The EIS seriously understates the full environmental impact on the Park, which, when vegetation clearance, earthworks, dumping and damage to streams and water-dependant ecosystems are included will exceed 10,000 ha.
Even the EIS admits that the Main Works will ‘disturb’ 1,680 ha, clear 1,053 ha of native vegetation and destroy 992 ha of threatened species habitat.
14 million cubic metres of excavated spoil, some of which contains asbestos and/or is acidic, will be dumped in Kosciuszko National Park. Most of the spoil will go into Talbingo and Tantangara Reservoirs, decreasing their storage capacities, with the remainder to go into roads or to ‘landscape’ the park.
Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Under normal circumstances these would not be allowed within a National Park, so why under Snowy 2.0?
Two side-by-side high voltage transmission lines for 10 km through the Park, with a 120m wide easement swathe.
Snowy 2.0 requires tunnelling through 27 kms of rock. This will depress the water table in some sections by more than 50 m and have an impact for up to 2 kms either side of the tunnel. This will lead to montane streams and water dependant alpine bogs drying up, further impacting upon vulnerable habitats and native species. It will also lead to a reduction of inflows to Snowy reservoirs and downstream rivers. These river systems are already under threat from feral animals and global heating. Any works that threaten water quality and quantity must be avoided.
Not only is Snowy 2.0 environmental vandalism, it isn’t economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission.
Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why were these alternatives, together with batteries and other forms of storage, not explored before proposing construction of such a huge project within a National Park?
Never before has a project of such immense size and environmental destruction been proposed within a National Park.

Comments are in the attachments

1. AABR is not convinced that sufficient cost-benefit analysis has been done to ensure that this project is the best way of attaining pumped hydro for Australia, taking into account the environmental losses that are likely to occur. To gain social license for Snowy 2, the net environmental benefits and need must be much more thoroughly evaluated after consideration of environmental risk of this project and the availability of alternative projects

2. AABR is also not convinced of the commitment of the project to an appropriate level of ecological restoration. Despite some good work in rehabilitation in recent decades in the National Park, the predictability of rehabilitation or restoration outcomes is not sufficiently reliable to remove environmental risk associated with the Snowy 2 developments. Most industrial development in Australia have failed to attain acceptable restoration outcomes. Satisfactory results have only been attained where there is a very high commitment to restoration to the pre-existing natural condition - which is missing in the current Snowy 2 development proposal.

To gain social license for Snowy 2, the rehabilitation plan framework would need explicit commitment to a five-star recovery outcome for all sites in a manner consistent with the National Standards [Standards Reference Group SERA (2017) National Standards for the Practice of Ecological Restoration in Australia. Second Edition. Society for Ecological Restoration Australasia URL: http://www.seraustralasia.com/standards/home.html] as well as commit to adequate compensation for the inevitable net environmental damage of such a project. This compensation would need to be provided in the form of offsets that attain additional restoration of current degradation in Koscziusko National Park including the removal of feral horses and rehabilitation of damage to bogs and fens created by their presence.

Please see the attached submission on behalf of STEP Inc.
We oppose the project in its current form. The ability of the project to achieve its objectives have not been proven from the information provided to date.

Conservation impacts of Snowy 2.

The Snowy 2 concept is at face value not unattractive from a conservation viewpoint. We applaud the development of energy storage systems that can reinforce the advantages of renewable energy in avoiding the climate impacts of fossil fuelled electricity generators. But the impacts of land clearing, roads, accommodation camps, spoil dumps etc. for the major engineering works involved in Snowy 2 will be detrimental to the ecosystem protection values of Kosciuszko National Park, arguably the most important in NSW. These impacts must therefore be weighed against the benefits and alternatives, which is properly the function of an environmental impact assessment.

The option for many smaller alternative pump-storage sites, explored by Prof. Blakers of ANU, are acknowledged in the project summary document but dismissed without cost-benefit-impact analysis in that document. The Snowy 2 concept was apparently the thought-bubble of ex-Prime Minister Turnbull, prompted no doubt by SMC engineers.

Assurances of environmental protection or restoration for Kosciuszko National Park features and values under Snowy 2 are called into question by the erratic history of environmental management by the NSW Government. From 1889 to 1957, NSW over-issued summer grazing leases with the same gay abandon more recently recognisable with Murray-Darling water rights. Seasonal overstocking and damaging erosion followed the free-for-all pattern of gold-mining at Kiandra.

Fortunately, with the creation of Kosciusko State Park in 1944, the erosion impacts of overgrazing by sheep and cattle were recognised as incompatible with engineering aspects of plans for the Snowy Mountains Hydroelectric Scheme. A far-sighted program by the Soil Conservation Commission of soil stabilisation and revegetation eg. around Mt Twynam on the Main Range was established to protect catchments, streams and reservoirs against erosion and siltation.

After establishment of the NSW National Parks and Wildlife Service and Kosciusko National Park in 1967 a firmly conservation based program was pursued but steadily undermined over subsequent decades by resort over-development, run-down of NPWS staffing for scientific and wildlife management and political distortion of priorities. The most recent and damaging of such perverse priorities has been the Kosciuszko Wild Horse Heritage Act, placing higher protection priority for feral horses than on threatened native species. Horses, having bred to a population of around 6000 are, as with stock prior to 1944, again pugging streams and swamps, mobilising silt, destroying habitat for eg. the corroboree frog, driving macropods from valleys and plains along the Cascades-Tin mines track and now even threatening walkers with dangerous attack. The NSW Government’s failure to address this current management problem destroys credibility for the promise of environmental responsibility in developing Snowy 2.

Snowy 2 might indeed be beneficial, even essential, to address climate change but it will not be accepted as such unless rigorously and transparently assessed against decentralised energy storage options in terms of cost, benefit and impact.

The Ryde Gladesville Climate Change Action group is composed of over 650 people who are greatly concerned about climate change and the need to for urgent action to reduce our carbon emissions and move to 100% renewables by 2030.
We are, therefore, greatly concerned about the proposed Snowy Hydro 2.0 and strongly do not support it going ahead. Our reasons are as follows:
1. Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector. Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. It will also be a net consumer of electricity, which means that the carbon emissions for NSW will increase, not decrease.
2. The EIS has understated the full environmental impact on the Park. The vegetation clearance, earthworks, dumping and damage to water streams and water-dependent ecosystems will exceed 10,000 ha. Clearing of native vegetation (when we so desperately need to keep our trees) will destroy 992 ha of threatened species habitat.
3. Snowy 2.0 isn’t economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission. The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0.
4. Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why haven’t these, together with batteries and other forms of storage, been explored before proposing construction of such a huge project within a National Park?
5. Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Why, then, is this type of project being considered when normally no such project would be allowed in a National Park.
6. Noxious weeds and pests will be spread through the Park as a result of the works.

Pamela Reeves
Secretary
Ryde Gladesville Climate Change Action Group

Submission on Snowy Hydro 2.0
I am greatly concerned about the proposed Snowy Hydro 2.0 and do not support it going ahead. My reasons are as follows:
1. The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0.
2. Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector. Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. It will also be a net consumer of electricity, which means that the carbon emissions for NSW will increase, not decrease.
3. Snowy 2.0 isn’t economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission.
4. Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why haven’t these, together with batteries and other forms of storage, been explored before proposing construction of such a huge project within a National Park?
5. Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Normally, this type of project would not be allowed in a National Park. Why, then, is it being considered in Australia’s most frequently visited park?
6. The EIS has understated the full environmental impact on the Park. The vegetation clearance, earthworks, dumping and damage to water streams and water-dependent ecosystems will exceed 10,000 ha. Clearing of native vegetation (when we so desperately need to keep our trees) will destroy 992 ha of threatened species habitat.
7. Noxious weeds and pests will be spread through the Park.
This proposal is totally unacceptable. The destruction of large sections of the National Park for a badly thought out, environmentally destructive and economically unsound project cannot be justified.