Name Withheld
Object
Name Withheld
Object
DUBBO
,
New South Wales
Message
I wish to raise serious concerns regarding the adequacy of emergency response preparedness and capability associated with the proposed Battery Energy Storage System (BESS) development.
In particular, I do not believe sufficient evidence has been provided demonstrating that local and regional emergency response agencies possess the personnel, equipment, specialist training, infrastructure, resources, water supply capability, hazardous materials response capacity, or operational procedures necessary to safely respond to a large-scale lithium-ion battery thermal runaway event.
Given the scale and complexity of modern utility-scale BESS infrastructure, this issue represents a significant public safety concern that warrants detailed independent assessment prior to any project approval.
Thermal Runaway Risks
Thermal runaway events involving lithium-ion battery systems are widely recognised internationally as presenting highly complex and hazardous emergency scenarios. These events may involve:
prolonged fires lasting many hours or days
rapid reignition risks
explosion potential
production of toxic and corrosive gases
significant water demand for cooling and exposure protection
difficult access conditions for responders
environmental contamination risks
evacuation and exclusion zone requirements.
Potential gases generated during thermal runaway events may include:
hydrogen fluoride (HF)
hydrogen chloride (HCl)
carbon monoxide (CO)
volatile organic compounds
flammable gases including hydrogen.
Hydrogen fluoride is of particular concern due to its toxicity, corrosive properties, and ability to travel in smoke plumes under certain atmospheric conditions.
Concerns Regarding Emergency Response Capability
The project documentation does not appear to adequately demonstrate that emergency services within the region possess the specialist capability required to respond to a utility-scale BESS incident.
The following concerns require detailed assessment and public disclosure:
Local Firefighting Capability
It remains unclear whether local firefighting resources possess:
specialist lithium-ion battery firefighting training
thermal imaging equipment
gas monitoring capability
hazardous materials response capability
sufficient breathing apparatus resources
specialist foam or suppression systems
prolonged incident management capability
sufficient tanker and water supply capacity.
Many regional and rural brigades are volunteer-based and may not be equipped to manage complex industrial battery incidents involving prolonged thermal runaway.
Water Supply and Duration of Fire Events
Large-scale BESS incidents internationally have demonstrated that significant quantities of water may be required over extended periods to cool battery systems and protect adjacent infrastructure.
The project documentation does not clearly identify:
available firefighting water volumes
guaranteed water supply arrangements
refill logistics during prolonged incidents
mutual aid arrangements
contingency planning during drought conditions
impacts on surrounding communities and agricultural water resources.
Toxic Smoke and Community Evacuation
The project documentation appears to inadequately address:
toxic plume modelling
evacuation trigger thresholds
community notification systems
exclusion zone determination
protection of nearby residents
impacts to vulnerable persons
livestock exposure risks
school bus routes and transport corridors.
The potential for toxic smoke movement toward neighbouring rural residences and communities requires far greater scrutiny.
Reliance on External Specialist Resources
It is unclear whether the emergency response strategy relies upon specialist resources located significant distances away from the project area.
If specialist hazardous materials or industrial firefighting resources are required from metropolitan or regional centres, serious questions arise regarding:
response times
escalation procedures
interim containment capability
responder safety during initial attack phases
capacity to manage incidents overnight or during severe weather conditions.
Cumulative Renewable Energy Zone (REZ) Risks
This project must not be assessed in isolation.
Where multiple BESS facilities, substations, transmission infrastructure and renewable energy developments are proposed across a region, cumulative emergency response demands may exceed the capability of local emergency services.
The Department must assess:
regional emergency response capacity
cumulative hazardous materials risk
cumulative bushfire ignition potential
simultaneous incident scenarios
strain on volunteer emergency services
long-term emergency management funding obligations.
Inadequate Demonstration of Preparedness
The project should not proceed unless the proponent can clearly demonstrate:
independently verified emergency response capability
formal consultation with Fire and Rescue NSW, NSW Rural Fire Service, NSW Ambulance and NSW Police
detailed thermal runaway response procedures
publicly available emergency management plans
specialist responder training commitments
ongoing funding arrangements for emergency services
independent peer review of emergency response modelling
demonstrated access to specialist firefighting resources within acceptable response timeframes.
The proponent should also be required to contribute financially toward the capability uplift of local and regional emergency response agencies. This should include consideration of:
specialist lithium-ion battery fire training
hazardous materials response capability
thermal imaging and gas monitoring equipment
breathing apparatus capability
water supply and tanker capacity
emergency response planning and exercises
additional staffing and operational support.
If renewable energy proponents are not required to contribute toward these additional emergency response burdens, the result is effectively cost shifting onto volunteer emergency services, government agencies, local councils and ultimately the broader community and taxpayers.
General statements that emergency risks can be “managed” are insufficient for infrastructure of this nature and scale.
Until these matters are comprehensively addressed, I do not believe the project has demonstrated that risks to public safety, emergency responders, neighbouring landholders, and surrounding communities can be adequately managed.
In particular, I do not believe sufficient evidence has been provided demonstrating that local and regional emergency response agencies possess the personnel, equipment, specialist training, infrastructure, resources, water supply capability, hazardous materials response capacity, or operational procedures necessary to safely respond to a large-scale lithium-ion battery thermal runaway event.
Given the scale and complexity of modern utility-scale BESS infrastructure, this issue represents a significant public safety concern that warrants detailed independent assessment prior to any project approval.
Thermal Runaway Risks
Thermal runaway events involving lithium-ion battery systems are widely recognised internationally as presenting highly complex and hazardous emergency scenarios. These events may involve:
prolonged fires lasting many hours or days
rapid reignition risks
explosion potential
production of toxic and corrosive gases
significant water demand for cooling and exposure protection
difficult access conditions for responders
environmental contamination risks
evacuation and exclusion zone requirements.
Potential gases generated during thermal runaway events may include:
hydrogen fluoride (HF)
hydrogen chloride (HCl)
carbon monoxide (CO)
volatile organic compounds
flammable gases including hydrogen.
Hydrogen fluoride is of particular concern due to its toxicity, corrosive properties, and ability to travel in smoke plumes under certain atmospheric conditions.
Concerns Regarding Emergency Response Capability
The project documentation does not appear to adequately demonstrate that emergency services within the region possess the specialist capability required to respond to a utility-scale BESS incident.
The following concerns require detailed assessment and public disclosure:
Local Firefighting Capability
It remains unclear whether local firefighting resources possess:
specialist lithium-ion battery firefighting training
thermal imaging equipment
gas monitoring capability
hazardous materials response capability
sufficient breathing apparatus resources
specialist foam or suppression systems
prolonged incident management capability
sufficient tanker and water supply capacity.
Many regional and rural brigades are volunteer-based and may not be equipped to manage complex industrial battery incidents involving prolonged thermal runaway.
Water Supply and Duration of Fire Events
Large-scale BESS incidents internationally have demonstrated that significant quantities of water may be required over extended periods to cool battery systems and protect adjacent infrastructure.
The project documentation does not clearly identify:
available firefighting water volumes
guaranteed water supply arrangements
refill logistics during prolonged incidents
mutual aid arrangements
contingency planning during drought conditions
impacts on surrounding communities and agricultural water resources.
Toxic Smoke and Community Evacuation
The project documentation appears to inadequately address:
toxic plume modelling
evacuation trigger thresholds
community notification systems
exclusion zone determination
protection of nearby residents
impacts to vulnerable persons
livestock exposure risks
school bus routes and transport corridors.
The potential for toxic smoke movement toward neighbouring rural residences and communities requires far greater scrutiny.
Reliance on External Specialist Resources
It is unclear whether the emergency response strategy relies upon specialist resources located significant distances away from the project area.
If specialist hazardous materials or industrial firefighting resources are required from metropolitan or regional centres, serious questions arise regarding:
response times
escalation procedures
interim containment capability
responder safety during initial attack phases
capacity to manage incidents overnight or during severe weather conditions.
Cumulative Renewable Energy Zone (REZ) Risks
This project must not be assessed in isolation.
Where multiple BESS facilities, substations, transmission infrastructure and renewable energy developments are proposed across a region, cumulative emergency response demands may exceed the capability of local emergency services.
The Department must assess:
regional emergency response capacity
cumulative hazardous materials risk
cumulative bushfire ignition potential
simultaneous incident scenarios
strain on volunteer emergency services
long-term emergency management funding obligations.
Inadequate Demonstration of Preparedness
The project should not proceed unless the proponent can clearly demonstrate:
independently verified emergency response capability
formal consultation with Fire and Rescue NSW, NSW Rural Fire Service, NSW Ambulance and NSW Police
detailed thermal runaway response procedures
publicly available emergency management plans
specialist responder training commitments
ongoing funding arrangements for emergency services
independent peer review of emergency response modelling
demonstrated access to specialist firefighting resources within acceptable response timeframes.
The proponent should also be required to contribute financially toward the capability uplift of local and regional emergency response agencies. This should include consideration of:
specialist lithium-ion battery fire training
hazardous materials response capability
thermal imaging and gas monitoring equipment
breathing apparatus capability
water supply and tanker capacity
emergency response planning and exercises
additional staffing and operational support.
If renewable energy proponents are not required to contribute toward these additional emergency response burdens, the result is effectively cost shifting onto volunteer emergency services, government agencies, local councils and ultimately the broader community and taxpayers.
General statements that emergency risks can be “managed” are insufficient for infrastructure of this nature and scale.
Until these matters are comprehensively addressed, I do not believe the project has demonstrated that risks to public safety, emergency responders, neighbouring landholders, and surrounding communities can be adequately managed.
Name Withheld
Comment
Name Withheld
Comment
BRAYTON
,
New South Wales
Message
Submission regarding Canyonleigh Battery Energy Storage System (SSD-78247462)
Dear Department,
I am a nearby resident and landholder and wish to provide comments regarding the proposed Canyonleigh Battery Energy Storage System.
Overall, of the energy and infrastructure projects proposed in our district, this proposal is the one I am least concerned about in principle. I recognise the role battery storage can play in improving electricity reliability and supporting energy transition.
However, I ask that this project not be assessed in isolation and that the following matters receive particular attention.
1. Cumulative impacts across multiple nearby projects
Residents in this area are already facing cumulative change from multiple existing and proposed developments.
This proposal should be assessed together with:
* the proposed Wattle Creek solar development (approximately 500,000 panels); and
* the proposed gas-fired power station near the Canyonleigh Road substation area.
Each individual project may appear manageable, but local residents experience the combined effect of:
* construction traffic,
* heavy vehicle movements,
* visual change,
* emergency management pressures,
* road wear,
* cumulative noise and disruption.
I request a specific cumulative assessment that models overlapping construction periods and combined impacts rather than considering each project independently.
2. Canyonleigh Road suitability and traffic impacts
Canyonleigh Road is a rural road and should be assessed based on real local conditions.
The assessment should address:
* road width and condition,
* dust,
* heavy vehicle passing opportunities,
* pavement deterioration,
* safe access for residents,
* maintenance responsibilities,
* impacts during prolonged wet weather.
Road upgrades should not only facilitate project access but maintain safe conditions for residents throughout construction and operation.
3. Flood access and emergency response
A particular concern is that Canyonleigh Road experiences flooding.
The project should demonstrate:
* how emergency access will occur during flood conditions,
* whether the site can be safely managed if roads are temporarily inaccessible,
* whether fire response assumptions remain valid when flood isolation occurs,
* what backup arrangements exist if emergency services cannot reach the site.
4. Fire response capability
Battery energy storage facilities require specialised emergency planning.
The assessment should clearly explain:
* firefighting water supply,
* access under adverse weather conditions,
* emergency isolation procedures,
* coordination with local emergency services,
* how emergency response assumptions account for flood-affected access.
5. Community confidence
I request that consent conditions include:
* advance notification of major construction periods,
* public reporting of road management measures,
* ongoing community communication.
Page 54 mentions the community engagement. I don’t think this reflects reality as we met with the company several times and I don’t see our views reflected there.
My intention is not to oppose the project in principle but to ensure that approval decisions properly reflect local road conditions, cumulative regional development pressures and practical emergency management realities.
I am particularly concerned that residents experience the combined effect of multiple projects at once, even where each project individually meets acceptable thresholds.
I acknowledge that the Environmental Impact Statement may address some of the matters raised above. However, I request that the Department carefully consider whether the assumptions and mitigation measures reflect actual local conditions, particularly cumulative regional development, the characteristics of Canyonleigh Road, flood access constraints and practical emergency response capability in this area.
Thank you for considering this submission.
Resident Canyonleigh Rd
Brayton NSW
Dear Department,
I am a nearby resident and landholder and wish to provide comments regarding the proposed Canyonleigh Battery Energy Storage System.
Overall, of the energy and infrastructure projects proposed in our district, this proposal is the one I am least concerned about in principle. I recognise the role battery storage can play in improving electricity reliability and supporting energy transition.
However, I ask that this project not be assessed in isolation and that the following matters receive particular attention.
1. Cumulative impacts across multiple nearby projects
Residents in this area are already facing cumulative change from multiple existing and proposed developments.
This proposal should be assessed together with:
* the proposed Wattle Creek solar development (approximately 500,000 panels); and
* the proposed gas-fired power station near the Canyonleigh Road substation area.
Each individual project may appear manageable, but local residents experience the combined effect of:
* construction traffic,
* heavy vehicle movements,
* visual change,
* emergency management pressures,
* road wear,
* cumulative noise and disruption.
I request a specific cumulative assessment that models overlapping construction periods and combined impacts rather than considering each project independently.
2. Canyonleigh Road suitability and traffic impacts
Canyonleigh Road is a rural road and should be assessed based on real local conditions.
The assessment should address:
* road width and condition,
* dust,
* heavy vehicle passing opportunities,
* pavement deterioration,
* safe access for residents,
* maintenance responsibilities,
* impacts during prolonged wet weather.
Road upgrades should not only facilitate project access but maintain safe conditions for residents throughout construction and operation.
3. Flood access and emergency response
A particular concern is that Canyonleigh Road experiences flooding.
The project should demonstrate:
* how emergency access will occur during flood conditions,
* whether the site can be safely managed if roads are temporarily inaccessible,
* whether fire response assumptions remain valid when flood isolation occurs,
* what backup arrangements exist if emergency services cannot reach the site.
4. Fire response capability
Battery energy storage facilities require specialised emergency planning.
The assessment should clearly explain:
* firefighting water supply,
* access under adverse weather conditions,
* emergency isolation procedures,
* coordination with local emergency services,
* how emergency response assumptions account for flood-affected access.
5. Community confidence
I request that consent conditions include:
* advance notification of major construction periods,
* public reporting of road management measures,
* ongoing community communication.
Page 54 mentions the community engagement. I don’t think this reflects reality as we met with the company several times and I don’t see our views reflected there.
My intention is not to oppose the project in principle but to ensure that approval decisions properly reflect local road conditions, cumulative regional development pressures and practical emergency management realities.
I am particularly concerned that residents experience the combined effect of multiple projects at once, even where each project individually meets acceptable thresholds.
I acknowledge that the Environmental Impact Statement may address some of the matters raised above. However, I request that the Department carefully consider whether the assumptions and mitigation measures reflect actual local conditions, particularly cumulative regional development, the characteristics of Canyonleigh Road, flood access constraints and practical emergency response capability in this area.
Thank you for considering this submission.
Resident Canyonleigh Rd
Brayton NSW