Marion Glover
Object
Marion Glover
Object
NUNDAH
,
Queensland
Message
Department of Planning, Industry and Environment
Major Projects Team
Attention: Anthony Ko
5.11.2019
Submission on Snowy 2.0 Main Works Environmental Impact Statement
I, Marion Glover, wish to indicate my strong opposition to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS). The scale and intensity of environmental impact described in the EIS is inappropriate in any sensitive sub alpine region, let alone Kosciuszko National Park (KNP), one of our nation’s most iconic, National Heritage Listed national parks.
In addition to the unacceptable environmental impacts on KNP, the fractured assessment process seems designed to conceal the catastrophic extent of environmental impacts and there is a district lack of credible consideration of less expensive, lower impact alternatives.
Claims about energy storage potential are dubious and the excessive cost will be paid for by the Australian public, the ultimate owners of the Snowy Hydro scheme.
These failures clearly demonstrate that the Snowy 2.0 project does not meet the standards required of Environmentally Sustainable Development and accordingly the project should be refused by the Minister for Planning.
The project is of vast scale and the quantity of documentation makes it very difficult to address all my/our concerns about the project. Issues of particular concern are described below:
Environmental impacts
The EIS repeatedly asserts that the Snowy 2.0 project will have a minor impact on KNP on the basis that the development footprint represents approximately 0.25% of the total area of the park. I/we consider this assessment to be utterly incorrect for the following reasons:
• The “Project Area”, as depicted in the EIS, covers approximately 50 km by 50 km (250,000 hectares), which is a third of KNP - an area twice the size of Greater Sydney.
• While KNP is one of the largest National Parks in NSW (690,000 hectares), the portion containing sub-alpine habitats, the areas to be destroyed by Snowy 2.0, is much smaller. This sub-alpine area has some of the rarest habitat in Australia, and will prove increasingly important for the retreat of alpine species affected by the heating climate. These rare habitats provide the appropriate context for assessing the adverse environmental impacts of Snowy 2.0, not the lower altitude landscapes that characterise the majority of KNP.
• This construction will be largest ever proposed loss of critically important habitats in a NSW National Park. The EIS acknowledges that the construction footprint will ‘disturb’ 1,680 hectares, clear 1,053 hectares of native vegetation, and destroy 992 ha of threatened species habitat (threatened fauna, threatened flora and Threatened Ecological Communities). The construction footprint acknowledged in the EIS substantially understates the full extent of permanent damage outside the heavy construction zones, including Talbingo and Tantangara Reservoirs, 100 kms of new and upgraded roads, 10 kms of transmission lines with a 120 metre-wide easement swathe, ground water depleted areas above the tunnels, construction camps (for 2,100 workers) and multiple works areas. When all these areas are taken into account, Snowy 2.0 will permanently damage more than 10,000 ha of KNP (100 square kms), rather than the claimed 1,680 ha.
• No development of this scale or intensity is appropriate in the sensitive habitats of a declared conservation reserve. The issue should not be whether the impacts of a proposal of this scale and intensity can be ‘mitigated’, offset or otherwise approved under the Environmental Planning and Assessment Act framework. On the contrary, such a proposal simply should not be contemplated in an internationally renowned conservation reserve in the first place.
The project requires tunnelling through 27 kms of rock, large scale quarrying, road building and widening and the establishment of large accommodation and construction sites. The EIS does not provide a credible account of how 14 million cubic metres of spoil, some of which is heavily contaminated by asbestos and acidic compounds, can be disposed in KNP without further significant environmental impacts. It is clear that much of the excavated materials will be used in ‘landscaping’ works that will further exacerbate the damage to the Park. Unbelievably, over 8 million cubic metres is to be dumped in the active storage areas of Talbingo and Tantangara Reservoirs, depleting their capacities. How could approval be given for anyone to dump waste material, some of which is contaminated, in a National Park, let alone 14,000,000 m3 - enough to cover a football field to a height of 3 km?
The EIS describes extensive impacts on water dependant habitats and species through disruption to ground water systems by the tunnelling as well as in works beside 8 kms of the Yarrangobilly River.
Watertable drawdown is predicted to be in excess of 50 m above the tunnel in areas of high hydraulic conductivity (Gooandra Volcanics). The drawdown at 3 km either side of the tunnel is still 0.5 m in the western plateau. This will have a catastrophic impact on the environment along sections of the 27 km tunnel, will dry up existing creeks, impact the local fish and animals and reduce inflows to the reservoirs and hence water releases.
It is remarkable that Snowy Hydro would show such disregard for the protection of water dependant ecosystems not just in alpine areas but at the headwaters of our major waterways. I/we do not accept the assertion that such impacts are ‘acceptable’. Experience demonstrates that once ground water systems are disrupted by mining activities the damage is irreversible and can become even more extensive over time.
Snowy 2.0 will disperse pest species (including redfin perch, eastern gambusia, wild goldfish, Epizootic Haematopoietic Necrosis Virus (EHNV) and elodea weed) throughout the waterways of KNP and downstream. Redfin is a Class One Noxious Pest - it is illegal to transfer Redfin between waterways in NSW. Snowy Hydro acknowledges that it is inevitable that these noxious species will be transferred from Talbingo to Tantangara. Establishment of the dominant Redfin Perch will be to the detriment of both recreational anglers and significant populations of threatened native fish.
Even worse than it being accepted that these noxious species will be transferred to Tantangara, it is highly doubtful that the barrier and filtration systems proposed by Snowy Hydro will stop their eventual transfer downstream to the Murrumbidgee River and Lake Eucumbene and thence throughout the rest of the Snowy Scheme and downstream rivers (Snowy, Murrumbidgee and Murray).
One of KNP’s core values is the sense of wilderness and solitude unique to alpine landscapes. These aesthetic qualities, and the experience of visitors, will be seriously diminished by the increases in roads, permanent large structures and especially the transmission lines. The project will not only impact directly on the areas trashed by the project - the overall sense and experience of the Park landscape will be damaged forever. The implication in the EIS that the community will regard the proposed infrastructure as evidence of the nation’s engineering prowess offers hollow recompense for the loss of the Park’s unique aesthetic qualities.
Minimal contribution to renewable energy
Snowy Hydro claims that Snowy 2.0 will play a pivotal role in stabilising the national energy market as new renewable generation is added to the grid. I/we don’t not accept that such claims justify the extent and severity of environmental destruction that the project will cause to KNP, especially in the absence of a credible assessment of alternative ways of providing this service. In any case, the data provided in the EIS seriously undermines the claimed benefits of the project. Specifically:
• Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
• For the next decade or so most pumping electricity will come from coal-fired power stations, not renewables, belying the claim that Snowy 2.0 will ‘store’ electricity from renewable generators.
• The claimed 350 GWh would only be available in the most exceptional of circumstances, requiring the top reservoir (Tantangara) to be full. If the full volume was used, at least one-third of the water couldn’t ‘fit’ within the smaller capacity of the lower reservoir (Talbingo) and would be discharged to Blowering and ‘lost’ to the Snowy 2.0 system. If Talbingo were not empty (historically it is kept near full to provide for operation of the Tumut 3 pumped hydro station), then most of the water from Tantangara would be discharged to Blowering and ‘lost’ to Snowy 2.0.
• The practical recyclable capacity of Snowy 2.0 is considerably less than the claimed 350 GWh.
• Whenever Tantangara were emptied, it would then require several months of pumping to be returned to full supply.
• If Snowy 2.0 ever generated its claimed 350 GWh of energy, it would take 500 GWh of pumping energy to re-charge, incurring 150 GWh of losses.
Uneconomic
It is clear that the cost of Snowy 2.0 will be many times greater than the original $2 billion and then $3.8 billion estimates – a single contract for $5.1 billion has recently been awarded. It is likely that the project, including transmission, will be $10 billion, or even more. At anything approaching this amount the project is totally uneconomic.
Conclusion
The Snowy 2.0 project, as described in the Main Works EIS, does not meet the principles of Ecologically Sustainable Development as mandated in the Environmental Planning and Assessment Act. In short, the staggering scale and severity of environmental impacts are by no means commensurate with the environmental, economic and community benefits of the project.
Yours sincerely, Marion Glover.
Major Projects Team
Attention: Anthony Ko
5.11.2019
Submission on Snowy 2.0 Main Works Environmental Impact Statement
I, Marion Glover, wish to indicate my strong opposition to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS). The scale and intensity of environmental impact described in the EIS is inappropriate in any sensitive sub alpine region, let alone Kosciuszko National Park (KNP), one of our nation’s most iconic, National Heritage Listed national parks.
In addition to the unacceptable environmental impacts on KNP, the fractured assessment process seems designed to conceal the catastrophic extent of environmental impacts and there is a district lack of credible consideration of less expensive, lower impact alternatives.
Claims about energy storage potential are dubious and the excessive cost will be paid for by the Australian public, the ultimate owners of the Snowy Hydro scheme.
These failures clearly demonstrate that the Snowy 2.0 project does not meet the standards required of Environmentally Sustainable Development and accordingly the project should be refused by the Minister for Planning.
The project is of vast scale and the quantity of documentation makes it very difficult to address all my/our concerns about the project. Issues of particular concern are described below:
Environmental impacts
The EIS repeatedly asserts that the Snowy 2.0 project will have a minor impact on KNP on the basis that the development footprint represents approximately 0.25% of the total area of the park. I/we consider this assessment to be utterly incorrect for the following reasons:
• The “Project Area”, as depicted in the EIS, covers approximately 50 km by 50 km (250,000 hectares), which is a third of KNP - an area twice the size of Greater Sydney.
• While KNP is one of the largest National Parks in NSW (690,000 hectares), the portion containing sub-alpine habitats, the areas to be destroyed by Snowy 2.0, is much smaller. This sub-alpine area has some of the rarest habitat in Australia, and will prove increasingly important for the retreat of alpine species affected by the heating climate. These rare habitats provide the appropriate context for assessing the adverse environmental impacts of Snowy 2.0, not the lower altitude landscapes that characterise the majority of KNP.
• This construction will be largest ever proposed loss of critically important habitats in a NSW National Park. The EIS acknowledges that the construction footprint will ‘disturb’ 1,680 hectares, clear 1,053 hectares of native vegetation, and destroy 992 ha of threatened species habitat (threatened fauna, threatened flora and Threatened Ecological Communities). The construction footprint acknowledged in the EIS substantially understates the full extent of permanent damage outside the heavy construction zones, including Talbingo and Tantangara Reservoirs, 100 kms of new and upgraded roads, 10 kms of transmission lines with a 120 metre-wide easement swathe, ground water depleted areas above the tunnels, construction camps (for 2,100 workers) and multiple works areas. When all these areas are taken into account, Snowy 2.0 will permanently damage more than 10,000 ha of KNP (100 square kms), rather than the claimed 1,680 ha.
• No development of this scale or intensity is appropriate in the sensitive habitats of a declared conservation reserve. The issue should not be whether the impacts of a proposal of this scale and intensity can be ‘mitigated’, offset or otherwise approved under the Environmental Planning and Assessment Act framework. On the contrary, such a proposal simply should not be contemplated in an internationally renowned conservation reserve in the first place.
The project requires tunnelling through 27 kms of rock, large scale quarrying, road building and widening and the establishment of large accommodation and construction sites. The EIS does not provide a credible account of how 14 million cubic metres of spoil, some of which is heavily contaminated by asbestos and acidic compounds, can be disposed in KNP without further significant environmental impacts. It is clear that much of the excavated materials will be used in ‘landscaping’ works that will further exacerbate the damage to the Park. Unbelievably, over 8 million cubic metres is to be dumped in the active storage areas of Talbingo and Tantangara Reservoirs, depleting their capacities. How could approval be given for anyone to dump waste material, some of which is contaminated, in a National Park, let alone 14,000,000 m3 - enough to cover a football field to a height of 3 km?
The EIS describes extensive impacts on water dependant habitats and species through disruption to ground water systems by the tunnelling as well as in works beside 8 kms of the Yarrangobilly River.
Watertable drawdown is predicted to be in excess of 50 m above the tunnel in areas of high hydraulic conductivity (Gooandra Volcanics). The drawdown at 3 km either side of the tunnel is still 0.5 m in the western plateau. This will have a catastrophic impact on the environment along sections of the 27 km tunnel, will dry up existing creeks, impact the local fish and animals and reduce inflows to the reservoirs and hence water releases.
It is remarkable that Snowy Hydro would show such disregard for the protection of water dependant ecosystems not just in alpine areas but at the headwaters of our major waterways. I/we do not accept the assertion that such impacts are ‘acceptable’. Experience demonstrates that once ground water systems are disrupted by mining activities the damage is irreversible and can become even more extensive over time.
Snowy 2.0 will disperse pest species (including redfin perch, eastern gambusia, wild goldfish, Epizootic Haematopoietic Necrosis Virus (EHNV) and elodea weed) throughout the waterways of KNP and downstream. Redfin is a Class One Noxious Pest - it is illegal to transfer Redfin between waterways in NSW. Snowy Hydro acknowledges that it is inevitable that these noxious species will be transferred from Talbingo to Tantangara. Establishment of the dominant Redfin Perch will be to the detriment of both recreational anglers and significant populations of threatened native fish.
Even worse than it being accepted that these noxious species will be transferred to Tantangara, it is highly doubtful that the barrier and filtration systems proposed by Snowy Hydro will stop their eventual transfer downstream to the Murrumbidgee River and Lake Eucumbene and thence throughout the rest of the Snowy Scheme and downstream rivers (Snowy, Murrumbidgee and Murray).
One of KNP’s core values is the sense of wilderness and solitude unique to alpine landscapes. These aesthetic qualities, and the experience of visitors, will be seriously diminished by the increases in roads, permanent large structures and especially the transmission lines. The project will not only impact directly on the areas trashed by the project - the overall sense and experience of the Park landscape will be damaged forever. The implication in the EIS that the community will regard the proposed infrastructure as evidence of the nation’s engineering prowess offers hollow recompense for the loss of the Park’s unique aesthetic qualities.
Minimal contribution to renewable energy
Snowy Hydro claims that Snowy 2.0 will play a pivotal role in stabilising the national energy market as new renewable generation is added to the grid. I/we don’t not accept that such claims justify the extent and severity of environmental destruction that the project will cause to KNP, especially in the absence of a credible assessment of alternative ways of providing this service. In any case, the data provided in the EIS seriously undermines the claimed benefits of the project. Specifically:
• Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
• For the next decade or so most pumping electricity will come from coal-fired power stations, not renewables, belying the claim that Snowy 2.0 will ‘store’ electricity from renewable generators.
• The claimed 350 GWh would only be available in the most exceptional of circumstances, requiring the top reservoir (Tantangara) to be full. If the full volume was used, at least one-third of the water couldn’t ‘fit’ within the smaller capacity of the lower reservoir (Talbingo) and would be discharged to Blowering and ‘lost’ to the Snowy 2.0 system. If Talbingo were not empty (historically it is kept near full to provide for operation of the Tumut 3 pumped hydro station), then most of the water from Tantangara would be discharged to Blowering and ‘lost’ to Snowy 2.0.
• The practical recyclable capacity of Snowy 2.0 is considerably less than the claimed 350 GWh.
• Whenever Tantangara were emptied, it would then require several months of pumping to be returned to full supply.
• If Snowy 2.0 ever generated its claimed 350 GWh of energy, it would take 500 GWh of pumping energy to re-charge, incurring 150 GWh of losses.
Uneconomic
It is clear that the cost of Snowy 2.0 will be many times greater than the original $2 billion and then $3.8 billion estimates – a single contract for $5.1 billion has recently been awarded. It is likely that the project, including transmission, will be $10 billion, or even more. At anything approaching this amount the project is totally uneconomic.
Conclusion
The Snowy 2.0 project, as described in the Main Works EIS, does not meet the principles of Ecologically Sustainable Development as mandated in the Environmental Planning and Assessment Act. In short, the staggering scale and severity of environmental impacts are by no means commensurate with the environmental, economic and community benefits of the project.
Yours sincerely, Marion Glover.
jennifer slavec
Object
jennifer slavec
Object
AVALON BEACH
,
New South Wales
Message
I strongly object to the Snowy 2.0 project. I am alarmed at the widespread destruction of delicate sub-alpine habitat. We have enormous problems with the river systems and this area is the headwater for many large rivers. The water table will be disturbed and large quantities of tunnel debris will be dumped. The contribution to renewable energy is debatable. I am disgusted by this government's lack of credibility with regard to National Parks. They are supposed to be protected. We members of the public expect that the government would respect their protection but instead this government is pushing forward infrastructure at all costs. There is hardly any wilderness remaining. I am most concerned by the upcoming loss of a unique, irreplaceable piece of our planet.
Name Withheld
Object
Name Withheld
Object
ALBURY
,
New South Wales
Message
Please refer to my attached submission.
Attachments
Name Withheld
Object
Name Withheld
Object
ALBURY
,
New South Wales
Message
I wish to indicate our strong opposition to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS).
Please refer to the attached document for my full submission
Please refer to the attached document for my full submission
Attachments
Name Withheld
Object
Name Withheld
Object
DALGETY
,
New South Wales
Message
I've taken a good look at the EIS and conclude that there is a large amount of scientific rigor omitted that may negate many of the proposals within it. I find it astonishing that the EIS is so lengthy, often repeating rhetoric (eg. “it is just 0.25% of the park”) and laden with emotive images most of which are not linked to text or even identified, yet objection submission is limited to 10k characters.
Snowy Hydro has bombarded the public with emotive documents, claiming that Snowy 2.0 must go ahead because it is in the public interest to reduce power bills. eg. One defense of criticism absurdly compares the footprint in the national park to the Sydney Opera House; two very different projects in different eras. Emotion should be omitted and decisions back by peer reviewed science only. The unreasonable behaviour displayed by Snowy Hydro in the EIS and in associated public statements is repetitive, tantamount to bullying as defined by the Premier’s Dignity and Respect Charter.
My central objection centres around the prevention of feral fauna and/or introduced native predator species and pathogens in the event of water, polluted by uphill transfer into Tantangra from Talbingo, flowing into Eucumbene; in the event of overtopping into the Eucumbene R (or future environmental release) and/or water transfer into Jindabyne, the Snowy System is effected by, so far unmeasured and unmitigated invasion, both downstream and in the montane areas. An unacceptable and preventable alteration of what is left of the natural Snowy R. environment.
Two fauna species that will pose grave risk to Stocky Galaxias and Macquarie Perch are Climbing Galaxias and Redfin Perch. Attempts to address this problem appear severely inadequate. As I understand it mitigation measures for the preservation of fish species have been deemed too expensive in cost and environmental change and have been rejected.
Further, epizootic haematopoietic necrosis virus (EHNV) is widely studied. It will be transferred from the Tumut River Valley by pumping and decimate native species.
Macquarie Perch (EPBC listed species) and Stocky Galaxias (pending listing) must be protected on ethical grounds regardless of non-compulsion due to pending processes.
These species populations (and possibly more that have been omitted) knowingly suffering extinction is an unacceptable consequence of this project.
There are numerous impacts on ecology that are apparent. It appears that elements of the impact have divided between Transgrid, Snowy Hydro (3 separate EIS stages) and the governments in order to strategically confuse and exhaust concerned citizens for the benefit of a politically influenced agenda. Numerous alternatives have been proposed by prominent academics, yet are ridiculed by Snowy Hydro. The studies are economically viable, environmentally more responsible (particularly not in national parks) and provide socially acceptable assets (jobs, recreation, etc).
I put it to you that the damage to the ancient national park has been significant in the past 200 years (particularly in the past 70 years) and it must be left alone to recover as best as possible without the impacts posed by this project. More responsible alternative projects are viable.
Snowy Hydro has bombarded the public with emotive documents, claiming that Snowy 2.0 must go ahead because it is in the public interest to reduce power bills. eg. One defense of criticism absurdly compares the footprint in the national park to the Sydney Opera House; two very different projects in different eras. Emotion should be omitted and decisions back by peer reviewed science only. The unreasonable behaviour displayed by Snowy Hydro in the EIS and in associated public statements is repetitive, tantamount to bullying as defined by the Premier’s Dignity and Respect Charter.
My central objection centres around the prevention of feral fauna and/or introduced native predator species and pathogens in the event of water, polluted by uphill transfer into Tantangra from Talbingo, flowing into Eucumbene; in the event of overtopping into the Eucumbene R (or future environmental release) and/or water transfer into Jindabyne, the Snowy System is effected by, so far unmeasured and unmitigated invasion, both downstream and in the montane areas. An unacceptable and preventable alteration of what is left of the natural Snowy R. environment.
Two fauna species that will pose grave risk to Stocky Galaxias and Macquarie Perch are Climbing Galaxias and Redfin Perch. Attempts to address this problem appear severely inadequate. As I understand it mitigation measures for the preservation of fish species have been deemed too expensive in cost and environmental change and have been rejected.
Further, epizootic haematopoietic necrosis virus (EHNV) is widely studied. It will be transferred from the Tumut River Valley by pumping and decimate native species.
Macquarie Perch (EPBC listed species) and Stocky Galaxias (pending listing) must be protected on ethical grounds regardless of non-compulsion due to pending processes.
These species populations (and possibly more that have been omitted) knowingly suffering extinction is an unacceptable consequence of this project.
There are numerous impacts on ecology that are apparent. It appears that elements of the impact have divided between Transgrid, Snowy Hydro (3 separate EIS stages) and the governments in order to strategically confuse and exhaust concerned citizens for the benefit of a politically influenced agenda. Numerous alternatives have been proposed by prominent academics, yet are ridiculed by Snowy Hydro. The studies are economically viable, environmentally more responsible (particularly not in national parks) and provide socially acceptable assets (jobs, recreation, etc).
I put it to you that the damage to the ancient national park has been significant in the past 200 years (particularly in the past 70 years) and it must be left alone to recover as best as possible without the impacts posed by this project. More responsible alternative projects are viable.
James Smith
Support
James Smith
Support
TALBINGO
,
New South Wales
Message
In response to the EIS for the Snowy 2.0 Main Works I would like to raise the following points.
1. Tunnel Boring Machine: This will cause powder & dust, unlike drill & blast method, will it cause a film on Talbingo & Tantangara Dams when the spoil is placed in the dams. What effect will this cause on ski / fishing boats and on the general fish population
2. Asbestos: This is found on the western side of Talbingo Dam, is it on the eastern side as well? What measures are in place that it won't enter water with the spoil in both solid & powder form?
3. Spoil: What guarantee is there that in the long term that there will be no effect on fish, both breeding & life expectancy for the long term of the tourist trade?
4. Will boring cause any damage to Yarrangobilly Caves, the water table and the minerals that create the stalagmites & stalactites? What guarantee that this will not harm or change the water quality to affect the caves long term as they have large visitor numbers and it will have a huge impact on tourism in the area if they are affected adversely.
5. The area is well known for its copper. Will a small or large amount of copper be in the spoil in either dust or solid form. What are the long term effects on water qulity and fish quality?
6. With large amounts of trucks using Link Road and the snow season increase in traffic, this will affect the tourists going to the snow with a build up of traffic around the National Park booth and the Selwyn Snowfields turn off. What measures will be in place?
1. Tunnel Boring Machine: This will cause powder & dust, unlike drill & blast method, will it cause a film on Talbingo & Tantangara Dams when the spoil is placed in the dams. What effect will this cause on ski / fishing boats and on the general fish population
2. Asbestos: This is found on the western side of Talbingo Dam, is it on the eastern side as well? What measures are in place that it won't enter water with the spoil in both solid & powder form?
3. Spoil: What guarantee is there that in the long term that there will be no effect on fish, both breeding & life expectancy for the long term of the tourist trade?
4. Will boring cause any damage to Yarrangobilly Caves, the water table and the minerals that create the stalagmites & stalactites? What guarantee that this will not harm or change the water quality to affect the caves long term as they have large visitor numbers and it will have a huge impact on tourism in the area if they are affected adversely.
5. The area is well known for its copper. Will a small or large amount of copper be in the spoil in either dust or solid form. What are the long term effects on water qulity and fish quality?
6. With large amounts of trucks using Link Road and the snow season increase in traffic, this will affect the tourists going to the snow with a build up of traffic around the National Park booth and the Selwyn Snowfields turn off. What measures will be in place?
Ralph Cartwright
Object
Ralph Cartwright
Object