Thomas Anderson
Object
Thomas Anderson
Object
Pulletop
,
New South Wales
Message
Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.
Because of The extreme lack of equipment available for the local Rural Fire Service members to fight a lithium-ion battery fire.
I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of The extreme lack of equipment available for the local Rural Fire Service members to fight a lithium-ion battery fire.
The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.
Fire Risk and Safety to the local Rural Fire Service members and their lack of equipment to fight a lithium-ion battery fire, is of major concern in the event of a fire occurring within the proposed Mangoplah BESS project site, as the NSWFR state “that large-scale LiBESS pose a unique challenge to firefighters when responding to and managing an incident”, the NSWFR goes on to say that “large-scale LiBESS as a hazardous electrical, chemical and fire risk with the risk of community consequence that necessitates special consideration”. In addition, Superintendent James O’Carroll, stated “that BESS facilities present special problems of fighting fire…” (NSW Fire & Rescue, 2025).
In addition, radiant heat, is a form of heat transfer, it can cause severe burns even without direct contact with flames, according to the NSW Rural Fire Service, rural fire service members responding to bushfires face the risk of radiant heat burns due to the nature of the environment, the NSW Rural Fire Service goes onto state that “to mitigate this risk, firefighters wear protective clothing”, this can be extremely difficult in the event of a lithium-ion battery fire, due to the lack of appropriate protective clothing, including self-contained breathing apparatuses and structural firefighting gear, required to fight such a fire, this equipment is only at the disposal of appropriately qualified members and experienced to fight such a fire, according to the NSW Fire & Rescue.
Furthermore, lithium-ion battery fires pose a significant thermal hazard, with fires reaching extreme temperatures ranging from 700-1000 degrees Celsius, additionally lithium-ion battery fires can produce toxic gases and potentially lead to explosions, further increasing the danger facing the local Rural Fire Service members.
Moreover, is the lack of appropriate equipment, such as self-contained breathing apparatuses and structural firefighting gear, which according to the NSWFR, should only be used by appropriately qualified members. This is of major concern to the local Rural Fire Service members, because they only have the knowledge, experience and equipment to fight bushfire, not fires of this nature, but then in the Deniliquin EIS Report it states that “Following commissioning of the BESS, the preparedness of local RFS and Fire and Rescue brigades would be enhanced through site orientation and information events and the facilitation of training in the management of LFP battery fires” (p.132, 2025).
The very idea of being asked or told that the local Rural Fire Service members are to be involved in fighting a fire that may occur near or within the proposed Mangoplah BESS project site is outrageous, our local Rural Fire Service members are volunteers who are not directly paid for their time, and are not volunteers to sacrifice their lives to protect the proposed Mangoplah BESS project in the event of a fire occurring near or within the area of the proposed Mangoplah BESS project site infrastructure but another whole range due to lithium-ion batteries and potential toxicity (Bowman, 2025).
This is very concerning for the local Rural Fire Service members, as they are volunteers who are not directly paid for their time and are not volunteers to sacrifice their lives to protect the proposed Mangoplah BESS project in the event of a fire occurring near or within the area of the proposed Mangoplah BESS project site.
Fire Risk and Safety and the lack of equipment available for the local Rural Fire Service members to fight a lithium-ion battery fire, is of major concern in the event of a fire occurring within the BESS, not only from the potential threat of thermal runaway and release of toxic chemicals into the air affecting the village of Mangoplah, the surrounding farm land, crops and livestock but also leaking into the local waterways and creeks.
It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk and being impacted so heavily. Please consider the fire risk and the added pressure posed to the local Rural Fire Service members and the broader community. In addition, changing the land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the cost to the Mangoplah community – their environment, their safety, their homes and many farming families who have been here for generations will all be at increased risk if the proposed Mangoplah BESS project goes ahead.
Because of The extreme lack of equipment available for the local Rural Fire Service members to fight a lithium-ion battery fire.
I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of The extreme lack of equipment available for the local Rural Fire Service members to fight a lithium-ion battery fire.
The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.
Fire Risk and Safety to the local Rural Fire Service members and their lack of equipment to fight a lithium-ion battery fire, is of major concern in the event of a fire occurring within the proposed Mangoplah BESS project site, as the NSWFR state “that large-scale LiBESS pose a unique challenge to firefighters when responding to and managing an incident”, the NSWFR goes on to say that “large-scale LiBESS as a hazardous electrical, chemical and fire risk with the risk of community consequence that necessitates special consideration”. In addition, Superintendent James O’Carroll, stated “that BESS facilities present special problems of fighting fire…” (NSW Fire & Rescue, 2025).
In addition, radiant heat, is a form of heat transfer, it can cause severe burns even without direct contact with flames, according to the NSW Rural Fire Service, rural fire service members responding to bushfires face the risk of radiant heat burns due to the nature of the environment, the NSW Rural Fire Service goes onto state that “to mitigate this risk, firefighters wear protective clothing”, this can be extremely difficult in the event of a lithium-ion battery fire, due to the lack of appropriate protective clothing, including self-contained breathing apparatuses and structural firefighting gear, required to fight such a fire, this equipment is only at the disposal of appropriately qualified members and experienced to fight such a fire, according to the NSW Fire & Rescue.
Furthermore, lithium-ion battery fires pose a significant thermal hazard, with fires reaching extreme temperatures ranging from 700-1000 degrees Celsius, additionally lithium-ion battery fires can produce toxic gases and potentially lead to explosions, further increasing the danger facing the local Rural Fire Service members.
Moreover, is the lack of appropriate equipment, such as self-contained breathing apparatuses and structural firefighting gear, which according to the NSWFR, should only be used by appropriately qualified members. This is of major concern to the local Rural Fire Service members, because they only have the knowledge, experience and equipment to fight bushfire, not fires of this nature, but then in the Deniliquin EIS Report it states that “Following commissioning of the BESS, the preparedness of local RFS and Fire and Rescue brigades would be enhanced through site orientation and information events and the facilitation of training in the management of LFP battery fires” (p.132, 2025).
The very idea of being asked or told that the local Rural Fire Service members are to be involved in fighting a fire that may occur near or within the proposed Mangoplah BESS project site is outrageous, our local Rural Fire Service members are volunteers who are not directly paid for their time, and are not volunteers to sacrifice their lives to protect the proposed Mangoplah BESS project in the event of a fire occurring near or within the area of the proposed Mangoplah BESS project site infrastructure but another whole range due to lithium-ion batteries and potential toxicity (Bowman, 2025).
This is very concerning for the local Rural Fire Service members, as they are volunteers who are not directly paid for their time and are not volunteers to sacrifice their lives to protect the proposed Mangoplah BESS project in the event of a fire occurring near or within the area of the proposed Mangoplah BESS project site.
Fire Risk and Safety and the lack of equipment available for the local Rural Fire Service members to fight a lithium-ion battery fire, is of major concern in the event of a fire occurring within the BESS, not only from the potential threat of thermal runaway and release of toxic chemicals into the air affecting the village of Mangoplah, the surrounding farm land, crops and livestock but also leaking into the local waterways and creeks.
It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk and being impacted so heavily. Please consider the fire risk and the added pressure posed to the local Rural Fire Service members and the broader community. In addition, changing the land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the cost to the Mangoplah community – their environment, their safety, their homes and many farming families who have been here for generations will all be at increased risk if the proposed Mangoplah BESS project goes ahead.
Trina Baker
Object
Trina Baker
Object
Mangoplah
,
New South Wales
Message
Subject: Formal Objection to the Mangoplah Battery Energy Storage System (BESS) – SSD-77527735
I am writing to formally object to the proposed Mangoplah Battery Energy Storage System (BESS), SSD-77527735, to be developed by Samsung C&T Renewable Energy Australia (SREA) Pty Ltd at 4178 Holbrook Road, Mangoplah.
My objection is grounded in significant concerns regarding the threat the project poses to the local environment and, critically, the potential damage to Aboriginal cultural heritage and artefacts within and surrounding the proposed development area. These concerns are directly relevant to the legal obligations imposed on developers and consent authorities under New South Wales planning and heritage legislation.
1. Risks to Aboriginal Cultural Heritage
The proposed disturbance of land associated with large-scale battery infrastructure, earthworks, and associated transmission works poses a substantial risk of destroying or displacing Aboriginal artefacts and cultural sites. These items are protected under the following NSW legislation:
• Aboriginal Cultural Heritage Act 2024 (NSW) – pending commencement
Although not yet in full force, this Act reflects the NSW Government’s formal recognition of the need to protect Aboriginal cultural heritage through stronger, more transparent processes and genuine consultation with Aboriginal communities.
• National Parks and Wildlife Act 1974 (NPW Act)
Until the 2024 Act commences, the NPW Act remains the primary legislation protecting Aboriginal objects and places.
Under Section 86, it is an offence to harm or desecrate an Aboriginal object.
Under Section 89A, developers are legally required to exercise due diligence in identifying and avoiding harm to Aboriginal cultural heritage.
Failure to adequately survey, assess, and consult constitutes non-compliance.
• Environmental Planning and Assessment Act 1979 (EP&A Act)
Under Section 1.3 (Objects of the Act), planning decisions must promote the protection and conservation of Aboriginal cultural heritage.
Under Section 4.15, consent authorities must consider the likely environmental impacts of the development, including impacts on heritage.
This requires comprehensive cultural heritage assessment and meaningful consultation with Registered Aboriginal Parties (RAPs) and Traditional Custodians.
Given these legislative requirements, I am concerned that the current documentation and assessments for the Mangoplah BESS project do not sufficiently address the potential for harm to Aboriginal artefacts or sacred cultural landscapes. Any disturbance to these heritage items would represent an irreversible loss and a failure to meet statutory obligations.
2. Insufficient Cultural Heritage Assessment and Consultation
Large-scale energy projects must be supported by rigorous Aboriginal Cultural Heritage Assessments (ACHAs) prepared in accordance with NSW Government guidelines, including the Due Diligence Code of Practice for the Protection of Aboriginal Objects in NSW (2010).
At present, it is unclear whether:
• a complete ACHA has been conducted;
• appropriate archaeological surveys have been undertaken;
• Traditional Custodians have been adequately consulted;
• avoidance and mitigation strategies have been properly considered.
Approval of the Mangoplah BESS project without these steps would be inconsistent with the above legislation and with NSW Government policy requirements.
3. Request for the Proposal to Be Reconsidered
Given the cultural, environmental, and legal risks associated with the proposal, I strongly oppose approval of the Mangoplah BESS project in its current form. I urge the consent authorities to:
1. Require a full Aboriginal Cultural Heritage Assessment by qualified archaeologists with Traditional Custodian participation;
2. Ensure compliance with the NPW Act, the EP&A Act, and relevant codes of practice;
3. Give primacy to the protection of Aboriginal cultural heritage in decision-making, as required by law.
Conclusion
The loss or disturbance of Indigenous artefacts is irreversible, and the legislation in NSW clearly sets out strict obligations to prevent such harm. Until the proponent can demonstrate full compliance with these obligations and provide evidence that cultural heritage will be preserved, this project should not proceed.
I am writing to formally object to the proposed Mangoplah Battery Energy Storage System (BESS), SSD-77527735, to be developed by Samsung C&T Renewable Energy Australia (SREA) Pty Ltd at 4178 Holbrook Road, Mangoplah.
My objection is grounded in significant concerns regarding the threat the project poses to the local environment and, critically, the potential damage to Aboriginal cultural heritage and artefacts within and surrounding the proposed development area. These concerns are directly relevant to the legal obligations imposed on developers and consent authorities under New South Wales planning and heritage legislation.
1. Risks to Aboriginal Cultural Heritage
The proposed disturbance of land associated with large-scale battery infrastructure, earthworks, and associated transmission works poses a substantial risk of destroying or displacing Aboriginal artefacts and cultural sites. These items are protected under the following NSW legislation:
• Aboriginal Cultural Heritage Act 2024 (NSW) – pending commencement
Although not yet in full force, this Act reflects the NSW Government’s formal recognition of the need to protect Aboriginal cultural heritage through stronger, more transparent processes and genuine consultation with Aboriginal communities.
• National Parks and Wildlife Act 1974 (NPW Act)
Until the 2024 Act commences, the NPW Act remains the primary legislation protecting Aboriginal objects and places.
Under Section 86, it is an offence to harm or desecrate an Aboriginal object.
Under Section 89A, developers are legally required to exercise due diligence in identifying and avoiding harm to Aboriginal cultural heritage.
Failure to adequately survey, assess, and consult constitutes non-compliance.
• Environmental Planning and Assessment Act 1979 (EP&A Act)
Under Section 1.3 (Objects of the Act), planning decisions must promote the protection and conservation of Aboriginal cultural heritage.
Under Section 4.15, consent authorities must consider the likely environmental impacts of the development, including impacts on heritage.
This requires comprehensive cultural heritage assessment and meaningful consultation with Registered Aboriginal Parties (RAPs) and Traditional Custodians.
Given these legislative requirements, I am concerned that the current documentation and assessments for the Mangoplah BESS project do not sufficiently address the potential for harm to Aboriginal artefacts or sacred cultural landscapes. Any disturbance to these heritage items would represent an irreversible loss and a failure to meet statutory obligations.
2. Insufficient Cultural Heritage Assessment and Consultation
Large-scale energy projects must be supported by rigorous Aboriginal Cultural Heritage Assessments (ACHAs) prepared in accordance with NSW Government guidelines, including the Due Diligence Code of Practice for the Protection of Aboriginal Objects in NSW (2010).
At present, it is unclear whether:
• a complete ACHA has been conducted;
• appropriate archaeological surveys have been undertaken;
• Traditional Custodians have been adequately consulted;
• avoidance and mitigation strategies have been properly considered.
Approval of the Mangoplah BESS project without these steps would be inconsistent with the above legislation and with NSW Government policy requirements.
3. Request for the Proposal to Be Reconsidered
Given the cultural, environmental, and legal risks associated with the proposal, I strongly oppose approval of the Mangoplah BESS project in its current form. I urge the consent authorities to:
1. Require a full Aboriginal Cultural Heritage Assessment by qualified archaeologists with Traditional Custodian participation;
2. Ensure compliance with the NPW Act, the EP&A Act, and relevant codes of practice;
3. Give primacy to the protection of Aboriginal cultural heritage in decision-making, as required by law.
Conclusion
The loss or disturbance of Indigenous artefacts is irreversible, and the legislation in NSW clearly sets out strict obligations to prevent such harm. Until the proponent can demonstrate full compliance with these obligations and provide evidence that cultural heritage will be preserved, this project should not proceed.
Anneliese Seager
Object
Anneliese Seager
Object
Mangoplah
,
New South Wales
Message
Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.
Because of the Very high risk of hazardous toxic plumes from a fire that may occur within the proposed Mangoplah BESS project and exacerbated by water/rain.
I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of the Very high risk of hazardous toxic plumes from a fire that may occur within the proposed Mangoplah BESS project and exacerbated by water/rain.
The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.
As stated by Lote Consulting, Fire Safety Security, 2022, stated, “There have been several recent fires at BESS projects around Australia with associated dispersion of potentially toxic gases” (cited, p.7, Neoen Territory Battery, EIS, 2024) and the potential impact on sensitive receptors. Lote Consulting, Fire Safety Security, 2022, further mentioned within the report that these toxic gases included, Carbon Dioxide, Carbon Monoxide and Fluorine Gases.
Despite the within the Mangoplah Environmental Impact Statement stating that the Tesla Megapack 2XL are safe, it was noted in the Preliminary Hazardous Analysis report that identified hazards include the “Release of electrolyte (liquid/vented gas) from the battery cell”, further stating the consequences include:
· “Release of flammable liquid electrolyte
· Vapourisation of liquid electrolyte
· Release of vented gas from cells
· Fire and/or explosion in battery enclosure/building
· Release of toxic combustion products
· Injury/fatality” (p. 23, Preliminary Hazard Analysis, 2025).
Umwelt Australia Pty. Limited, state that in the event of “toxic chemicals/fumes being released”, the risk is rated as high (cited, p. 251, Neoen, Territory Battery, 2024). Moreover, according to the NSW Department of Planning, these hazardous “toxic substances can affect people in many different ways and the seriousness of the exposure will be highly dependent on the sensitivity of the individual and on the duration of the exposure” (p.16, Hazardous Industry Planning Advisory, Paper 6, 2011). Umwelt Australia Pty. Limited, report, that “most people will begin to experience health effect if exposed to the chemicals for one hour” (cited, p.277, Neoen, Territory Battery EIS, 2024). Umwelt Australia Pty. Limited, have recommended that the residents “from the source to a distance of 20 km shall be notified to shelter inside in the event of a BESS fire” (cited, p. 1054, Neoen, Territory Battery EIS, 2024). Even more concerning, is the increased Hydrofluoric Acid (HF) produced, the “larger impact distances should be considered…” (cited, p.1053, Neoen Territory Battery EIS, 2024). More disturbing however is “under less stable weather conditions, people within 247 metres of the fire could be exposed to fatal concentrations of Hydrogen Floride (HF) gas if exposed for one hour” (cited, p.258, Neoen Territory Battery EIS, 2024).
Furthermore, in the event of a fire occurring within the proposed Mangoplah BESS site, battery fires should not come into contact with water, “this may be unavoidable in the event of rain or if water is being used to combat adjacent bushfire” (cited, p. 275, Umwelt Australia Pty. Limited, Neoen, Territory Battery, 2024), Lote Consulting, Fire Safety Security, 2022, go onto state that Hydrogen Floride (HF) “would be exacerbated through the application of water to a lithium-ion battery fire” (cited, p.275, Neoen, Territory Battery, 2024). As mentioned above, water contact with a battery fire is extremely dangerous and hazardous, but sometimes is unavoidable, such as during a bushfire or storm, therefore it is important that the local Rural Fire Service members are not within close proximity to the proposed Mangoplah BESS project, as they do not have the necessary required equipment or knowledge and experience, which may result in injury or death to a local Rural Fire Service member.
Moreover, the NSW Department of Planning state that a hazard “is anything or situation with a potential for causing damage to people, property or the biophysical environment” (p.6, Hazardous Industry Planning Advisory, Paper 6, 2011). Furthermore, they describe risk, as “the likelihood of a defined adverse outcome…risk of fatality, injury or environmental damage” (p.6, Hazardous Industry Planning Advisory, Paper 6, 2011).
It is of major concern that the residents of the village of Mangoplah and the surrounding landholders, but more so, my family and young children will be at a very high risk of exposure to hazardous toxic plumes in the event of a fire that may occur at the proposed Mangoplah BESS project, which can be life changing for everyone in the village of Mangoplah, especially the farmers in the surrounding area with the toxic fumes from a lithium-ion battery fire affecting their soil, crops, and pasture grasses, resulting in loss of income for farmers, but the hazardous toxic plumes can also have a devastating impact on the ecosystem surrounding the area of Mangoplah.
It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk of having the proposed Mangoplah BESS project built within close proximity to the village of Mangoplah but also very close to productive farming and grazing land. Additionally, the change of land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the environment, the cost to the Mangoplah community and surrounding farming families, many of whom have been here for generations, working hard to keep the area going, do not want the proposed Mangoplah BESS project to go ahead.
Because of the Very high risk of hazardous toxic plumes from a fire that may occur within the proposed Mangoplah BESS project and exacerbated by water/rain.
I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of the Very high risk of hazardous toxic plumes from a fire that may occur within the proposed Mangoplah BESS project and exacerbated by water/rain.
The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.
As stated by Lote Consulting, Fire Safety Security, 2022, stated, “There have been several recent fires at BESS projects around Australia with associated dispersion of potentially toxic gases” (cited, p.7, Neoen Territory Battery, EIS, 2024) and the potential impact on sensitive receptors. Lote Consulting, Fire Safety Security, 2022, further mentioned within the report that these toxic gases included, Carbon Dioxide, Carbon Monoxide and Fluorine Gases.
Despite the within the Mangoplah Environmental Impact Statement stating that the Tesla Megapack 2XL are safe, it was noted in the Preliminary Hazardous Analysis report that identified hazards include the “Release of electrolyte (liquid/vented gas) from the battery cell”, further stating the consequences include:
· “Release of flammable liquid electrolyte
· Vapourisation of liquid electrolyte
· Release of vented gas from cells
· Fire and/or explosion in battery enclosure/building
· Release of toxic combustion products
· Injury/fatality” (p. 23, Preliminary Hazard Analysis, 2025).
Umwelt Australia Pty. Limited, state that in the event of “toxic chemicals/fumes being released”, the risk is rated as high (cited, p. 251, Neoen, Territory Battery, 2024). Moreover, according to the NSW Department of Planning, these hazardous “toxic substances can affect people in many different ways and the seriousness of the exposure will be highly dependent on the sensitivity of the individual and on the duration of the exposure” (p.16, Hazardous Industry Planning Advisory, Paper 6, 2011). Umwelt Australia Pty. Limited, report, that “most people will begin to experience health effect if exposed to the chemicals for one hour” (cited, p.277, Neoen, Territory Battery EIS, 2024). Umwelt Australia Pty. Limited, have recommended that the residents “from the source to a distance of 20 km shall be notified to shelter inside in the event of a BESS fire” (cited, p. 1054, Neoen, Territory Battery EIS, 2024). Even more concerning, is the increased Hydrofluoric Acid (HF) produced, the “larger impact distances should be considered…” (cited, p.1053, Neoen Territory Battery EIS, 2024). More disturbing however is “under less stable weather conditions, people within 247 metres of the fire could be exposed to fatal concentrations of Hydrogen Floride (HF) gas if exposed for one hour” (cited, p.258, Neoen Territory Battery EIS, 2024).
Furthermore, in the event of a fire occurring within the proposed Mangoplah BESS site, battery fires should not come into contact with water, “this may be unavoidable in the event of rain or if water is being used to combat adjacent bushfire” (cited, p. 275, Umwelt Australia Pty. Limited, Neoen, Territory Battery, 2024), Lote Consulting, Fire Safety Security, 2022, go onto state that Hydrogen Floride (HF) “would be exacerbated through the application of water to a lithium-ion battery fire” (cited, p.275, Neoen, Territory Battery, 2024). As mentioned above, water contact with a battery fire is extremely dangerous and hazardous, but sometimes is unavoidable, such as during a bushfire or storm, therefore it is important that the local Rural Fire Service members are not within close proximity to the proposed Mangoplah BESS project, as they do not have the necessary required equipment or knowledge and experience, which may result in injury or death to a local Rural Fire Service member.
Moreover, the NSW Department of Planning state that a hazard “is anything or situation with a potential for causing damage to people, property or the biophysical environment” (p.6, Hazardous Industry Planning Advisory, Paper 6, 2011). Furthermore, they describe risk, as “the likelihood of a defined adverse outcome…risk of fatality, injury or environmental damage” (p.6, Hazardous Industry Planning Advisory, Paper 6, 2011).
It is of major concern that the residents of the village of Mangoplah and the surrounding landholders, but more so, my family and young children will be at a very high risk of exposure to hazardous toxic plumes in the event of a fire that may occur at the proposed Mangoplah BESS project, which can be life changing for everyone in the village of Mangoplah, especially the farmers in the surrounding area with the toxic fumes from a lithium-ion battery fire affecting their soil, crops, and pasture grasses, resulting in loss of income for farmers, but the hazardous toxic plumes can also have a devastating impact on the ecosystem surrounding the area of Mangoplah.
It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk of having the proposed Mangoplah BESS project built within close proximity to the village of Mangoplah but also very close to productive farming and grazing land. Additionally, the change of land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the environment, the cost to the Mangoplah community and surrounding farming families, many of whom have been here for generations, working hard to keep the area going, do not want the proposed Mangoplah BESS project to go ahead.
Stace Creasy
Object
Stace Creasy
Object
Mangoplah
,
New South Wales
Message
Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.
Because of the Inappropriate use of RU1 land to accommodate the proposed Mangoplah BESS project site.
I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of the Inappropriate use of RU1 land to accommodate the proposed Mangoplah BESS project site.
The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.
The Environmental Impact Statement states that “The land is classified as RU1 and occupies the majority of the Study Area and the entirety of the Project Site. The landscape within the Project Area and immediate surrounds comprise of agricultural practices including grazing native vegetation, cropping and residential and farm infrastructure. Rural residential properties are dotted throughout the agricultural lands” (p.134, 2025).
Samsung C&T Renewable Energy Australia (SREA) Pty. Limited, state in the Scope Report that “the Project Site has been selected with the goal of balancing the assessed social, environmental and economic aspects associated with the development of a BESS” (p. 21), this situation may be appropriate in other zones, such as a Renewable Energy Zone (REZ), REZ zones are specifically designed to accommodate renewable energy infrastructure, including storage facilities like batteries and substations. The NSW Government states that they ensure that development occurs in these designated areas. The area in which the proposed Mangoplah BESS project will be located, is not in a REZ zone, it is a RU1 area, which is Primary Production zoning, which aims to encourage sustainable agricultural production and protect natural resources.
The Scope Report goes onto state that “the selection of the site to develop an energy facility supports the…objections” (p.9), of the Wagga Wagga Local Environment Plan, 2010 objectives associated with RU1 classification –
• To encourage sustainable primary industry production by maintaining and enhancing the natural resource base
• To encourage diversity in primary industry enterprises and systems appropriate for the area
• To minimise the fragmentation and alienation of resource lands
• To minimise conflict between land use within this zone and land uses within adjoining zones
• To foster strong, sustainable rural community lifestyles
• To maintain the rural landscape character of the land…”(p.9, Mangoplah BESS, Scope Report).
Furthermore, the Scope Report also states that “the proposal aligns closely with two planning principles for the Wagga Wagga City Council (WWCC). These include
. Principle 1: The environment – Protect and enhance natural areas and corridors. The project aims to balance the natural environment and development through minimising impact on terrestrial biodiversity within the project site and surrounding areas.
. Principle 2: The environment – increase resilience to natural hazards and land constraints” (p.18, Samsung C&T Renewable Energy Australia (SREA) Pty. Limited).
Moreover, the aims of the NSW State Environmental Planning Policy (Primary Production) 2021 –
(a) to facilitate the orderly economic use and development of lands for primary production.
(b) to reduce land use conflict and sterilisation of rural land by balancing primary production…
(c) to identify State significant agricultural land for the purpose of ensuring the ongoing viability of agriculture on that land, having regard to social, economic and environmental considerations.
(d) to encourage sustainable agriculture…”(2025).
The community of Mangoplah feel that if this Battey Energy Storage System (BESS) were to go ahead, not only does it go against the aims, objectives and policies of all levels of government, as mentioned above, but it will have a devastating impact on the village of Mangoplah and the surrounding landholders, socially, economically, mentally, but also the surrounding environment, especially in the event of a fire occurring within the proposed Mangoplah BESS project.
NSW Government Planning, Hazardous Industry Planning Advisory Paper No. 4, states, “when considering strategic planning, the primary emphasis needs to be on the suitability of land for the proposed land of uses, having regard to existing risk exposure and the sensitivity of the current land use” (p.6), this statement should be the key issue when looking at where the proposed Mangoplah BESS project is to be constructed, the community voice that RU1 land areas are specifically zoned for the intention of agricultural production and environmental protection, with the main focus on activities like farming and grazing.
Furthermore, the community of Mangoplah feel that if the proposed Mangoplah (BESS) project were to go ahead that their concerns have not been taken seriously, when it involves the protection of our land, the environment, our small village, it’s residents and the surrounding agricultural farm land, the farmers and their livestock, and their livelihood, as stated in the State Environmental Planning Policy (Primary Production) 2021, that placing a hazardous development or industry, would pose a significant risk to human health, life or property, and the biophysical environment in relation to the planned location of the proposed Mangoplah BESS project.
It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk of having the proposed Mangoplah BESS project built within close proximity to the village of Mangoplah but also very close to productive farming and grazing land. Additionally, the change of land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the environment, the cost to the Mangoplah community and surrounding farming families, many of whom have been here for generations, working hard to keep the area going, do not want the proposed Mangoplah BESS project to go ahead.
Because of the Inappropriate use of RU1 land to accommodate the proposed Mangoplah BESS project site.
I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of the Inappropriate use of RU1 land to accommodate the proposed Mangoplah BESS project site.
The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.
The Environmental Impact Statement states that “The land is classified as RU1 and occupies the majority of the Study Area and the entirety of the Project Site. The landscape within the Project Area and immediate surrounds comprise of agricultural practices including grazing native vegetation, cropping and residential and farm infrastructure. Rural residential properties are dotted throughout the agricultural lands” (p.134, 2025).
Samsung C&T Renewable Energy Australia (SREA) Pty. Limited, state in the Scope Report that “the Project Site has been selected with the goal of balancing the assessed social, environmental and economic aspects associated with the development of a BESS” (p. 21), this situation may be appropriate in other zones, such as a Renewable Energy Zone (REZ), REZ zones are specifically designed to accommodate renewable energy infrastructure, including storage facilities like batteries and substations. The NSW Government states that they ensure that development occurs in these designated areas. The area in which the proposed Mangoplah BESS project will be located, is not in a REZ zone, it is a RU1 area, which is Primary Production zoning, which aims to encourage sustainable agricultural production and protect natural resources.
The Scope Report goes onto state that “the selection of the site to develop an energy facility supports the…objections” (p.9), of the Wagga Wagga Local Environment Plan, 2010 objectives associated with RU1 classification –
• To encourage sustainable primary industry production by maintaining and enhancing the natural resource base
• To encourage diversity in primary industry enterprises and systems appropriate for the area
• To minimise the fragmentation and alienation of resource lands
• To minimise conflict between land use within this zone and land uses within adjoining zones
• To foster strong, sustainable rural community lifestyles
• To maintain the rural landscape character of the land…”(p.9, Mangoplah BESS, Scope Report).
Furthermore, the Scope Report also states that “the proposal aligns closely with two planning principles for the Wagga Wagga City Council (WWCC). These include
. Principle 1: The environment – Protect and enhance natural areas and corridors. The project aims to balance the natural environment and development through minimising impact on terrestrial biodiversity within the project site and surrounding areas.
. Principle 2: The environment – increase resilience to natural hazards and land constraints” (p.18, Samsung C&T Renewable Energy Australia (SREA) Pty. Limited).
Moreover, the aims of the NSW State Environmental Planning Policy (Primary Production) 2021 –
(a) to facilitate the orderly economic use and development of lands for primary production.
(b) to reduce land use conflict and sterilisation of rural land by balancing primary production…
(c) to identify State significant agricultural land for the purpose of ensuring the ongoing viability of agriculture on that land, having regard to social, economic and environmental considerations.
(d) to encourage sustainable agriculture…”(2025).
The community of Mangoplah feel that if this Battey Energy Storage System (BESS) were to go ahead, not only does it go against the aims, objectives and policies of all levels of government, as mentioned above, but it will have a devastating impact on the village of Mangoplah and the surrounding landholders, socially, economically, mentally, but also the surrounding environment, especially in the event of a fire occurring within the proposed Mangoplah BESS project.
NSW Government Planning, Hazardous Industry Planning Advisory Paper No. 4, states, “when considering strategic planning, the primary emphasis needs to be on the suitability of land for the proposed land of uses, having regard to existing risk exposure and the sensitivity of the current land use” (p.6), this statement should be the key issue when looking at where the proposed Mangoplah BESS project is to be constructed, the community voice that RU1 land areas are specifically zoned for the intention of agricultural production and environmental protection, with the main focus on activities like farming and grazing.
Furthermore, the community of Mangoplah feel that if the proposed Mangoplah (BESS) project were to go ahead that their concerns have not been taken seriously, when it involves the protection of our land, the environment, our small village, it’s residents and the surrounding agricultural farm land, the farmers and their livestock, and their livelihood, as stated in the State Environmental Planning Policy (Primary Production) 2021, that placing a hazardous development or industry, would pose a significant risk to human health, life or property, and the biophysical environment in relation to the planned location of the proposed Mangoplah BESS project.
It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk of having the proposed Mangoplah BESS project built within close proximity to the village of Mangoplah but also very close to productive farming and grazing land. Additionally, the change of land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the environment, the cost to the Mangoplah community and surrounding farming families, many of whom have been here for generations, working hard to keep the area going, do not want the proposed Mangoplah BESS project to go ahead.
Susan Porter
Object
Susan Porter
Object
Mangoplah
,
New South Wales
Message
Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.
Because of the Very high risk of hazardous toxic plumes from a fire that may occur within the proposed Mangoplah BESS project affecting the health of livestock.
I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of the Very high risk of hazardous toxic plumes from a fire that may occur within the proposed Mangoplah BESS project affecting the health of livestock.
The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.
As stated by Lote Consulting, Fire Safety Security, 2022, in their report cited in Neoen, Territory Battery stated, “There have been several recent fires at BESS projects around the world and in Australia with associated dispersion of potentially toxic gases” (p.7, 2024) and the potential impact on sensitive receptors. Lote Consulting, Fire Safety Security, 2022, mentioned within the report that these toxic gases included, Carbon Dioxide, Carbon Monoxide and Fluorine Gases, how these affect people is discussed in more detail below.
Umwelt Australia Pty. Limited, state that in the event of “toxic chemicals/fumes being released”, the risk is rated as high (p. 251, Neoen, Territory Battery, 2024). Moreover, according to the NSW Department of Planning, these hazardous “toxic substances can affect people in many different ways and the seriousness of the exposure will be highly dependent on the sensitivity of the individual and on the duration of the exposure” (p.16, Hazardous Industry Planning Advisory, Paper 6, 2011). As stated by Umwelt Australia Pty. Limited, that “most people will begin to experience health effect if exposed to the chemicals for one hour” (p.277, Neoen, Territory Battery EIS, 2024). Additionally, Umwelt Australia Pty. Limited have recommended that the residents “from the source to a distance of 20 km shall be notified to shelter inside in the event of a BESS fire” (p. 1054, Neoen, Territory Battery EIS, 2024). Even more concerning by Umwelt Australia Pty. Limited, is the increased Hydrofluoric Acid (HF) produced, the “larger impact distances should be considered…” (p.1053, Neoen, Territory Battery EIS, 2024). More disturbing as stated by Umwelt Australia Pty., is “under less stable weather conditions, people within 247 metres of the fire could be exposed to fatal concentrations of Hydrogen Floride (HF) gas if exposed for one hour” (p.258, Neoen, Territory Battery EIS, 2024).
Moreover, the NSW Department of Planning state that a hazard “is anything or situation with a potential for causing damage to people, property or the biophysical environment” (p.6, Hazardous Industry Planning Advisory, Paper 6, 2011). Furthermore, they describe risk, as “the likelihood of a defined adverse outcome…risk of fatality, injury or environmental damage” (p.6, Hazardous Industry Planning Advisory, Paper 6, 2011).
These toxic gases also have the potential to affect livestock in the surrounding farmland in a similar way, with Hydrogen Fluoride (HF)/Hydrofluoric Acid causing bronchoconstriction, pulmonary edema and respiratory distress, which can lead to systemic fluoride poisoning, affecting calcium and magnesium levels. Hydrogen Fluoride can also cause deep tissue burns, necrosis and pain, even in low concentrations. Additionally, eye exposure may result in corneal damage, blindness or permanent scarring. The Fluoride Ions can also disrupt electrolyte balance, leading to cardiac arrhythmias, seizures and organ failure, with chronic exposure causing fluorosis, affecting bones and teeth. These heavy metals, accumulate in tissues, leading to neurological, renal and reproductive issues. Moreover, cattle and sheep grazing on contaminated pastures may show reduce fertility, milk contamination, and growth retardation. In addition, Hydrogen Fluoride and heavy metals alter soil PH, disrupt microbial activity, and reduce forage quality. Furthermore, contaminated water sources can lead to chronic poisoning in livestock (Professor Bruce Allworth, CSU, School of Agriculture, Environmental and Veterinary Sciences, 2025).
As mentioned above the toxic gases released during a BESS fire include Hydrogen Fluoride, which if inhaled “is almost completely absorbed in the upper respiratory tract, before reaching the lungs, and distribution to the blood is rapid” (p.81, National Industrial Chemicals Notification and Assessment Scheme, 2001), resulting in possible burns, cough, narrowing of the large airways (bronchoconstriction), and difficulty breathing or shortness of breath (dyspnea).
●Severe: Immediate narrowing and swelling of the throat, upper airway obstruction, accumulation of fluid in the lungs (pulmonary edema), and partial or complete lung collapse.
●Whole-body (systemic) effects are likely, including low blood levels of calcium and magnesium (hypocalcemia and hypomagnesemia), high blood levels of potassium (hyperkalemia), low blood pressure (hypotension), abnormal or disordered heart rhythms (dysrhythmias), accumulation of acid in blood and tissues (metabolic acidosis), involuntary muscle contractions, seizures, and death. Hydrofluoric acid can also be absorbed through the skin, resulting in corrosive effects on the skin, it can also cross the placenta during pregnancy resulting in fetal deaths.
It is of major concern that the residents of the village of Mangoplah and the surrounding landholders will be at a very high risk of exposure to hazardous toxic plumes in the event of a fire that may occur at the proposed Mangoplah BESS project, which can be life changing for everyone in the village of Mangoplah, especially the farmers in the surrounding area with the toxic fumes from a lithium-ion battery fire affecting their soil, crops, and pasture grasses, resulting in loss of income for farmers, but the hazardous toxic plumes can also have a devastating impact on the ecosystem surrounding the area of Mangoplah.
It deeply affects and concerns me immensely, as my family was one of the very first farming families to settle in the Mangoplah district, that a rural community like Mangoplah is being exposed to this degree of risk of having the proposed Mangoplah BESS project built within close proximity to the village of Mangoplah but also very close to productive farming and grazing land. Additionally, the change of land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the environment, the cost to the Mangoplah community and surrounding farming families, many of whom have been here for generations, working hard to keep the area going, do not want the proposed Mangoplah BESS project to go ahead.
Because of the Very high risk of hazardous toxic plumes from a fire that may occur within the proposed Mangoplah BESS project affecting the health of livestock.
I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of the Very high risk of hazardous toxic plumes from a fire that may occur within the proposed Mangoplah BESS project affecting the health of livestock.
The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.
As stated by Lote Consulting, Fire Safety Security, 2022, in their report cited in Neoen, Territory Battery stated, “There have been several recent fires at BESS projects around the world and in Australia with associated dispersion of potentially toxic gases” (p.7, 2024) and the potential impact on sensitive receptors. Lote Consulting, Fire Safety Security, 2022, mentioned within the report that these toxic gases included, Carbon Dioxide, Carbon Monoxide and Fluorine Gases, how these affect people is discussed in more detail below.
Umwelt Australia Pty. Limited, state that in the event of “toxic chemicals/fumes being released”, the risk is rated as high (p. 251, Neoen, Territory Battery, 2024). Moreover, according to the NSW Department of Planning, these hazardous “toxic substances can affect people in many different ways and the seriousness of the exposure will be highly dependent on the sensitivity of the individual and on the duration of the exposure” (p.16, Hazardous Industry Planning Advisory, Paper 6, 2011). As stated by Umwelt Australia Pty. Limited, that “most people will begin to experience health effect if exposed to the chemicals for one hour” (p.277, Neoen, Territory Battery EIS, 2024). Additionally, Umwelt Australia Pty. Limited have recommended that the residents “from the source to a distance of 20 km shall be notified to shelter inside in the event of a BESS fire” (p. 1054, Neoen, Territory Battery EIS, 2024). Even more concerning by Umwelt Australia Pty. Limited, is the increased Hydrofluoric Acid (HF) produced, the “larger impact distances should be considered…” (p.1053, Neoen, Territory Battery EIS, 2024). More disturbing as stated by Umwelt Australia Pty., is “under less stable weather conditions, people within 247 metres of the fire could be exposed to fatal concentrations of Hydrogen Floride (HF) gas if exposed for one hour” (p.258, Neoen, Territory Battery EIS, 2024).
Moreover, the NSW Department of Planning state that a hazard “is anything or situation with a potential for causing damage to people, property or the biophysical environment” (p.6, Hazardous Industry Planning Advisory, Paper 6, 2011). Furthermore, they describe risk, as “the likelihood of a defined adverse outcome…risk of fatality, injury or environmental damage” (p.6, Hazardous Industry Planning Advisory, Paper 6, 2011).
These toxic gases also have the potential to affect livestock in the surrounding farmland in a similar way, with Hydrogen Fluoride (HF)/Hydrofluoric Acid causing bronchoconstriction, pulmonary edema and respiratory distress, which can lead to systemic fluoride poisoning, affecting calcium and magnesium levels. Hydrogen Fluoride can also cause deep tissue burns, necrosis and pain, even in low concentrations. Additionally, eye exposure may result in corneal damage, blindness or permanent scarring. The Fluoride Ions can also disrupt electrolyte balance, leading to cardiac arrhythmias, seizures and organ failure, with chronic exposure causing fluorosis, affecting bones and teeth. These heavy metals, accumulate in tissues, leading to neurological, renal and reproductive issues. Moreover, cattle and sheep grazing on contaminated pastures may show reduce fertility, milk contamination, and growth retardation. In addition, Hydrogen Fluoride and heavy metals alter soil PH, disrupt microbial activity, and reduce forage quality. Furthermore, contaminated water sources can lead to chronic poisoning in livestock (Professor Bruce Allworth, CSU, School of Agriculture, Environmental and Veterinary Sciences, 2025).
As mentioned above the toxic gases released during a BESS fire include Hydrogen Fluoride, which if inhaled “is almost completely absorbed in the upper respiratory tract, before reaching the lungs, and distribution to the blood is rapid” (p.81, National Industrial Chemicals Notification and Assessment Scheme, 2001), resulting in possible burns, cough, narrowing of the large airways (bronchoconstriction), and difficulty breathing or shortness of breath (dyspnea).
●Severe: Immediate narrowing and swelling of the throat, upper airway obstruction, accumulation of fluid in the lungs (pulmonary edema), and partial or complete lung collapse.
●Whole-body (systemic) effects are likely, including low blood levels of calcium and magnesium (hypocalcemia and hypomagnesemia), high blood levels of potassium (hyperkalemia), low blood pressure (hypotension), abnormal or disordered heart rhythms (dysrhythmias), accumulation of acid in blood and tissues (metabolic acidosis), involuntary muscle contractions, seizures, and death. Hydrofluoric acid can also be absorbed through the skin, resulting in corrosive effects on the skin, it can also cross the placenta during pregnancy resulting in fetal deaths.
It is of major concern that the residents of the village of Mangoplah and the surrounding landholders will be at a very high risk of exposure to hazardous toxic plumes in the event of a fire that may occur at the proposed Mangoplah BESS project, which can be life changing for everyone in the village of Mangoplah, especially the farmers in the surrounding area with the toxic fumes from a lithium-ion battery fire affecting their soil, crops, and pasture grasses, resulting in loss of income for farmers, but the hazardous toxic plumes can also have a devastating impact on the ecosystem surrounding the area of Mangoplah.
It deeply affects and concerns me immensely, as my family was one of the very first farming families to settle in the Mangoplah district, that a rural community like Mangoplah is being exposed to this degree of risk of having the proposed Mangoplah BESS project built within close proximity to the village of Mangoplah but also very close to productive farming and grazing land. Additionally, the change of land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the environment, the cost to the Mangoplah community and surrounding farming families, many of whom have been here for generations, working hard to keep the area going, do not want the proposed Mangoplah BESS project to go ahead.
Philip Davis
Object
Philip Davis
Object
PULLETOP
,
New South Wales
Message
I am the Pulletop Rural Fire Brigade, Fire Captain and as such, have grave concerns about the proposed Mangoplah BESS being located in my rural area and the risks it poses to the volunteer men and women fire fighters under my control.
Also of concern are the risks of damage to our very productive local prime agricultural land, personal property, stock, business losses and the risk of damage to our pristine environmental landscape.
“The Battery Energy Storage System industry has been promoting the idea that great strides in safety are being made and that despite a massive growth in deployments, failures have not increased as fast. Improvements certainly have been made. The industry has learned from past mistakes. But the statement that fires are “extremely rare” doesn’t pass muster. EPRI (Electric Power Research Institute), the research arm of the power industry, keeps a database of failures. Their own data shows approximately 87 failures since the first utility scale BESS was installed less than thirteen years ago. The majority of these have happened since 2021, about one failure per month. Note, the number has increased since publication to 90 failures.”
https://www.stopseguro.org/the-hidden-risk/
Further research into Bess incidents reveals that BESS’s are highly energy-dense and are highly flammable.
https://www.epri.com/research/products/000000003002030360
An important caveat to the EPRI failure data: their database mostly tracks fires that have received media attention so it understates the incidence of fires.
The above link is to the … EPRI 2024 White Paper which has produced the most comprehensive compilation of stationary BESS incidents, called the EPRI BESS Incident Database which is based on publicly accessible underlying data.
The database was initiated in 2021 following the series of lithium-ion BESS fires in South Korea and the Surprise, AZ, incident in the US. The database gathers information on stationary BESS failure events for commercial and industrial (C&I) and utility-scale BESS.
Of concern is that this report states that:
• Transparency on the cause of BESS failures continues to be limited.
• Battery OEMs and BESS integrators are often reluctant to disclose the cause of failure, and many investigation reports are not released to the public.
Of concern is the lag time in finding out a BESS has failed which then results in a large fire. For example, take the Elkhorn battery facility, Moss Landing, CA, which experienced a fire on 20/9/2022.
The investigation report was shared publicly by Tesla (the BESS manufacturer and integrator) and Pacific Gas & Electric (site owner). The investigation found that rainwater intrusion through the container caused electrical arcing within the system roper installation of a vent shield. As a confounding factor, insulation loss alarms were not properly escalated to the operator. Two days after the initial insulation alarms were recorded, smoke and fire were reported to the fire department.
We are a farming community with a 26 inch or more annual rainfall, water intrusion is highly likely. The Mangoplah BESS is to be located in an area that won’t have eyes on it 24/7 & thus it is unlikely any failure starting off with small smoke / fire will be be noticed until it is a larger fire, thus there must be appropriate measures in place for remote reporting & early actioning of any BESS failure.
With the Elkhorn BESS fire, early alarms could have prevented escalation of the initial failure into a fire that consumed the whole BESS unit and threatened the local area.
Government Regulators and Facility developers must prove/assure local communities that they are installing remote monitoring and shutdown systems to quickly detect and limit hazards, and that they can communicate critical information to emergency responders in a timely manner.
There are two main fire risks for BESS as outlined in this link:
https://www.firetrace.com/fire-protection-blog/the-dual-threat-of-bess-fire-safety
1) Fire and explosion risk due to thermal runaway
A well-studied hazard associated with BESS utilizing Li-ion batteries is the risk of thermal runaway. This phenomenon occurs when a failure or malfunction leads to an increase in battery temperature, triggering a reaction that further raises the temperature, creating a vicious cycle that can lead to fires. The compact and interconnected nature of BESS units exacerbates this risk, as a malfunction in a single component can have a domino effect, compromising the safety of the entire system. The implications of thermal runaway are not just limited to the potential for physical damage; they also pose significant safety threats to individuals and the environment.
Moreover, BESS units employing Li-ion batteries are vulnerable to off-gassing, a condition where stressed batteries release flammable gases. This issue often accompanies thermal runaway, intensifying safety concerns. Accumulated gases within BESS enclosures can create an explosive atmosphere, poised for ignition by a mere spark or surge in temperature. Notably, some fire suppression systems based on total flooding principles may inadvertently exacerbate this risk by failing to adequately vent these gases, potentially leading to severe explosions that threaten both human safety and environmental integrity, thereby highlighting the necessity for tailored safety measures.
2) Fire risk due to high voltage electronics
BESS fire risks extend beyond thermal runaway, with the Power Conversion System (PCS) presenting significant hazards. Critical PCS components, including transformers, inverters, and capacitor cabinets, are integral to the conversion and management of electrical energy within the storage system. These components can catch on fire due to electrical malfunctions, overheating from high power density, inadequate thermal management, and the stress from frequent charge/discharge cycles on system's components. Fires originating in the PCS can swiftly propagate to adjacent battery racks, rendering the extensive safety mechanisms designed to prevent thermal runaway ineffective. This scenario underscores the complexity of fire risks in BESS, highlighting the need for comprehensive fire protection strategies that encompass all system components.
Additionally, if a battery fire does occur, it releases toxic chemicals, including hydrogen fluoride and carbon monoxide which I would be not be happy send my local volunteer firefighting neighbours and friends in to fight.
There needs to be a design for a total flood fire suppression system for BESS units, as it's crucial to consider the risks associated with off-gassing. These systems must be engineered to not only suppress fires effectively but also to manage or mitigate the accumulation of flammable gases released during battery stress or failure. Strategies must be in place for gas detection and ventilation to prevent the formation of explosive atmospheres, thus ensuring the fire suppression approach addresses both immediate fire risks and the secondary dangers posed to responders, locals, agriculture produce and stock by off-gassing.
My other concerns:
1. The EIS fire history map is not accurate as it is missing 3 fires that I have attended on the property “Athlone” – the property the proposed BESS will be on.
a. One haystack fire
b. Fire started by slashing grass
c. Fire of unknown ignition amongst old machinery.
2. The 1952 fire, which engulfed the proposed site property “Athlone” ended up crossing the Murray River East of Albury about 100 km from its ignition point.
3. The proposed 100,000 litres on Mangoplah BESS water storage is totally inadequate
(The Deniliquin BESS has a 200,000-litre storage & Canberra BESS has 2 x 300,000 Litre water storage tanks on site.)
4. There is no water hydrant plan for the site
5. There is no emergency exit, there is only one way in/out
6. In Samsungs’ EIS, Appendix F.5 (The Bushfire Assessment Report) states the property is rated by the Australian Fire Danger Index as 80, which is extreme. The Fire Danger Index (FDI) is a number and rating used to show how dangerous fire conditions are in your area. Developed by Australia’s top fire scientists and the BOM, it takes into account temperature, humidity, wind, and how much fuel (dry grass, leaves, scrub) is on the ground. The higher the number, the more easily fires start and the faster they spread.
7. Proposed tree line on the western side is far too close as our predominant winds are from the west and all our past severe fires have come from the west.
8. We have no data on the failure rate of older facilities. Because this industry is so new (the first utility scale facility was commissioned in 2012) and the vast majority of facilities have come online in the past 4 years, there is almost no data on facilities that are 5 or more years old. Aging facilities will have more maintenance issues and more problems related to aging lithium-ion battery cells. Research has shown that lithium-ion batteries become less stable as they age and are more prone to undergo thermal runaway at lower threshold temperatures compared to newer batteries.
What will happen when billions of lithium-ion cells approach their end-of-life? Will we see more fire incidents? We don’t know because we haven’t gotten there yet.
9. Also concerning is that Samsung representatives advised recently that they do not have a decommissioning plan or agreement with the local land holder hosting the proposed Mangoplah BESS project.
10. The cost shifting of responsibility to the local volunteer Rural Fire Service to have the responsibility of babysitting this infrastructure for the next 25 years trying to prevent fire entering or escaping from the BESS is unrealistic and inequitable.
Please see the attachment for final concluding paragraphs which did not fit in this space, there is not a lot more. Thank you.
Also of concern are the risks of damage to our very productive local prime agricultural land, personal property, stock, business losses and the risk of damage to our pristine environmental landscape.
“The Battery Energy Storage System industry has been promoting the idea that great strides in safety are being made and that despite a massive growth in deployments, failures have not increased as fast. Improvements certainly have been made. The industry has learned from past mistakes. But the statement that fires are “extremely rare” doesn’t pass muster. EPRI (Electric Power Research Institute), the research arm of the power industry, keeps a database of failures. Their own data shows approximately 87 failures since the first utility scale BESS was installed less than thirteen years ago. The majority of these have happened since 2021, about one failure per month. Note, the number has increased since publication to 90 failures.”
https://www.stopseguro.org/the-hidden-risk/
Further research into Bess incidents reveals that BESS’s are highly energy-dense and are highly flammable.
https://www.epri.com/research/products/000000003002030360
An important caveat to the EPRI failure data: their database mostly tracks fires that have received media attention so it understates the incidence of fires.
The above link is to the … EPRI 2024 White Paper which has produced the most comprehensive compilation of stationary BESS incidents, called the EPRI BESS Incident Database which is based on publicly accessible underlying data.
The database was initiated in 2021 following the series of lithium-ion BESS fires in South Korea and the Surprise, AZ, incident in the US. The database gathers information on stationary BESS failure events for commercial and industrial (C&I) and utility-scale BESS.
Of concern is that this report states that:
• Transparency on the cause of BESS failures continues to be limited.
• Battery OEMs and BESS integrators are often reluctant to disclose the cause of failure, and many investigation reports are not released to the public.
Of concern is the lag time in finding out a BESS has failed which then results in a large fire. For example, take the Elkhorn battery facility, Moss Landing, CA, which experienced a fire on 20/9/2022.
The investigation report was shared publicly by Tesla (the BESS manufacturer and integrator) and Pacific Gas & Electric (site owner). The investigation found that rainwater intrusion through the container caused electrical arcing within the system roper installation of a vent shield. As a confounding factor, insulation loss alarms were not properly escalated to the operator. Two days after the initial insulation alarms were recorded, smoke and fire were reported to the fire department.
We are a farming community with a 26 inch or more annual rainfall, water intrusion is highly likely. The Mangoplah BESS is to be located in an area that won’t have eyes on it 24/7 & thus it is unlikely any failure starting off with small smoke / fire will be be noticed until it is a larger fire, thus there must be appropriate measures in place for remote reporting & early actioning of any BESS failure.
With the Elkhorn BESS fire, early alarms could have prevented escalation of the initial failure into a fire that consumed the whole BESS unit and threatened the local area.
Government Regulators and Facility developers must prove/assure local communities that they are installing remote monitoring and shutdown systems to quickly detect and limit hazards, and that they can communicate critical information to emergency responders in a timely manner.
There are two main fire risks for BESS as outlined in this link:
https://www.firetrace.com/fire-protection-blog/the-dual-threat-of-bess-fire-safety
1) Fire and explosion risk due to thermal runaway
A well-studied hazard associated with BESS utilizing Li-ion batteries is the risk of thermal runaway. This phenomenon occurs when a failure or malfunction leads to an increase in battery temperature, triggering a reaction that further raises the temperature, creating a vicious cycle that can lead to fires. The compact and interconnected nature of BESS units exacerbates this risk, as a malfunction in a single component can have a domino effect, compromising the safety of the entire system. The implications of thermal runaway are not just limited to the potential for physical damage; they also pose significant safety threats to individuals and the environment.
Moreover, BESS units employing Li-ion batteries are vulnerable to off-gassing, a condition where stressed batteries release flammable gases. This issue often accompanies thermal runaway, intensifying safety concerns. Accumulated gases within BESS enclosures can create an explosive atmosphere, poised for ignition by a mere spark or surge in temperature. Notably, some fire suppression systems based on total flooding principles may inadvertently exacerbate this risk by failing to adequately vent these gases, potentially leading to severe explosions that threaten both human safety and environmental integrity, thereby highlighting the necessity for tailored safety measures.
2) Fire risk due to high voltage electronics
BESS fire risks extend beyond thermal runaway, with the Power Conversion System (PCS) presenting significant hazards. Critical PCS components, including transformers, inverters, and capacitor cabinets, are integral to the conversion and management of electrical energy within the storage system. These components can catch on fire due to electrical malfunctions, overheating from high power density, inadequate thermal management, and the stress from frequent charge/discharge cycles on system's components. Fires originating in the PCS can swiftly propagate to adjacent battery racks, rendering the extensive safety mechanisms designed to prevent thermal runaway ineffective. This scenario underscores the complexity of fire risks in BESS, highlighting the need for comprehensive fire protection strategies that encompass all system components.
Additionally, if a battery fire does occur, it releases toxic chemicals, including hydrogen fluoride and carbon monoxide which I would be not be happy send my local volunteer firefighting neighbours and friends in to fight.
There needs to be a design for a total flood fire suppression system for BESS units, as it's crucial to consider the risks associated with off-gassing. These systems must be engineered to not only suppress fires effectively but also to manage or mitigate the accumulation of flammable gases released during battery stress or failure. Strategies must be in place for gas detection and ventilation to prevent the formation of explosive atmospheres, thus ensuring the fire suppression approach addresses both immediate fire risks and the secondary dangers posed to responders, locals, agriculture produce and stock by off-gassing.
My other concerns:
1. The EIS fire history map is not accurate as it is missing 3 fires that I have attended on the property “Athlone” – the property the proposed BESS will be on.
a. One haystack fire
b. Fire started by slashing grass
c. Fire of unknown ignition amongst old machinery.
2. The 1952 fire, which engulfed the proposed site property “Athlone” ended up crossing the Murray River East of Albury about 100 km from its ignition point.
3. The proposed 100,000 litres on Mangoplah BESS water storage is totally inadequate
(The Deniliquin BESS has a 200,000-litre storage & Canberra BESS has 2 x 300,000 Litre water storage tanks on site.)
4. There is no water hydrant plan for the site
5. There is no emergency exit, there is only one way in/out
6. In Samsungs’ EIS, Appendix F.5 (The Bushfire Assessment Report) states the property is rated by the Australian Fire Danger Index as 80, which is extreme. The Fire Danger Index (FDI) is a number and rating used to show how dangerous fire conditions are in your area. Developed by Australia’s top fire scientists and the BOM, it takes into account temperature, humidity, wind, and how much fuel (dry grass, leaves, scrub) is on the ground. The higher the number, the more easily fires start and the faster they spread.
7. Proposed tree line on the western side is far too close as our predominant winds are from the west and all our past severe fires have come from the west.
8. We have no data on the failure rate of older facilities. Because this industry is so new (the first utility scale facility was commissioned in 2012) and the vast majority of facilities have come online in the past 4 years, there is almost no data on facilities that are 5 or more years old. Aging facilities will have more maintenance issues and more problems related to aging lithium-ion battery cells. Research has shown that lithium-ion batteries become less stable as they age and are more prone to undergo thermal runaway at lower threshold temperatures compared to newer batteries.
What will happen when billions of lithium-ion cells approach their end-of-life? Will we see more fire incidents? We don’t know because we haven’t gotten there yet.
9. Also concerning is that Samsung representatives advised recently that they do not have a decommissioning plan or agreement with the local land holder hosting the proposed Mangoplah BESS project.
10. The cost shifting of responsibility to the local volunteer Rural Fire Service to have the responsibility of babysitting this infrastructure for the next 25 years trying to prevent fire entering or escaping from the BESS is unrealistic and inequitable.
Please see the attachment for final concluding paragraphs which did not fit in this space, there is not a lot more. Thank you.