There is a great need in Australia for more, abundant, responsibly produced and affordable electricity to be brought on stream - to serve the needs of growing communities and to help achieve our goals for carbon emission reduction. Solar energy, firmed with batteries, remains the quickest to build and deploy and most cost-effective solution when it comes to new energy production. Ask any homeowner who has installed solar on their own roof, and they will quickly tell you of the cost-saving benefits. There is also a need for energy production at varying scales and at various locations. There is no doubt that the energy grid of the future is one that is based around smart, scaleable and distributed generating infrastructure.
I have reviewed the documents and proposal for the Merino Solar Farm near Goulburn. I am wholeheartedly in support of this development. This is a well-sited location for solar PV. The location has been carefully chosen. focussed at the end of the Goulburn Airport runway, which limits the size and scope of what may be built there. The project has no impact on the planned future town expansion. The project also has ready access to existing power transmission infrastructure, removing the need to build large power lines over long distances (and impacting many more landowners). Neighbour consultation has been carried out and the design modified based on community feedback. There is a plan in place for a benefit‑sharing program that will operate into the future, ensuring the locals share in the advantages, amongst which are benefit payments of $382,500 per year (plus CPI) for the project's 35-year lifespan. The project is a $1.2 billion investment into the Goulburn region, creating over 500 jobs during construction and 10-12 permanent jobs during operation. The solar farm is truly a "farm", producing not only electrons, but through agri-voltaics, fibre as well. This is a win-win; sheep do better under the shade of solar panels, as has been the experience of farmers in other parts of NSW. They will also assist with keeping the pasture from interfering with the operation of the solar trackers. Agreements with host landowners are in place to fund the clean-up and restoration of the land at the end of the project’s life. Solar PV panels can now be recycled in Australia and the valuable component materials recovered for re-use, promoting a true circular energy economy.
In closing, this is an important large-scale solar & battery project that will go a long way to addressing future energy needs in NSW and across the National Electricity Market. I humbly rerquest that this project is looked on favourably for support to move forward.

I object to the proposed Merino solar installation for the following reasons:

FIRE

EDPR have identified over 100 families affected by their proposal. There are also many other including those living in Goulburn who will be affected by the proposal when a fire on the solar land cannot be fought and the winds are from the south or south-east.

Having a theoretical fire report as to the conditions on the solar factory land is really not relevant. The fact is that in the mid 1980’s a massive and destructive fire jumped Braidwood Rd to the west of the solar land, burned large areas of the Gundary Plains, jumped Windellama Rd, burned the Plains to Kooringaroo Rd, a dead end and currently the home of over 40 families, and was not able to be contained until it reached the coast.

That fire was able to be fought but still travelled to the coast, burned thousands of stock and wildlife and badly injured volunteer firefighters.

When a similar fire starts on or burns onto the Merino solar land the physical constraints imposed by the installation including the nature of the fire including sub-station, battery and inverter fires, the 8 foot high perimeter fence, the massive number of panels and the rods that run between the rows of panels will make it impossible to effectively fight a fire if at all. As a consequence the people living on Windellama Rd and Kooringaroo Rd and beyond to the east will be faced with a catastrophic life threatening situation.

The prevailing winds across the Plains are west to north westerly which would quickly push a fire onto the solar land and from it to Windellama Rd and to the east. Goulburn winds are frequent and fierce. In September 2024 BOM recorded gusts of 96 kph. On 26.11.2 5 we experienced westerly gusts of 91kph. This is not unusual on the Gundary Plains. Look at The Bureau of Meteorology weather records. Grass fires are fast and unpredictable, affected by the wind gusts.

How will the residents of the Gundary Plains be warned of a fire especially at night. How fasts will EDPR respond keeping in mind how fast a fire driven by 92kmp gusts will travel.

LightsourceBP, the British company that wants to build a solar factory a few kilometres to the east of the Merino one stated in one of its pamphlets after their drop in session that solar farms increase the risk of fires. LSBP should be asked to explain why the fire started in their Wellington solar farm recently. This fire jumped the road and threatened the Wellington jail.

A sub-station fire is a real possibility.
On Sunday 9.10.22 a fire started in a transformer at the Canyonleigh substation near Goulburn/Gundary. The emergency crews that attended had to wait a number of hours before they could access the property. As advised to us on 14.10.22 by the RFS, the fire was still burning on 14.10.22. We were told that transformer fires are difficult to extinguish and control. The temperature of oil fires ranges from 960 to 1200 °C.
The officer from RFS Southern Tablelands Zone (one of the brigades attending) told us that, once those fires grew to a certain size, the retardants that they normally use become ineffective and that the only way that the fire could be controlled was to cool it down by spraying a lot of water on it. He said that the issue with fires on solar installations was the fact that very high voltage was involved and that specialist information was required. The amount of water that LSBP has provided for i.e. 180,000 litres of water would last for only 4 hours. They have provided no water tank anywhere near the battery.
The release of oil and/or the water used to cool the burning oil in a sub-station fire on Windellama Rd would cause major environmental pollution of the Gundary Creek flood plain which is part of the Sydney water catchment and runs through a number of properties.
For general information abut the fire see the Goulburn Post link below:
https://www.goulburnpost.com.au/story/7934936/emergency-crews-attend-substation-fire-emitting-cloud-of-black-smoke/?cs=181

This was the second sub-station fire in NSW in 2022.. There was a substation fire at the Tallawarra Power Station in Yallah in June 2022 and it impacted nearby residents in Wollongong, Unanderra and Shellharbour. Paul Baxter of the Fire and Rescue NSW described it as “a large Transgrid 33 KV (sic) transformer, a very dangerous operation, …” (see link https://wattclarity.com.au/articles/2022/06/18june-transgrid-330kv-substation-at-tallawarra-power-station-on-fire/). 16 Fire trucks attended but were unable to enter the site until they could confirm the power had been shut off and some 60 fire fighters attended along with Police and Ambulance. Details were on ABC Illawarra.
There are many instances in other states of transformers catching fire (Victoria) and the solar factories having to be closed down.

The report has completely failed to properly realistically assess the impact of the toxic smoke and fumes from a sub-station or battery fire and their impact on the neighbours and the residents in Goulburn which, as the crow flies is approximately 5 kms away. Stock, domestic animals and our soil and water supplies including household drinking water will also be affected.

The very real threat of fire from this proposal and the inability to properly fight the fire supports the position that this land is the completely wrong place to build a solar factory.

Mundy Street Bridge (from Sloane St, crossing the railway line to Braidwood Rd)
This brick bridge is so old the Council has no record of any weight limit. It is showing signs of stress at street level where the cracks have been patched with metal plates.
It is the only bridge that oversize trucks can use to access the proposed Merino site, has no weight limit recorded by Council as it is so old. It is made of bricks and if it is damaged by the trucks carrying 477 tonnes (the transformer) or 170 tonnes (other equipment) plus the weight of the vehicle, and becomes unusable or unstable it will close the Southern Railway line which it crosses. Not only will it prevent passenger travel but Veolia, the company which runs the Woodlawn incinerator at Tarago, ships approximately 110 – 132 train containers of waste to Tarago each week using this railway line. This is two trains per day, six days per week. These will either cease completely or will have to be transferred to trucks which will have to go south to Collector and turn around and use a very narrow road to get to the incinerator if that road does not have a weight limit on it. If the proposed extension to the incinerator is approved the number of container loads will increase significantly.

If the Bridge cannot be used it will also stop all truck and caravan access across the Bridge to/from Braidwood Rd including farming equipment, trade trucks, livestock trucks and tourist caravans. It will also prevent access to the Showground for regular trotting and other events including the yearly show, the yearly circus, the yearly rodeo. It will prevent access to the Goulburn Brewery and will completely disrupt Divall’s earthmoving and bulk hauling business which is on the showground side of Braidwood Road.

Braidwood Road is the road that is part of the access to the South Coast.

There is no work alternate access to Windellama and Braidwood Roads for trucks of this weight and size. The Garroorigang Bride has a height limit of 2.7m and the other possible roads, e.g. over Rocky Hill have a 5 tonne weight limit.

The inability to provide safe truck access to the solar land that will not damage existing infrastructure supports the position that this land is the completely wrong place to build a solar factory.

Community Benefits

EDPR proposes to donate $20,000 each year to an elite group in Goulburn called the “Goulburn Group”. This group is a group of political activists which restricts membership and blocks access to its face book page. It is not possible to find the names of the people on its committee on the internet. This is not a community group. There is no explanation as to what the “Group” will use the money for and whether it will in fact be used to support needy residents of Goulburn.
Appropriate recipients would be Riding for the Disabled, Rotary, The Lions Club and the many Church groups that regularly feed the underprivileged, homeless and those that need a helping hand.
There are many other groups in Goulburn that would benefit from $20,000 per annum.

State Environmental Planning Policy (Transport and Infrastructure) 2021 (SEPP)

Goulburn has been designated as a regional city.
The State Environmental Planning Policy (Transport and Infrastructure) 2021 (SEPP) provides as follows:
“2.42 Determination of development applications for solar or wind electricity generating works on certain land.

(1) This section applies to development in a regional city for the purposes of electricity generating works using a solar or wind energy source that is—.

(a) State significant development, or.

(b) regionally significant development. .

(2) Development consent must not be granted unless the consent authority is satisfied that the development—.

(a) is located to avoid significant conflict with existing or approved residential or commercial uses of land surrounding the development, and (b) is unlikely to have a significant adverse impact on the regional city’s —.
(i) capacity for growth, or

(ii) scenic quality and landscape character.

(3) In determining whether to grant development consent, the consent authority must consider measures proposed to be included in the development to avoid or mitigate conflicts referred to in subsection (2)(a) or adverse impacts referred to in subsection (2)(b). “


- The proposed Merino solar factory does not comply with the above requirements including mitigation measures and should be rejected. The first portion of the proposed project will be on land that has been mapped under the SEPP (T

Along with my husband, I am one of the owners of Little Gundary, a 160-acre rural-residential lifestyle property and small productive agricultural enterprise at 352 Painters Lane, Tirrannaville. Our property shares its entire western boundary with the proposed Merino Solar Project. It would run the full length of our boundary, becoming a defining and unavoidable presence in our lives.
Our property is owned through a Self-Managed Superannuation Fund and represents our entire superannuation. It is our home, our livelihood and our long-term future.
We support renewable energy and recognise its importance to Australia’s energy transition. Our objection is not to solar energy itself, but to this project being placed in the wrong location, without appropriate regard for the people and landscape it directly affects.
It is apparent that this site is attractive to the proponent primarily because of its proximity to existing electricity transmission infrastructure, which reduces connection costs and improves project economics. That reduced cost to the developer comes at a very real and enduring cost to surrounding landowners, Council and the community.
Those costs include:
• loss of rural amenity and sense of place
• heightened and ongoing fire risk
• reduced land values and financial security
• mental health impacts from loss of safety and control
• long-term road, access and emergency response burdens
These costs are externalised onto the community, while the benefits largely accrue to an offshore proponent, with minimal long-term economic benefit to Goulburn Mulwaree once construction concludes.
The Merino Solar Project:
• is outside a designated Renewable Energy Zone
• is located within an area identified in Council’s long-term residential and rural-residential planning considerations
• would permanently industrialise land currently supporting rural living, biodiversity and small-scale agriculture
When considered alongside the proposed Gundary Plains Solar Project, the cumulative impact becomes stark:
• Merino Solar Project: approximately 3,600 acres, up to 1 million panels
• Gundary Plains Solar Project: approximately 2,700 acres, around 740,000 panels
Together, these projects would industrialise approximately 6,300 acres of the Gundary Plains with more than 1.7 million solar panels for an entire generation.
The NSW Large-Scale Solar Energy Guideline requires cumulative impacts to be assessed holistically. Considering these projects in isolation materially understates their combined effect on landscape character, amenity, fire risk, land-use conflict and long-term planning outcomes.
The NSW Large-Scale Solar Energy Guideline also establishes clear expectations for how large solar developments should be planned and assessed, including:
• minimising visual impact
• protecting rural character and amenity
• ensuring early and meaningful engagement with affected landowners
• assessing fire risk and emergency access
• considering cumulative impacts and long-term land use
In our experience, and as supported by community survey material provided separately, the Merino Solar Project has not been progressed in accordance with either the intent or practical application of the Guideline.
The project will be clearly visible from our home, working paddocks, Painters Lane and Braidwood Road. Despite being an immediately adjoining landholder, no site-specific mitigation has been proposed for our property, including buffers, screening or tailored fire-risk management.
Glare and glint impacts—explicitly recognised in the Guideline due to effects on amenity, livestock behaviour and road safety—have not been adequately assessed.
Fire risk is not theoretical. A previous grass fire on the subject land reached our boundary and was stopped only due to the chance presence of a neighbouring Rural Fire Service volunteer. Based on observed fire behaviour, a future fire could reach our home in under three minutes. This risk is compounded by the condition of Painters Lane, which is narrow, unsealed and already degraded.
Consultation has been reactive, generic and inconsistent. Adjoining landholders have not been treated as priority stakeholders. This has created confusion, distress and division within a previously close community.
EDPR has not completed or operated a solar project in Australia and has provided insufficient clarity regarding long-term maintenance, decommissioning and land remediation. Based on conduct to date, there is no reasonable basis to assume impacts will be responsibly managed once approval is granted.
This land is our sanctuary. It is where our family gathers, where our teenage daughter feels grounded and safe, and where we care for animals and land. The prospect of living beside an industrial development running the full length of our boundary, combined with fire risk, loss of amenity and ongoing anxiety would have real mental-health and wellbeing consequences. It will also directly and immediately impact our plans for the farm as we would not have the confidence to continue to invest in improvements including our farm stay, truffle orchard or to support multi-generational living for our family.
These impacts are permanent. They do not end when construction finishes.
The Merino Solar Project would impose severe, enduring and disproportionate harm on directly adjoining landholders and fundamentally alter the Gundary Plains for a lifetime.
For these reasons, and for the detailed matters set out in Appendix A, we respectfully submit that development consent should not be granted.

The 75 metre height limit is the maximum height that should be permissable in this location. Nothing more. If this is approved should we have up to 50 storeys the closer we get to the station? Loftus Crescent is a narrow road with a narrow footpath. Totally inappropriate for a 35 storey building. There's only one footpath as the other side of the road is the railway. The amount of cars these proposed apartments will bring onto the roads will be such that there will be chaos every morning and afternoon. The roundabout on the corner of Loftus Crescent and Subway Lane will not be able to cope with the number of cars that will be passing through there everyday.
This area has a lack of amenities and this proposal does nothing to help with that. The mention of express trains passing through Homebush is deceptive as they don't stop at Homebush.
Once again, 35 storeys is far too much for this location. The infrastructure here just can't support two buildings of heights up to 119m. Parramatta Rd, the main road that passes through here at this location isn't coping with the traffic volume as it is now.