The University of Sydney is pleased to support Spark Renewables in relation to their development application (Case ID SSD-63345458) for the Wattle Creek Battery Energy Storage System, located on the University’s property in regional New South Wales (Arthursleigh, Brayton).
Spark Renewables was selected as the University’s preferred partner following a competitive process, and we have since entered into a long-term collaboration to support the development of a hybrid solar and battery energy storage system (BESS) facility at Arthursleigh. This project represents a significant opportunity to advance the University’s sustainability, research, and education objectives. As part of this agreement, the Wattle Creek Battery Energy Storage System will not only contribute to the decarbonisation of the electricity grid, but also serve as a platform for high-impact research and innovation. Under the Research and Education Agreement, the University and Spark Renewables will collaborate on a range of research initiatives.
Attached is the letter of support from the University with further detail, signed by the Interim Deputy Vice Chancellor Research, The University of Sydney.

This submission statement accompanies my full formal objection (attached as a PDF) to the Wattle Creek Battery Energy Storage System (BESS) (SSD-63345458) Environmental Impact Statement (EIS). After a thorough review of the EIS and its specialist assessments, it is evident that the proposal for this 350 MW / 1400 MWh BESS, storing approximately 5,125 tonnes of Lithium-ion Batteries, is fundamentally flawed and presents an unacceptable risk to the community and environment. The EIS fails to adequately assess or provide credible mitigation for significantly amplified risks associated with a BESS of this enormous scale, does not meet requisite environmental and safety standards, and systemically defers critical planning and assessment to post-approval stages.

My detailed objection highlights numerous critical deficiencies, demonstrating why the EIS is not fit for purpose and the project should be refused. The core grounds for this objection include:

An Unacceptable Threat to Public Safety and Emergency Response Capability: The proposal places a major hazardous industrial facility in a high bushfire risk area with an indefensibly insufficient dedicated firefighting water supply of only a "minimum 40,000 litres," orders of magnitude below what is required for a 1400MWh BESS fire. The Preliminary Hazard Analysis (PHA) is based on an inadequate "Level 2 Assessment" for a facility of this scale, wrongly concluding "no observed offsite impacts". Critical safety measures like detailed fire propagation and toxic plume dispersion modelling are missing or inadequate, and the Emergency Response Plan is deferred. Furthermore, verifiable UL9540A test data for the BESS technology is not provided upfront.

Fundamental Deficiencies in Traffic and Road Safety: The Traffic and Transport Assessment relies on flawed data (a single 12-hour count) and fails to propose adequate upgrades for Canyonleigh Road, a narrow, partially unsealed road projected to experience an over 800% increase in cumulative daily traffic. Proposed "resurfacing works" without widening are insufficient to ensure safety or manage the impacts. Critical safety audits and management plans, including for Over Size Over Mass (OSOM) vehicles and school bus interactions, are improperly deferred.

Significant and Unresolved Environmental Impacts:

Biodiversity: The project will destroy 2.12 ha of critically endangered Box Gum Grassy Woodland, part of up to 28.84 ha of total native vegetation clearing, impacting threatened species habitat. The assessment of Serious and Irreversible Impacts (SAII) for the CEEC is unconvincing.

Water Quality: The EIS admits the project will fail to meet Neutral or Beneficial Effect (NorBE) criteria for Total Nitrogen and Total Phosphorus loads and concentrations within the Sydney drinking water catchment. Proposed solutions are deferred, and the proponent's own assessment questions the feasibility of standard mitigation measures.

Land Use and Soil Erosion: The project will occur on soils with "Very High" erosion risk, and the proponent's own assessment identifies multiple "Moderate" residual risks for land use conflict with neighbouring agricultural and community interests.

Inadequate Assessment of Aboriginal Cultural Heritage: The archaeological investigation was incomplete, with some areas of potential not excavated due to "boggy conditions". The assessment of cultural significance does not appear to adequately reconcile with RAP concerns of "high significance," and mitigation clarity for all impacted sites is lacking.

Systemic Methodological Flaws: Key assessments, including Noise (using assumed background levels instead of site-specific measurements), Landscape and Visual (failing to assess all components like the 80m communications mast and relying on "leaf-on" photomontages), and Electromagnetic Fields (deferring mitigation for identified public exposure exceedances), are inadequate or incomplete.

Improper Assessment of Cumulative Impacts via Project Splitting: The EIS fails to transparently assess the total combined risks of the Wattle Creek Energy Hub, which includes this 350MW BESS and a co-located 100MW BESS with the Wattle Creek Solar Farm. This is despite the proponent's own documentation acknowledging "HIGH" potential for substantial cumulative impacts across most environmental and social aspects, including hazards and bushfire risk. A consolidated hazard assessment for the combined 450MW/1800MWh BESS capacity is critically lacking.

Use of Restrictive Neighbour Agreements: The proponent has offered deeds that restrict landholders from objecting to project applications, undermining genuine public consultation.

The EIS, in its current form, is an exercise in justification rather than a rigorous, objective assessment. It is characterised by a pattern of downplaying significant risks, deferring critical safety and environmental planning, relying on insufficient assessment methodologies, and proposing inadequate solutions.

Therefore, I strongly urge the Department of Planning, Housing and Infrastructure to refuse consent for this project. Should the project be considered further, a comprehensively revised and integrated EIS for the entire Wattle Creek Energy Hub is mandatory, addressing all deficiencies detailed in my full submission (attached as a PDF). This must include, at a minimum, a FRNSW/RFS endorsed Emergency Plan with adequate water supply, a Level 3 QRA for the total BESS capacity, proponent-funded road upgrades, verifiable solutions to meet NorBE criteria, and a transparent assessment of all cumulative impacts.

Save Our Surroundings (SOS) objects to the proposed BESS Works in this project because there are still so many unresolved concerns about risks and issues involved with Battery Energy Storage Systems (BESS), for instance:
1. Lack of research into the life-cycle of BESS
2. Resource intensive requirements
3. Involves slavery in mining and production
4. Environmentally damaging
5. Fire starting risks increased
6. Fire-fighting dangers increased
7. Local fire risks considerably increased
8. Expensive
9. Short life-span
10. Variable operation
11. Very little Australian content
12. Increased energy and sovereign risks
13. Roads and road travel are impacted
14. Electricity charging and air-conditioning requirements are high
15. Classed as hazardous goods
16. No certainty at end of the short life of a BESS or frequent battery/inverter replacements
17. Increased dependency on intermittent electricity generation
18. Poor viability
19. Increase retail electricity prices.

Contamination and Waste Management are issues that are being swept under the carpet. It’s time government stop putting renewable targets ahead of the nation’s public health and food security. Please see attachment for further details:

As a strong supporter of renewable energy innovation and grid resilience, I fully endorse the proposed standalone Battery Energy Storage System (BESS) project.

This project is a vital investment in our clean energy future, enabling better integration of renewable resources like solar and wind, and ensuring a more stable and reliable electricity supply. By storing excess energy and dispatching it when needed most, the battery system will help reduce reliance on fossil fuels, lower energy costs over time, and contribute to emissions reduction targets.

Beyond its technical benefits, the BESS project also represents a commitment to forward-thinking infrastructure that supports regional development and local employment opportunities specially for the research of the University of Sydney.

I am confident that this project will deliver long-term environmental, economic, and community benefits, and I proudly support its development.

I strongly support the development of the Wattle Creek Battery Energy Storage System due to its potential to deliver significant environmental, economic, and community benefits. The project will contribute to Australia’s clean energy transition by generating renewable electricity and reducing reliance on fossil fuels, helping to meet national and state emissions reduction targets. This is a forward-looking project that aligns with the urgent need for sustainable infrastructure and a resilient energy system. I encourage its approval and timely development.

It is exciting to see a significant BESS project proposed in a critical part of the network. I am supportive of the role this project will play redistributing energy to the times of the day when it is most needed.