment of the impact of this
increased traffic on Spring Mountain Road and Sturmans Road. Appendix I ( Traffic Impact
Assessment ) paragraph 4.1 and Table 4.1 asserts that this risk assessment is contained in
paragraph 6.4 of Appendix I. However paragraph 6.4 does not address the risks of using these
access roads at all but states that the use of these roads is “acceptable to Council as a
temporary construction stage road”

As a Primary Producer and resident on Spring Mountain Road and part of the Swan Vale community, I strongly oppose to the proposed construction and development of a 360 MW Solar Farm and 150 MW Battery Energy Storage System at Spring Mountain.
After having no consultation in relation to the alleged proposal from Sundown Solar Farm or Inverell Council, I am now only becoming aware of not only the direct impact it will cause to myself and my family as residents on Spring Mountain Road, but as close neighbours to the proposed site.
The project has proposed Spring Mountain Road as the access road to the Solar Farm site. Spring Mountain Road is a no through road thus making it the only road residents can use to access the Gwydir Highway. This promotes major concern as it has been proposed that this quiet country road will have an increase during construction phase of 960% in traffic DAILY ! Spring Mountain Rd is used by landholders to muster and transport stock and just everyday access to neighbouring towns for food, medical services etc. That increase in traffic will not only cause major impacts to residents who have homesteads right on the road but every resident who uses it . I myself have already nearly had two head on crashes with other vehicles travelling too fast on the wrong side of the road. With that increase in traffic and with stock using that road regularly, I can foresee and accident waiting to happen should they use Spring Mountain Road.
An alternative shorter, more direct route was also proposed however, Inverell Council and Sundown Solar Farm did not see it as a 'feasible' road to use due to the impact it would have on vegetation and cost. I find these two reasons in comparison to the adverse impacts it will have on the residents of Spring Mountain Rd that I have stated above, very unreasonable, almost absurd. In relation to this the Solar Farm's proposed storage of 150 MW batteries on site, there is potentially a very high risk of fires occurring. If this were to happen, which I believe is highly likely as have heard reports of it happening regularly at other solar farms due to increase in temperatures etc, the RFS would need the quickest, most direct access to the site. Upon talking to the RFS in the Swan Vale area who would be directly responsible for fighting the fires, it was discovered upon looking at the two access roads proposed, that Spring Mountain Road would not be the RFS' road of choice as it would be 13 km longer than the alternative access road. Thus, if an emergency were to occur, valuable time would be wasted. Therefore, in the case of the risk of fires , I believe Inverell council's proposal to use Spring Mountain Road as the access road highly negligible on all accounts.
With all these points considered I am strongly opposed to the proposed construction of Sundown Solar Farm and the use of Spring Mountain Road as the access road should it go ahead.

This Project will be Redundant

Decommissioning: It is perfectly understandable that the Community remains very nervous as to who will decommission, what will be decommissioned and when. The issues have been given very poor policy consideration by the Government and the developers.

Roads and Traffic: The operational and decommissioning traffic will be significantly less than peak construction traffic across Spring Mth Rd and Sturmans Rd. Traffic impacts have not been assessed in detail. Assessments detail the impacts along the Gwydir Hwy and the access to, but no mention of Spring Mth Rd and Sturmans Rd.

Socio-Economic: Existing shortages of a skilled workforce from local towns moving to solar project and other renewable projects, leaves locals without a key workforce to attend to their day to day operations, including 400 people required on site during construction. Project times can ‘blow out’ and there is no guarantee that construction will cease in 21 months.

I object to application No SSD-8911 by Sundown Solar Pty Ltd which is classed as a State Significant Project.
This planned Solar farm, in the area of Swan Vale will impact that community and surrounding communities for the next 35 years and for years after.
The increased traffic alone will cause a significant impact on the local communities with over 400 heavy vehicles proposed to be travelling on the network of roads, including Spring Mountain Road and Sturmans Road to the site. These Rural roads are not designed to take this volume of traffic, and the residents who will still need to use these roads to travel to and from their properties, towns and other local communities will be disadvantaged by the massive increase of traffic. The negative impact of traffic not only includes meeting a stream of heavy vehicles on narrower roads but also the increased noise and ground vibrations that go with heavy vehicles.
The loss of the quality of life presently enjoyed by those who live in the Swan Vale community is irreplaceable. Land for primary production is extremely valuable not only to the farmers and landholders but to the Australian population who rely on the production of food resources from this land.
Has there been a study which takes into account the sheer volume of prime agriculture land that has been swallowed up, in not only solar farms but also wind farms, and the combined impact that has on the landscape by the loss of tree cover and therefore loss of biodiversity.
Farm land resources are precious, and should not be abandoned to the developers without the full impacts of the development, both short and long term, being made known to those closely affected and to the general public. This development in the Swan Vale area will create a major negative impact for many others including the possible contamination of the land and water resources in the vicinity of the planned farm. The problem in the future of disposing of the infrastructure required for the farm, including but not limited to the panels, posts and wiring has not been solved. Is that something we are willing to just leave to the future generations.
This proposal needs to be re-evaluated taking into account all stakeholders and not a minority.