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David Wakeling
Object
Mangoplah , New South Wales
Message
Subject: Objection against the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of The limited amount of local Rural Fire Service members available to fight a fire that may occur in or near the new access roadway to the proposed Mangoplah BESS project.

I am writing to formally express my objection against the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of The limited amount of local Rural Fire Service members available to fight a fire that may occur in or near the new access roadway to the proposed Mangoplah BESS project.

The nation's volunteer firefighting force has been reduced by about 18,000 members over the past decade, and the loss of more than 3,000 members in the NSW’s Rural Fire Service in four years, raising concerns about state fire services' ability to combat fires during prolonged bushfire seasons (Paul Sakkal, The Age. 2019).

In the event of a fire occurring near or along the new access roadway to the proposed Mangoplah BESS site is of major concern to the local Rural Fire Brigade members, as the proposed Mangoplah BESS project site is located 3km from the Holbrook Road, is 2.4 from the closest local Rural Fire Brigade, with other available Rural Fire Brigade units located up to 22km from the proposed Mangoplah BESS project site.

More concerning, is the fact that the average age according to the NSW Rural Fire Service is over 50 years of age, with The Age Newspaper stating “only one in 10 RFS volunteers is aged 25 or younger, and the median age of NSW volunteers is more than 50 (Paul Sakkal, 2019), this can be disconcerting for the safety of the local members, as the NSW Rural Fire Service, states that the proposed Mangoplah BESS project site is located within a Priority 2 area, which prioritizes firefighter safety, then people, then property, then the environment, and finally restoring normality. This means that when responding to an incident, the safety of firefighters is paramount, followed by the protection of human life, and then the protection of structures and other assets.

In addition, there are problems with being able to contact Rural Fire Brigade members because of poor mobile reception and mobile ‘black spots’ in the area around Mangoplah, it can take approximately 1 hour to manage to get a crew together to man even one tanker, which adds a degree of difficulty in being able to get an appropriate number of Rural Fire Brigade members to attend the fire. The Australian Government stated in their article Mobile Black Spot Program to “provide new resilient mobile coverage in regional and remote areas of Australia that are prone to Natural Disasters, including bushfires…”, further saying “The focus on areas impacted by, or at risk of, Natural Disasters reflects the increasing exposure of many regions to these events, and the need for communities to access resilient mobile communications services during and after these events” (n.d., Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts). Unfortunately, a large portion of the area around the Mangoplah and Pulletop area continue to have mobile black spots, this is despite the NSW Government stating in their Connecting Country Communities, Mobile Black Spot Program fact sheet, that the program will “focus on locations with unique coverage problems in small communities or areas prone to natural disasters” (p.2, n.d.). The fact sheet goes onto to state that “The Mobile Black Spot Program in NSW is being delivered through the NSW Telco Authority and is focussed on targeting mobile black spots within NSW, specifically within smaller reginal and rural communities” (p.2, n.d.).

Fire Risk and Safety to the local Rural Fire Service members who are very limited in number, is of major concern in the event of a fire occurring within or near the proposed Mangoplah BESS project site, not only because of the lack of knowledge in how to fight such a fire, but also because of the lack of appropriate safety equipment needed to fight such a fire.

Moreover, are the community concerns regarding bushfires and potential limitations to firefighting operations are often dismissed due to the RFS not raising any objections to projects during the planning process. Not only are there issues with access due to infrastructure but another whole range due to lithium-ion batteries and potential toxicity.

It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk and being impacted so heavily. Please consider the fire risk and the added pressure posed to the local Rural Fire Service members, and the broader community. In addition, changing the land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the cost to the Mangoplah community – their environment, their safety, their homes and many farming families who have been here for generations will all be at increased risk if the proposed Mangoplah BESS project goes ahead.
Jenny Creasy
Object
Mangoplah , New South Wales
Message
Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of the High risk of contamination to the waterways, creeks and dams in the area surrounding the proposed Mangoplah BESS project, during construction.

I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of the High risk of contamination to the waterways, creeks and dams in the area surrounding the proposed Mangoplah BESS project, during construction.

The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.

Construction of the proposed Mangoplah BESS project can significantly contaminate waterways, creeks, and dams through various means, primarily runoff containing sediment, chemicals, and other pollutants from the site. Furthermore, these construction activities can have long-lasting impacts on receiving water bodies, such as creeks and dams, when they received polluted runoff (Science of the Total Environment, 2024), this pollutant runoff from construction sites, includes oil, grease, heavy metals and nutrients from construction equipment and materials. Moreover, construction activities such as excavation and grading expose soil, making it vulnerable to erosion and can have a significant impact on the quality and quantity of receiving waters due to the introduction of additional runoff. The pollution of receiving water bodies during construction can lead to severe degradation of water quality. Furthermore, studies have shown that road construction across streams can lead to substantial increases in total suspended solids (TSS) downstream, these increased sediment and chemical loads can reduce water clarity, affect oxygen levels, and introduce toxins into the water, impacting and harming aquatic ecosystems. Moreover, “spills or leaks of chemicals used in construction of the Proposal could lead to impacts to groundwater quality if transported into the underlying aquifer” (cited, p.110, Environmental Impact Statement, Territory Battery, 2024).

This contamination to the waterways around the proposed Mangoplah BESS project site, is very alarming and of major concern if this water supply is contaminated during the construction of the proposed Mangoplah BESS project, as water is a valuable commodity to the residents of Mangoplah and more so to the surrounding landholders, who rely on clean water in the creeks that supply the dams on their farms for their livestock. More alarming, to the landholders around the proposed Mangoplah BESS project is the fact that “groundwater quantity and hydrology could be impacted by the Proposal through changes to the amount of stormwater seeping into the groundwater…” (cited, p.110, Umwelt, Territory Battery, EIS, 2024), moreover, this would involve an increase in the area of impervious or less permeable surfaces, which would lead to a localised increase in stormwater runoff…”(cited, p110, Umwelt, Territory Battery, EIS, 2024). This knowledge is further disturbing as there is an increased probability that this stormwater runoff will contain sediment, chemicals and other pollutants, as mentioned above, into the many waterways and creeks that surround the proposed Mangoplah BESS project site, from the initial access off the Holbrook Road, through to the Mangoplah BESS and substation sites, which flow into Burkes Creek to the north of the proposed Mangoplah BESS project site, which then flows into the Murrumbidgee River.


It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk of having the BESS built within close proximity to the village of Mangoplah but also very close to productive farming and grazing land. Additionally, the change of land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the environment, the cost to the Mangoplah community and surrounding farming families, many of whom have been here for generations, working hard to keep the area going, do not want the proposed Mangoplah BESS project to go ahead.
Raymond Creasy
Object
Mangoplah , New South Wales
Message
Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of The increased risk of bushfire encroaching on landscape vegetation used as visual screening to the proposed Mangoplah BESS project site.

I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of The increased risk of bushfire encroaching on landscape vegetation used as visual screening to the proposed Mangoplah BESS project site.

The proposed Mangoplah BESS project site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land and is classified as being in a ‘High Fire Prone Area’, according to the NSW Rural Fire Service, in addition the area around the proposed Mangoplah BESS project site is classified as being Category 1 and 3 vegetation, as stated by Ember Consulting Pty. Ltd. (p.19, Bushfire Assessment Report, 2025), with “Vegetation Category 1 is considered to be the highest risk for bushfires…” and “Vegetation Category 3 is regarded as a medium vegetation…” (p.19, Bushfire Assessment Report, 2025), with the majority bushfires in the area typically ignited by lightning strikes.

According to the Mangoplah Battery Energy Storage System (BESS) Landscape Plan, Lot 222, referred to on page 2 as “Screening Vegetation”, is completely inappropriate, not only for the very close proximity to the proposed Mangoplah BESS project, which according to the Mangoplah BESS EIS Report “The proposed landscaping will have a 3m buffer from the security fence” (p.42, 2025), but also for the size, height and type of tree to be planted, such as the Callitris glaucophylla – White cypress pine, “reaches a maximum height of about 20 metres” (Australian Forest Profiles, 1997), the Eucalyptus blakely Blackely’s Red Gum “is a tree that grows to a height of 25 metres”, and Eucalyptus melliodora, Yellow Box, “is a tree that typically grows to a height of 30 metres” (Atlas of Living Australia, ala.org.au). In addition are the lower vegetation, including the lower growing shrubs will only add to the fuel load within this “Screening Vegetation”.

This 3m buffer from the proposed Mangoplah BESS and substation site, is totally against what has been recommended in the Mangoplah BESS Bushfire Assessment Report states that there will be an Asset Protection Zone of only 11 metres, moreover, as the area to the south of the proposed site contains vegetation known as “woodland vegetation” (p.27, Ember Bushfire Consulting, Bushfire Assessment Report, 2025), which is similar woodland vegetation to be planted along this “Screening Vegetation”, and therefore comes under the fire Category 1, which states in the Mangoplah Bushfire Assessment Report that “A 100 m buffer is applied to each area of Bushfire Prone Vegetation (BEPV) Category 1” (p.19, 2025)

Upon consultation with both the Mangoplah and Pulletop Rural Fire Service members it is recommended the “Screening Vegetation” be replaced with a fire-retardant barrier along the western side of the proposed Mangoplah BESS project. This will not only help screen the Mangoplah BESS project visually but will also help protect the proposed Mangoplah BESS project from any bushfire encroaching from the western side of the Mangoplah BESS site.

Moreover, the Australian Bushfire Protection Planners Pty. Limited, state that “The erection of a non-combustible sound barrier to the perimeter of the BESS site (including the Substation) would increase the protection provided to the facility provided by the Asset Protection Zones and would improve the protection of the equipment from high intensity bushfires. The erection of a non-combustible sound barrier to the perimeter of the BESS site would also remove the likelihood of fire spread from the BESS site to the adjoining landscape (should a fire occur within the equipment within the BESS site – including the Substation equipment)” (p. 27, Bushfire Assessment Report, Territory Battery Energy Storage System, 2023). The report goes on to further state that the “product selected would need to be non-combustible for bushfire mitigation purposes and also to mitigate the spread of fire that may occur within the battery storage and substation compounds” (p.26, Bushfire Assessment Report, Territory Battery Energy Storage System, 2023).

It deeply affects and concerns me that the rural community like Mangoplah is being exposed to this degree of risk and being impacted so heavily. Please consider the fire risk and the added pressure posed to the local Rural Fire Service members, and the broader community. In addition, changing the land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the cost to the Mangoplah community – their environment, their safety, their homes and many farming families who have been here for generations will all be at increased risk if the proposed Mangoplah BESS project goes ahead.
Kerry Langfield
Object
MANGOPLAH , New South Wales
Message
Objection against the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of Complete lack of engagement and social licence with the landholder near the proposed Mangoplah BESS project, using a roadway on private property.

I am writing to formally express my objection against the Mangoplah BESS project proposed by Samsung C & T Renewable Energy Australia Pty. Ltd., located at 4178 Holbrook Road, Mangoplah.

The site is within close vicinity to the village of Mangoplah, surrounded by agricultural and grazing land, not a place to build such a project.

“Landholder and community engagement is an important aspect of providing essential energy services to Australian communities”, with landholders considered as “critical partners and stakeholders in the delivery of major energy projects” (p. 1, The Energy Charter, n.d.). Additionally, The Energy Charter, goes onto state that “respectful engagement…needs to take place for the design, development, delivery, operation and/or maintenance of new…energy assets”, with its “primary purpose is to encourage better engagement and outcomes for landholders…You can use it to encourage us to do better and to hold us to account” (p.1, The Energy Charter).

It is disappointing that Samsung C&T Renewable Energy Australia Pty. Limited do not have the same understanding as The Energy Charter, as there has been a complete lack of consultation, and discussion with the landholder in relation to a meeting with Cumulus Engineering, (Flood Risk Specialists), Samsung C&T Renewable Energy Australia Pty. Limited and Wagga Wagga City Council, regarding the use of a roadway on private property, namely “Access Route B (via an unnamed track to Paper Forest Road…”, despite in the Scoping Report Mangoplah BESS, 2024, stating “this was however deemed unsuitable, as the unsealed road passes a number of non-associated receiver dwellings and private driveways”, but stating “use of this road will continue to be explored within the EIS stage in consultation with potential impacted receivers. To reduce overall impact to nearby non-associated receivers, the associated receivers private access road is being considered” (p.28).

This road was mentioned by Bushfire Assessment Report, stating “A secondary emergency route, subject to ongoing consultation is available from Paper Forest Road to the south of the Project site, providing safe access and egress during an emergency, all of which will comply with acceptable solutions set out in PBP (2019)” (p. 3, 2025). Also, stated in the EIS, that “Access of Paper Forest Road is proposed to only be utilised in the event of emergency, as directed by the NSW SES. Outside of these conditions, there will not be any traffic to and from the Subject Lot along the emergency access route to the Project” (p.161, 2025).
Additionally, there is the high risk of biosecurity issues with workers bringing in weeds and pests as they drive through the properties, also high risk to the livestock that graze along this roadway, with these workers leaving gates open, allowing the livestock to move onto Paper Forest Road, then onto Holbrook Road. Moreover, the high risk of insurance issues not only from a worker, who is not authorised to be on the property having an accident, to the cost incurred by the landholder’s livestock on open roadways not confined within the property fencing.

In a Flood Impact Assessment by Cumulus Engineering, it was noted that Samsung C&T Renewable Energy Australia Pty. Limited discussed with Wagga Wagga City Council the use of this unsealed road. Moreover, there has been no consultation, no discussion and no written documentation with the landholder to the proposed Mangoplah BESS project site, regarding the proposed use of this unsealed road.

Australian Energy Infrastructure Commissioner, states “Most large-scale renewable energy and transmission projects will have neighbours. Neighbours are residents or owners of properties in proximity of the proposed project, whether or not they are adjoining the host land” (p.45, Annual Report to the Parliament of Australia, 2022). Furthermore, the report states “developers have not always understood the importance of consulting and working with neighbours in proximity to a project. A typical complaint received by our Office from project neighbours is that they were not consulted by the developer” (p.45).

Samsung C&T Renewable Energy Australia Pty. Limited, state in the Scoping Report Mangoplah BESS, that “the engagement strategy aimed to achieve the following objectives:
1. Produce clear information on the Project, potential impacts (positive and negative) and benefits for the environment, community, and region by delivering high-quality communication channels across all targeted channels.
2. Endeavour to contribute towards positive impact in the region with shared local and broader regional social, economic and environmental benefits considered.
3. Develop a sense of local ownership in the Project by identifying local advocates.
4. Work together with the community in a collaborative way by identifying issues and likely mitigations throughout Project phases.
5. Support an uplift in the regional economy and level of local prosperity via a regional economic assessment.
6. Demonstrate sharing of Project benefits.
7. Support and engage local capabilities, engaging several local suppliers, including Aboriginal owned suppliers.
8. Maintain a positive corporate image for the Applicant and the renewable energy industry with the development of social licence and management of social and reputational risks...” (p.35).

The Australian Energy Regulator, state “effective engagement is necessary to build the social licence” (p.9, Direction Paper, 2023), further stating “social licence or social licence to operate, is a broad concept covering factors related to the level of community acceptance of, or opposition to, potential change or an organisation’s operation” (p.2). The community of Mangoplah and the surrounding landholders feel there has been a complete lack of social licence. Social licence is described as an informal, implicit agreement based on trust, transparency, and responsible, ethical behaviour, this concept of ‘engagement and social licence’.

This trust and ethical behaviour has been the complete opposite with the Mangoplah community, this is evident with Samsung C&T Renewable Energy Australia Pty. Limited, not informing the landholder of the proposed use of the unnamed, unsealed roadway to the Mangoplah BESS site, this roadway is on private land, and is described under the NSW Department of Primary Industries, Lands as a ‘Road Closed’, which according to the NSW Government Gazette…”Notification of closing of road - In pursuance of the provisions of the Roads Act, 1993, the road hereunder described is closed and the lands comprised therein cease to be public road and the rights of passage and access that previously existed in relation to the road is extinguished. Upon closing, title to the land, comprising the former public road, vests in the body specified in the Schedule hereunder.”

The Australian Energy Regulator goes onto say that “Effective engagement is necessary to build the social licence”…”that facilitates collaboration and dialogue between landholders, communities” (p.9, Direction Paper, 2023) and developers. The community of Mangoplah and the surrounding landholders feel that Samsung C&T Renewable Energy Australia Pty. Limited should understand what factors are mostly concerning to the community of Mangoplah and the surrounding landholders, as according to The Australian Energy Regulator,”building a social licence is therefore an important part of doing business in the energy sector” (p.9, Direction Paper, 2023).

In a Newsletter sent to the Mangoplah community in July, 2025, Samsung C&T Renewable Energy Australia Pty. Limited stated “We recognise that community expectations are changing. There is a growing demand for open communication, meaningful involvement in decision-making, and clear, timely benefits that reflect both the scale of a Project and its local impacts. The Proponent is committed to meeting these expectations by:
• Providing clear, accurate, and easy-to understand information
• Offering genuine opportunities for input throughout the process
• Reporting back on how community feedback has been considered and reflected in the
Project. This approach reflects our commitment to engaging respectfully with the community and ensuring the Project is developed in a way that considers local interests and concerns”.

Moreover, social licence is not present if a community withholds support and opposes an industry or development, this statement is of major concern to the community of Mangoplah and surrounding landholders as they feel that there has been a distinct lack of information and consultation regarding how this proposed Mangoplah BESS project will benefit the environment, community socially and economically, if anything it will impact the community in reverse.

It deeply concerns and affects me that a rural community like Mangoplah is being treated with the disrespect and disregard of not being informed, consulted and clear lack of ethical behaviour, there has been a distinct lack of social licence with the community of Mangoplah and the surrounding landholders, as this change in the land use from farming to industrial will negatively impact upon Mangoplah’s rural setting and lifestyle. I take it upon you to consider the cost to the Mangoplah community, the surrounding landholders and how this project will affect them in the future, as many of the local community members have been in the district for generations and do not want the Mangoplah BESS to be constructed in such an inappropriate and ill-chosen location.
Attachments
Sharon Dew
Object
Mangoplah , New South Wales
Message
Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of the High risk of contamination to the waterways, creeks and dams in the area surrounding the access roadway to the proposed Mangoplah BESS project.

I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah.

Because of the High risk of contamination to the waterways, creeks and dams in the area surrounding the access roadway to the proposed Mangoplah BESS project.

The site is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land – to me it is not a place to build such a project.

The construction of roadways can significantly contaminate waterways, creeks, and dams through various means, primarily runoff containing sediment, chemicals, and other pollutants from the site. Furthermore, these construction activities can have long-lasting impacts on receiving water bodies, such as creeks and dams, when they received polluted runoff (Science of the Total Environment, 2024), this pollutant runoff from construction sites, includes oil, grease, heavy metals and nutrients from construction equipment and materials. Moreover, construction activities such as excavation and grading expose soil, making it vulnerable to erosion and can have a significant impact on the quality and quantity of receiving waters due to the introduction of additional runoff. The pollution of receiving water bodies during construction can lead to severe degradation of water quality. Furthermore, studies have shown that road construction across streams can lead to substantial increases in total suspended solids (TSS) downstream, these increased sediment and chemical loads can reduce water clarity, affect oxygen levels, and introduce toxins into the water, impacting and harming aquatic ecosystems. Moreover, “spills or leaks of chemicals used in construction of the Proposal could lead to impacts to groundwater quality if transported into the underlying aquifer” (cited, p.110, Territory Battery, Environmental Impact Statement, 2024).

This contamination to the waterways around the access roadway to the proposed Mangoplah BESS project site, is very alarming and of major concern if this water supply is contaminated during the construction of the access roadway to the proposed Mangoplah BESS project, as water is a valuable commodity to the residents of Mangoplah and more so to the surrounding landholders, who rely on clean water in the creeks that supply the dams on their farms for their livestock. More alarming, to the landholders around the proposed Mangoplah BESS project is the fact “groundwater quantity and hydrology could be impacted by the Proposal through changes to the amount of stormwater seeping into the groundwater…” (cited, p.110, Umwelt, Environmental and Social Consultants, Territory Battery, 2024 ), moreover, there “would involve an increase in the area of impervious or less permeable surfaces, which would lead to a localised increase in stormwater runoff…”(cited, p110, Umwelt, Environmental and Social Consultants, Territory Battery, 2024). This knowledge is further disturbing as there is an increased probability that this stormwater runoff will contain sediment, chemicals and other pollutants, as mentioned above, into the many waterways and creeks that surround the proposed Mangoplah BESS project site, from the initial access off the Holbrook Road, through to the Mangoplah BESS and substation sites, which flow into Burkes Creek to the north of the proposed Mangoplah BESS project site, which then flows into the Murrumbidgee River.

It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk of having the BESS built within close proximity to the village of Mangoplah but also very close to productive farming and grazing land. Additionally, the change of land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the environment, the cost to the Mangoplah community and surrounding farming families, many of whom have been here for generations, working hard to keep the area going, do not want the proposed Mangoplah BESS project to go ahead.
Winston Dew
Object
Mangoplah , New South Wales
Message
Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of The extreme risk of fire if construction to the proposed Mangoplah BESS project is not ceased during periods of Total Fire Ban.

I am writing to formally express my objection to the Mangoplah Battery Energy Storage System (BESS) project proposed by Samsung C & T Renewable Energy Australia (SREA) Pty. Ltd., to be located within the property on 4178 Holbrook Road, Mangoplah. Because of The extreme risk of fire if construction to the proposed Mangoplah BESS project is not ceased during periods of Total Fire Ban.

During a Total Fire Ban, according to the NSW Rural Fire Service you cannot light, maintain or use a fire in the open, or to carry out any activity in the open that causes, or is likely to cause, a fire, including general purpose hot works (such as welding, grinding or gas cutting or any activity that produces a spark or flame) are not to be done in the open. So, all construction should be ceased to comply with the NSW Rural Fire Service.

Moreover, as stated by Umwelt Environmental & Social Consultants, that during construction, there is a high risk of “sparks from construction machinery, vehicles or electrical works, or a fault occurring in the Proposal equipment (e.g. battery packs), start a fire, resulting in fire spreading onto the surrounding landscape and/or toxic chemicals/fumes being released” (p.251, Neoen, Territory Battery, EIS, 2024).

The site of the proposed Mangoplah BESS project is within close vicinity to the village of Mangoplah and is surrounded by agricultural and grazing land and is classified as being in a ‘High Fire Prone Area’, according to the NSW Rural Fire Service, in addition the area around the proposed Mangoplah BESS project site is classified as being Category 1 and 3 vegetation, as stated by Ember Consulting Pty. Ltd. (p.19, Bushfire Assessment Report, 2025), with “Vegetation Category 1 is considered to be the highest risk for bushfires…” and “Vegetation Category 3 is regarded as a medium vegetation…” (p.19, Bushfire Assessment Report, 2025), which according to the NSW Rural Fire Service requires a buffer zone of 30 metres, whereas the Mangoplah BESS Bushfire Assessment Report states that there will be an Asset Protection Zone of only 11 metres, while in a report by SLR Consulting Australia (SLR) for the Jindera BESS recommends a APZ of “30 metres from nearest BESS Site equipment”(p.26, Appendix J, Bushfire Assessment Report, 2025), along with an additional 30 metres required from the edge of vegetation. These inconsistencies with the required Asset Protection Zones are of major concern and need to be addressed and made uniform and become part of the Policies and/or Standards for all Battery Energy Storage System (BESS) sites across Australia, especially those in New South Wales and in High Fire Prone Areas.

Furthermore, there should be a 100 meter Buffer Zone around the entire Mangoplah BESS project site, because of the close proximity to “hazardous woodland vegetation”, as per photos iii and vi (p.27, Ember Bushfire Consulting, Bushfire Assessment Report, 2025).

As stated by Australian Bushfire Protection Planners Pty. Limited, “The BESS proposal is classified as ‘industrial’ development and…therefore, the default position for providing protection for ‘industrial’ development located in a bushfire prone area is to provide a defendable space (Asset Protection Zone) wide enough to prevent flame contact on the structure, or in the case of the BESS, the cabinets housing the battery packs and the electrical equipment in the Substation” (p.24, Bushfire Risk Assessment Report, TBESS, 2023).

In addition, as stated by Ember Bushfire Consulting, “Bushfire protection measures generally serve a dual purpose: protecting the site from external fire threats, containing fire within the site should it occur, and stopping it from escaping onto adjoining lands” (p.32, Bushfire Assessment Report, 2025). Moreover, Ember Bushfire Consulting state that “Given the heat-sensitive nature of the Mangoplah BESS substation and associated infrastructure, larger APZ and setback dimensions are recommended than those prescribed…”(p.32, Bushfire Assessment Report, 2025).

With the majority bushfires in the area typically ignited by lightning strikes and sparks from power lines during hot windy conditions, and with the bushfire season generally runs from October to March, depending on seasonal conditions (p.126, Deniliquin BESS, 2024), it is a period of non-complacency, a period in which landholders are alert to the dangerous weather conditions. Moreover, according to Vic Emergency “Bushfires and grassfires start quickly, often without warning and they can threaten lives and properties within minutes”, with them going onto say that “grassfires can be just as dangerous as bushfires – grass is the most predominant fuel type in Australia. It ignites very quickly, burns rapidly and can travel at speeds of up to 25 kilometres per hour”(Facts of Fire/Emergency Victoria, n.d.). Moreover, as stated in the Mangoplah BESS Bushfire Assessment Report that the Forest Fire Danger Index (FFDI) is rated at 80, (p.19, Ember Consulting Pty. Ltd., 2025), which according to the Australian Fire Danger Rating System is classified as “Extreme” stating to “Take action now to protect life and property” “Fire will spread quickly and be extremely dangerous”.

Furthermore, “during a fire, embers can travel up to 40 kilometres ahead of a fire front…starting spot fires well ahead of the fire-front-often without warning” (Facts of Fire/Emergency Victoria, n.d.). More concerning however is the fact that “Flame temperatures can reach up to 11000C and radiant heat fluxes high enough to vaporise vegetation, only adding speed to the scorching hot flames…so fires can spread and become out of control quickly” (Facts of Fire/Emergency Victoria, n.d.). In addition, according to the Australian Bushfire Protection Planners Pty. Limited, “a dangerous and damaging fire has the potential to occur when the following conditions prevail: continuous available fuel…exposure of vulnerable assets…a combination of weather conditions that generate a…grass fire danger index of Very High or greater…a fire in the landscape which is not effectively suppressed”(p. 20, Bushfire Risk Assessment Report, TBESS, 2023). As a result of these hot dry windy conditions, it is possible that a bushfire has the ability to, and is “likely to impact on the BESS site…and the “fire is likely to over-run the site” (p. 20, Australian Bushfire Protection Planners Pty. Limited, Bushfire Risk Assessment Report, TBESS, 2023.

Furthermore, in the Bushfire Assessment Report, for Mangoplah BESS, it states that “it is a SEARs requirement that the location of a electricity generating infrastructure, including BESS, should avoid any land subject to identified natural hazards (such as bushfires) and should not contribute to an increase of a natural hazard (bushfire)” (p.19, Ember Bushfire Consulting, 2025).

The NSW Rural Fire Service, also states that the proposed Mangoplah BESS project site is located within a Priority 2 area, which prioritizes firefighter safety, then people, then property, then the environment, and finally restoring normality. This means that when responding to an incident, the safety of firefighters is paramount, followed by the protection of human life, and then the protection of structures and other assets.

Despite there being 3 Rural Fire Service Stations around the area ranging in distance from 2.5km to 22km away from the Mangoplah Bess site, it can take approximately 1 hour to manage to get a crew together to man even one tanker, this is due to the Fire Captain not being notified of an incident, the Fire Captain not able to be notified because of being in a ‘blackspot’ mobile phone area, or other rural fire members not able to attend the fire, as they also cannot be contacted.

Fire Risk and Safety is of major concern in the event of a fire occurring near or within the proposed Mangoplah BESS project site, not only from the potential threat of a bushfire, but also the treat of thermal runaway and release of toxic chemicals into the air affecting the village of Mangoplah, the surrounding farmland, crops and livestock, but also leaking into the local waterways and creeks, in the event that a bushfire would over-run the proposed Mangoplah BESS project site.

It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk and being impacted so heavily. Please consider the fire risk and the added pressure posed to the local Rural Fire Service members and the broader community. In addition, changing the land use from farming to industrial will negatively impact Mangoplah’s rural setting and lifestyle. Please consider the cost to the Mangoplah community – their environment, their safety, their homes and many farming families who have been here for generations will all be at increased risk if the proposed Mangoplah BESS project goes ahead.

Pagination

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