I wish to object to the Sundown Solar project primarily because of the adverse impact on local residents.
Traffic safety will be heavily impacted by a 960% increase in traffic on the unsealed Spring Mountains Road and Sturmans Road. Local farms will not be able to safely move their livestock from paddock to paddock as a result. Visitors’ and residents’ access to properties in the area will be unsafe as they negotiate the narrow unsealed roads and huge increase in the large commercial vehicles using them. In addition the noise levels will be of an unacceptable level with the increasing traffic.
The loss of Spring Mountain Road and Sturmans Road as access roads for local properties will destroy their quality of life and make ongoing business unviable.

Another risk to consider is the project’s need for water. Sundown Solar proposes that 75 mega litres of their water requirements will be sourced from Kings Creek, which feeds into the Macintyre River. The risk of chemical spills could potentially create a water quality disaster for this major water source to the Inverell area. Sundown Solar also proposes using harvestable rights to take water from adjacent landowner dams which will adversely impact those landowners and their agricultural needs, especially with difficult drought predictions in the next seasons.

I wish for my objections to the Sundown Solar project and, in particular, its use of Spring Mountains Road and Sturmans Road, to be given full consideration.

Sundown Solar Farm
SSD-8911
Sturmans Rd Spring mountain.
I am pleased to support this project, it has the potential in the short term to create infrastructure that the local community could benefit by, for example, improved public road infrastructure. A broader community benefit would be that there is local employment opportunity and growth involving trades outside the normal agricultural frameworks which will be created that otherwise would not exist in the area. As a local resident I believe there is a potential positive flow on effect to the broader local community with these large infrastructure projects that are effectively managed in all the developmental phases. The project is a step in providing a renewable energy solution for future generations.

This project will have dire consequences for the Swan Vale residents and farming enterprises. I am an advocate for supporting Australian owned businesses and the farming enterprises in this area make a significant contribution to our food supply. The construction of this project will negatively impact farming practises and the health and welfare of the residents.
Traffic, noise and dust will certainly affect residents and livestock but the major concern will be the escalated risk of fire.
Sundown Solar is not Australian owned and that also rings alarm bells. Why should Australian farmers and residents be impacted by a foreign company's investment? Health and Safety is paramount and as this project represents a huge fire risk, why should it even be considered?
Renewable energy has its place when the environment is right.
This project is not ticking the right boxes.

Restricted Consultation: The Swan Vale community has only now become aware of the submission stage of this project. How clearly were the impacts communicated prior to holding community forums with the local Swan Vale Community so they would feel invested to find out more? Sundown Solar has an obligation to bring the community in on the details. Reviewing hundreds of documents before the community can assess the potential impacts on them during the submission period is overwhelming. Stakeholders benefiting from the project were approached for in depth interviews. They raised noise and dust from project construction traffic as a potential issue only for some residents closer to the project site. They didn’t believe the impacts would result in significant impacts to the lifestyle of local residents; most of whom have not been directly approached for comment. This is a conflict of interest.

Business and Lifestyle Impacts of Road Widening: 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. This is a breach of the Austroads design standard for rural roads. Appendix I to the EIS (Traffic Impact Statement) Table 3.6 states that the Austroads design standard for traffic of 150-500 vehicles is a 7.2 metre wide sealed road. Spring Mountain Road and Sturmans Road are currently 4 metre wide unsealed roads. Both roads are critical to the movement of stock for impacted neighbouring properties.

Extended Traffic Times. According to paragraph ES.5.6 of the EIS , construction works are scheduled to occur from 7 am to 6pm Monday to Friday and from 8 am to 6pm on Saturday. There would be a peak construction workforce of about 400 people (Appendix H, paragraph 2.1.1). If workers are required to start work at 7 am and finish at 6 pm it can be expected that this traffic will commence past affected homes 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.

Unsafe default speed limit.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 to motorists, pedestrians and graziers mustering stock along these roads. Local residents, some elderly, have no option but to use Spring Mountain Road and Sturmans Road to purchase supplies and access services from Inverell and Glen Innes.

The EIS contains no risk assessment of the impact of this increased traffic on Spring Mountain Road and Sturmans Road. Widening the road to 8.7m from the current 4.0m is a safety issue for residents and livestock. A safe shoulder to access residential properties and adjacent gates for stock access is impacted by widening where there is no safe egress. Existing fences are stock proof for the low volume of traffic (approximately 10 movements per day), but will not be for the proposed volume of heavy traffic that will impact livestock. Some stakeholders raised the concern that livestock is often transferred between lots which would be impacted by high volumes of construction vehicles, further expressing a need to upgrade fences along the site access roads. Safe crossing points for livestock and landholders to cross the widened road are safety concerns. What compensation is there for the landholder when livestock are injured or killed by the impact of heavy machinery? Sundown Solar has entered into lease agreement with 3 associated landowners, but not with non-associated landowners who were assessed as not significant enough to warrant such an agreement. This is despite impacts on these landowners' ability to conduct their businesses as usual including moving stock and equipment on their properties with high levels of noise and dust generated for long hours past their places of residence. Sundown Solar states that properties adjacent to the project area will be able to continue their agricultural activities unimpeded, during all phases of the project (noting that the issue of allowing stock to safely cross roads during construction will be addressed). The sides of the road are used to convey stock between paddocks for optimum movement. How can this occur when widening the roads eliminates this movement.

Health Risk Impacts: 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 close to homes. 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 residents health and the health of livestock.

Noise and Vibration Impacts on Sensitive Receptors 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. Predicted construction noise levels of 66dB in Stage 1 of construction and 67 dB in Stage 2 of construction affecting sensitive receptors does 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. At paragraph 6.6.3 on page 164 , the EIS states that vibration levels at sensitive receptors homes (R15) and ( R14) during Stage 1 of construction “ may exceed the levels for human comfort if the size of the vibrator roller used to construct the access road is greater than six tonnes”. Appendix H to the EIS ( Noise and Vibration Impact Assessment) at Table 5.2 on pages 26 identifies that 5 vibratory rollers over 18 tonnes will be used during Stage 1 and Stage 2 of construction (a predicted period of 17 months). This creates a level of vibration during construction that will be intolerable for these residents. The mitigation measures suggested in paragraph 7.3 of Appendix H notification, verification (i.e. measurement) and respite offers are cosmetic and will not eliminate the adverse impacts of vibration if the current access roads for the proposed development are approved.

Loss of Amenity: It is obvious that the proposed development would fundamentally adversely affect the lives of neighbouring residents to the project. Instead of quiet country laneways (which are not through roads) intersecting properties, during the construction phase Spring Mountain Road and Sturmans Road would be used by many hundreds of vehicles per day, including hundreds of daily movements of 26 metre B-double trucks. That’s a 960% increase from very early in the morning until evening six days a week.

Hazard Impacts: Appendix K to the EIS (Preliminary Hazard Analysis) contains a completely superficial analysis of the consequences of fire from the proposed development to neighbouring properties. Table 5.4 identifies fire hazards due to electrical conversion systems, the battery energy storage system, substation fire and bushfire but in each case in relation to the consequences of fire makes the facile statement that “ as there is a large separation distance … to the nearest non-project related residential dwelling, the effects are not expected to have an off-site impact”. The likelihood of a fire having a devastating consequence for people, and livestock, is entirely foreseeable yet has been completely dismissed in the EIS. Rural fire services are aware that fires on or near large-scale solar energy facilities present tactical challenges, while these are similar to those seen with existing transmission infrastructure, state and national fire organisations are developing research programs, guidance material and operational procedures to identify and manage local conditions and site-specific risks.”

I object on the following points:
- dust impacting on local animals and humans
- traffic (400 workers during construction phase on our dirt road)
- on prime agricultural land
- visual impact on neighbours
- mental health impact on neighbours who get all the problems & none of the financial benefit
- decreased land values & reduction of rural amenity

Looking to support the project with solutions tailored specifically to Sundown Solar Farm

Solar farms being built in this country are desecrating the environment and turning productive land into wasteland with a very large waste disposal problem. It is seen as a get rich scheme to attract government subsidies and is not economical. If panels must be installed construct them on existing building roof’s.

Instead of placing the solar panels on a single property, distribute them across multiple properties

Save Our Surroundings objects to this proposed project as it poses so many risks to the local human and animal populations. Risks still include grass/bush fires, noise, soil and water contamination, very high disposal costs, unclear responsibility for end-of-life cleanup, lack of economic viable recycling of such huge volumes of toxic components, and the risk of obsolesce as much better technologies, such as small nuclear reactors become available over the next few years. Australia's oldest wind electricity plant recently reached its end-of-life and rather than undertake the decommissioning, etc. that it promised, the owner just declared it a museum. How many more wind and solar projects will not meet their EIS commitments, as is happening in other countries? No upfront bond means no skin in the game.

I object to this Electricity Generating Works proposal because I am not convinced it will ever result in cheaper electricity for us or others. Our electricity costs have already gone up four-fold in four years even before the latest 25% increase by the AER. Wind and solar electricity generation have increased significantly over the same period. Conclusion, as discovered by others around the world: more wind and solar equals increasingly higher energy bills.