Another foreign developer hell bent on destroying our environment. STOP STOP STOP. This project will have a short lifespan, serve only the project owner to profit playing the electricity market, add to fire risk in the area, be backed up by diesel generators, be toxic waste at end of life, enable more mining all over the world to produce the raw materials for the battery manufacture and likely more child/slave labour will be used in the mining of the raw materials.

Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of The increased risk of fire on hot dry windy weather conditions during construction of the Substation, adjoining 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 increased risk of fire on hot dry windy weather conditions during construction of the Substation, adjoining the proposed Mangoplah BESS project.

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, as stated by Ember Bushfire Consulting, 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.31, Bushfire Impact Assessment, 2025), therefore, 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.31, 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.31, 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. During this period, problematic fire weather is more common, being the combination of very hot days (i.e. 40 degrees Celsius and above) with low humidity (i.e. less than 10%) and strong westerly and north-westerly winds. 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”.

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.).

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.

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).

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.

Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of The risk of injury to local Rural Fire Service members with live electricity around the proposed Mangoplah BESS project site in the event of a fire.

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 risk of injury to local Rural Fire Service members with live electricity around the proposed Mangoplah BESS project site in the event of a fire.

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.

There are numerous hazards which may cause injury to a member of the local Rural Fire Service, which may include “ladders touching power lines, fallen or exposed powerlines or wiring, accidents involving electrical installations, electric shock, conduction through metal structures, hose streams or damp equipment, arcing of high voltages to earth through smoke/flame, step potential, and hazardous materials in electrical components.”(NSW Rural Fire Service). In addition, as stated in the Finley EIS Report, “Electrical equipment fires typically begin with smouldering, leading to slow fire development before full ignition occurs” (p.90, 2025), the report further states this is “not a unique fire scenario”…”the fire is expected to grow slowly” (p.90, 2025), this in turn, makes it difficult for the local Rural Fire Service members to be aware of the impact that may be occurring, in and around the vicinity of the proposed Mangoplah BESS project.

Moreover, electricity around the proposed Mangoplah BESS project “poses several electrical hazards to personnel and assets such as arc flashes, electric shocks, fires and explosions”(p.1, Saed Amer, 2022), moreover, “managing electrical fire risks is of growing significance…it is the leading cause of fire accidents costing personnel to suffer from severe injuries to fatalities” (p.1, Saed Amer, 2022). Moreover, “There are many hazards in a substation, however the primary hazards are: a. fire caused by overheating and damage of insulation which can be either due to overcurrent or short circuiting; b. arc flash which results from an arcing fault, where the electric arcs and resulting radiation and shrapnel cause fires, severe skin burns, hearing damage, and eye injuries, c. electric shock resulting from current flowing through the body interfering with muscle and central nervous functions; d. electrical burns resulting from the heating effect of the current which burns the body tissue; e. explosion caused by an arc flash and an arc blast” (Hurley et al. 2015, cited in Managing Electrical Fire Risks in Substations: A Framework to Protect Lives and Assets, 2022). These hazards are of major concern to the local Rural Fire Service members, who are volunteers who are not directly paid for their time, and are not volunteers to sacrifice their lives to protect the proposed Mangoplah BESS project in the event of a fire occurring near or within the area of the proposed Mangoplah BESS project site.

Moreover, “Rural firefighters need to exercise extra caution when responding to large-scale battery energy storage system (BESS) fires, as these systems pose unique hazards…” and pose significant injury risks to firefighters due to explosions, toxic gas release, and intense heat. Furthermore, the NSW Rural Fire Service state that “to mitigate this risk, firefighters wear protective clothing”, this can be extremely difficult in the event of a lithium-ion battery fire, due to the lack of appropriate protective clothing, including self-contained breathing apparatuses and structural firefighting gear, required to fight such a fire, this equipment is only at the disposal of appropriately qualified members and experienced to fight such a fire, according to the NSW Fire & Rescue. Furthermore, lithium-ion battery fires pose a significant thermal hazard, with fires reaching extreme temperatures ranging from 700-1000 degrees Celsius, additionally lithium-ion battery fires can produce toxic gases and potentially lead to explosions, further increasing the danger facing the local Rural Fire Service members.

Fire Risk and Safety to the local Rural Fire Service members with live electricity, is of major concern in the event of a fire occurring within the proposed Mangoplah BESS project. Causing problems with the local Rural Fire Service members not being able to get close enough to be able to fight the fire. As the NSW Rural Fire Service states that “personnel should remain at least 8 metres away from electrical hazards”, they go on to say that “members responding to incidents involving live electricity must prioritize safety by adhering to strict protocols. They need to identify and avoid electrical hazards, remain a safe distance from power lines and equipment, and ensure power is isolated before approaching”. This is of major concern, as this might take some time to notify the appropriate personnel of the incident and to have all power turned off to the location, which only adds more pressure on the local Rural Fire Service members to control a fire near the proposed Mangoplah BESS project site and adjoining Substation.
Moreover, are the community concerns regarding 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 (Bowman, 2025).

Fire Risk and Safety to the local Rural Fire Service members of getting heat radiation and radiation burns, is of major concern in the event of a fire occurring within the proposed Mangoplah BESS project site, which can be life changing for the local Rural Fire Service members who are aging volunteers. These fires also have the potential threat 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.

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.

Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of The risk of damage to other lithium-ion batteries within the proposed Mangoplah BESS project site in the event of an explosion.

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 risk of damage to other lithium-ion batteries within the proposed Mangoplah BESS project site in the event of an explosion.

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.

In the event of a fire involving large-scale lithium-ion batteries, the primary risk to other batteries is the potential for thermal runaway, which can lead to a chain reaction of fire and explosions. This can be triggered by factors like overheating, physical damage, or electrical faults. The spread of fire and toxic gases from one battery to another can cause rapid escalation of the incident, this was evident in the Geelong BESS fire in 2021, where the Megapacks were installed in close proximity to each other. Moreover, lithium-ion battery fires pose a significant thermal hazard, with fires reaching extreme temperatures ranging from 700-1000 degrees Celsius, further increasing the risks and danger facing the local Rural Fire Service members who are untrained and ill-equipped to fight such a fire. The Industrial Lithium-Ion Battery Emergency Response Guide, for Tesla Industrial Energy Products, further state that “Firefighters should wear self-contained breathing apparatuses (SCBAs) and structural firefighting gear” (p.17, 2024).

Furthermore, “Runaway reaction in a Li-ion battery cell, should it occur, can result in the generation of excessive heat inside or outside the cell which keeps on generating more and more heat. The chemical reactions inside the cell in turn generate additional heat until there are no reactive agents left in the cell” (p. 19, cited in Fire Safety study Broken Hill Battery Energy Storage System, 2023).

Moreover, according to Industrial Lithium-Ion Battery Emergency Response Guide
For Tesla Industrial Energy Products including Megapack and Powerpack it states that “If subjected to abnormal heating or other abuse conditions, electrolyte and electrolyte decomposition products can vaporize and be vented from cells. Vented gases are a common early indicator of a thermal runaway reaction – an abnormal and hazardous condition” (p.14, 2024). They further state that “In close proximity, vented gases may irritate the eyes, skin, and throat. Cell vent gases are typically hot; upon exit from a cell, vent gas temperatures can exceed 600°C (1,110°F). Vented electrolyte is flammable and may ignite on contact with a competent ignition source such as an open flame, spark, or a sufficiently heated surface. Vented electrolyte may also ignite on contact with cells undergoing a thermal runaway reaction” (p.14, 2024).

In addition, stating that “Prolonged exposure of the product to conditions beyond these limits may increase the potential of thermal runaway and result in a fire. Exposure of battery packs to localized heat sources such as flames may result in cell thermal runaway reactions and should be avoided.
Mechanical damage to the product can result in a number of hazardous conditions (discussed below) including:
• Leaked battery pack coolant
• Leaked refrigerant
• Leaked cell electrolyte
• Rapid heating of individual cells due to exothermic reaction of materials (cell thermal runaway), venting of cells, and propagation of self-heating and thermal runaway reactions to neighboring cells.
• Fire” (p.13, 2024).

The Industrial Lithium-Ion Battery Emergency Response Guide, for Tesla Industrial Energy Products gives these crucial information “In Case of Emergency” (p.13, 2024).
“WARNING: In case of emergency, severe physical impact, or transportation accident, do not approach the product or open any of its doors” (p.13, 2024), and
“WARNING: In case of severe physical impact or transportation accident, it may take time before any visible indication of an abnormal and hazardous condition (e.g., smoke or fire) can be observed. Contact Tesla for guidance” (p.13,2024), and
“CAUTION: Response should only be performed by trained professionals” (p.13, 2024).
The main question here is, where is the closest trained professional, and how long will it take for this professional to be onsite.
Furthermore, The Industrial Lithium-Ion Battery Emergency Response Guide, for Tesla Industrial Energy Products state that,
“During storage or operation, emergencies include but are not limited to:
• Suspicious odor observed near the product
• Smoke or fire emanating from the product
• Severe physical impact on the product
In case of emergency, isolate, deny entry, and perform the following:
1. If possible, and if trained and properly equipped, shut off the unit/system (see Shutting Down in an Emergency on page 18).
2. Evacuate the area.
3. If not already present, notify appropriately trained first responders, the local fire department, and any appointed subject matter expert (SME) if available.
4. Contact Tesla for guidance” (p.16, 2024).
Shutting Down in an Emergency
WARNING: Shutting off power to the product does not de-energize the battery, and a shock hazard may still be present.
WARNING: If smoke or fire is visible, do not approach the product or open any of its doors.
WARNING: In case of flooding, stay out of the water if any part of the product or its wiring is submerged.
To shut the product down in an emergency, perform the appropriate steps below and then contact Tesla…
Megapack System
1. If an external emergency stop (E-Stop) button or remote shutdown contact to the Megapack is present, engage it.
2. If the Megapack is serviced upstream by an external AC breaker or disconnect, open the breaker or disconnect”(p.18,2024).
Fire Risk and Safety to the local Rural Fire Service members of getting heat radiation, radiation burns, and injury is of major concern in the event of an explosion of a lithium-ion battery and fire occurring within the proposed Mangoplah BESS project site, which can be life changing for the local Rural Fire Service members who are aging volunteers. These fires also have the potential threat 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.

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.

Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of the Inappropriate recommendation by Samsung C&T Renewable Energy Australia (SREA) Pty. Limited to have an Asset Protection Zone of only 11 metres, around 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 Inappropriate recommendation by Samsung C&T Renewable Energy Australia (SREA) Pty. Limited to have an Asset Protection Zone of only 11 metres, around the proposed Mangoplah BESS project.

According to Australia Bushfire Protection Planners Pty. Limited, 2024, “Bushfire risk is defined as the chance of a bushfire occurring that will have harmful consequences to human communities and the environment” (p.19). They go onto say that “Risk has two elements: likelihood, the chances of a bushfire occurring and consequence, the impact of a bushfire when it occurs” (p.19). Most of the bushfires that occur within the area of Mangoplah and the surrounding farmlands, is the result of lightning strikes, moreover, are the prevailing adverse fire weather conditions, such as strong winds. Further exacerbating the risk of migration of a bushfire according to Australian Bushfire Protection Planners Pty. Limited, 2024, is “a fire in the landscape which is not effectively suppressed” (p.19), as a result a bushfire within the vicinity of the proposed Mangoplah BESS project site will be exposed and “has the potential to rapidly travel across the landscape…over-running the BESS site” (Australian Bushfire Protection Planners Pty. Limited, 2024).

This is of major concern to the residents of Mangoplah and the surrounding landholders, as 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), 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.

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).

Moreover, 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.31, Bushfire Assessment Report, 2025). Moreover, Ember Bushfire Consulting, state that “APZ…provide a buffer zone between identified hazards and structures”(p.31, Bushfire Assessment Report), Ember Bushfire Consulting go onto further state that “APZs are bands of managed vegetation that minimise fuel loads and reduce potential radiant heat levels, flame, localised smoke, and ember attacks” (p.31, Bushfire Assessment Report).

The NSW Rural Fire Service, also states that the proposed Mangoplah BESS 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.

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).

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).

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.

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.

Subject: Objection to the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of the Inappropriate use of RU1 land being used for a hazardous and offensive development.

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 Inappropriate use of RU1 land being used for a hazardous and offensive development.

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.

A hazard according to the NSW Department of Planning “is anything or situation with a potential for causing damage to people, property, or the biophysical environment” (p.6, Hazardous Industry Planning Advisory, Paper 6, Hazard Analysis).

Large-scale lithium-ion battery premises are generally classified as a hazardous development, or hazardous industry due to the inherent risks associated with lithium-ion batteries, particularly fire, explosion hazards, and toxic gas release, according to NSW Fire and Rescue, they go onto state “fire agencies internationally now recognise large-scale LiBESS as a hazardous electrical, chemical and fire risk with potential community consequence that necessitates special consideration throughout the design, installation and lifetime management of the asset” (p.2, Fire safety guideline Technical information, 2023). It was also stated in the Territory Battery Energy Storage System (TBESS) bush fire report by Australian Bushfire Protection Planners Pty Ltd., that the TBESS “proposal is classified as ‘industrial’ development”(p. 24). Generally, hazardous and offensive developments are prohibited in RU1 Primary Production Zones. As stated in the NSW Government Planning, “when considering strategic planning, the primary emphasis needs to be on the suitability of land for the proposed range of uses, having regard to existing risk exposure and the sensitivity of the current land use” (p.6, Hazardous Industry Planning Advisory, Paper 4, 2011). The NSW Government Planning, go onto state that “zoning for the purpose of industry with a potential for accidental release of ecotoxic material would be inappropriate in an environmentally sensitive area, such as in proximity to threatened species habitat or near a natural watercourse or waterbody” (p.6, Hazardous Industry Planning Advisory, Paper 4, 2011). Within, the area surrounding the proposed Mangoplah BESS project, there are several ephemeral waterways directly within the portions or in proximity of the involved lands, ranging from 1st Order Streams to 5 th Order Streams which include Paper Forest Creek, and Burkes Creek, a 6 th Order Stream which flows into the Murrumbidgee River.

Furthermore, the NSW Department of Planning states that “for development proposals classified as ‘potentially hazardous industry’…should the risk exceed nominated criteria of acceptability, the development is classified as ‘hazardous industry’ and may not be permissible within most industrial zonings in NSW” (p.1, Hazardous Industry Planning Advisory, paper 10, 2011). This statement by the NSW Department of Planning is interesting, when an explosion of a large-scale lithium-ion battery energy storage system (BESS) is a significant risk and can easily exceed nominated criteria of acceptability. Lithium-ion battery explosions can lead to uncontrolled fires, toxic gas release, and significant property damage, potentially causing harm to people and the environment.

Moreover, the NSW Government, in the NSW legislation, Section 4.15, states in (1) “Matters for consideration-general in determining a development application, a consent authority is to take into consideration such of the following matters as a relevance to the development…” (Environmental Planning and Assessment Act 1979 No. 203). Section 4.15, goes onto further state in (iv) “the regulations that apply to the land to which the development application relates, (b) the likely impacts of that development, including environmental impacts on both the natural and built environments, and social and economic impacts in the locality, (c) the suitability of the site for the development,…and (e) the public interest”.
It is of major concern that the residents of the village of Mangoplah and the surrounding landholders that RU1 land is being used for such a hazardous and offensive industry, when is documented by the NSW Government in the various Hazardous Industry Planning Advisory Papers that hazardous and offensive industries should not be built in such an area, also stating that should a potentially hazardous industry exceed the nominated criteria of acceptability, that that industry would not be permissible within most industrial zonings in NSW, so why should the proposed Mangoplah BESS project be allowed to be built within close proximity to the village of Mangoplah, to Livingston State Forrest and especially close to surrounding farmers, with toxic fumes from a lithium-ion battery fire affecting their livestock, soil, crops, and pasture grasses, resulting in loss of income, but the hazardous toxic plumes can also have a devastating impact on the ecosystem surrounding the area of Mangoplah.

It deeply affects and concerns me that a rural community like Mangoplah is being exposed to this degree of risk of having the proposed Mangoplah BESS project 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.

Subject: Objection against the Mangoplah Battery Energy Storage System – SSD-77527735.

Because of the Complete lack of engagement and social licence with the landholders near 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.

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.

“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, n.d.).

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 landholders in the vicinity of the proposed Mangoplah BESS project site, with Samsung C&T Renewable Energy initially sending letters to addresses in Mangoplah where there is no actual house. But even worse is the complete lack of consideration to the landholders surrounding the proposed Mangoplah BESS project site, not receiving these initial letters, only to receive them by secondary sources, this shows a complete lack of respect and disregard towards the surrounding landholders and the community of Mangoplah. As stated in the first letter to the ‘Resident’, of a non-existent address, “Our approach is focused on fostering respectful, transparent, and lasting relationships with stakeholders, particularly near neighbours, Council and the local community”. And in a second letter, to the ‘Resident’, also addressed to a non-existent address, states that “You are receiving this letter as you live within 4 km of the Project site”. This initial approach to engage with the immediate landholders in the vicinity of the proposed Mangoplah BESS project site is disgusting.

As stated by the Australian Energy Infrastructure Commissioner, “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 that “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, Annual Report to the Parliament of Australia, 2022).

Samsung C&T Renewable Energy Australia (SREA) 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).

Furthermore, The Australian Energy Regulator, state that “effective engagement is necessary to build the social licence” (p.9, Direction Paper, 2023), they go onto say that “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, Direction Paper, 2023). The community of Mangoplah and the surrounding landholders feel that there has been a complete lack of social licence, as 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 and the surrounding landholders, this is evident with Samsung C&T Renewable Energy Australia (SREA) Pty. Limited, not informing the surrounding landholders directly initially about the proposed Mangoplah BESS project, instead of sending letters to non-occupant addresses, instead of sending them directly to the landholders in the vicinity of the proposed Mangoplah BESS project.

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 (SREA) 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).

Furthermore, in a Newsletter sent to the Mangoplah community and surrounding landholders in July, 2025, Samsung C&T Renewable Energy Australia (SREA) Pty. Limited stated that “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 a 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 a 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 I feel will negatively impact upon Mangoplah’s rural setting and lifestyle. I take it upon you to consider the cost to the Mangoplah community and 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 proposed Mangoplah project to be constructed in such an inappropriate and ill-chosen location.

Our prime agricultural land is the nation’s biggest asset; its fertile productive lands enable us to independently feed our nation & export to the world. Our prime agricultural land should only be used to grow, beef, lamb, milk/dairy products, fruits/vegetables/grains and many other items of fresh food for Australians…It should not have been recategorized to allow it to be used to GROW industrial battery factories.

The proposed site is Prime Agriculture land and following are my supporting arguments with links.
https://nff.org.au/wp-content/uploads/2020/09/2019.10.16_Policy-Summary_NRM_Prime-Agricultural-Land.pdf

“As at 30 June 2017, approximately 51 per cent of Australia’s landmass was managed by farmers. Agriculture remains Australia's dominant land use, covering around 372 million hectares (ha). However, the area of agriculture holdings is declining, with a reduction of about 14 per cent (almost 66 million hectares) between 1992-93 and 2016-17. Thus, any land use changes/zoning at the regional and local scale have the potential to significantly affect the agriculture sector.”

The EIS Soil Technical Report prepared by NHG for Samsung -https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=SSD-77527735%2120251107T023730.101%20GMT states that the land on which the Mangoplah Bess will be put has been classed as Class 4 under the NSW Land and Soil Capability Assessment scheme (NSW OEH, 2012) which describes and maps 8 land and soil capability classes.

The classes range from 1 (best, highest capability land) and 8 (worst, lowest capability land). This EIS Soil report goes on to say “A search of the Central Resource for Sharing and Enabling Environmental Data in NSW (SEED) database 01 May 2025 indicated that the subject land is mapped with the following features with a low data confidence as Land and Soil Capability (LSC); Class 3, Class 4 and Class 5… It also states “The BESS infrastructure would be located on Class 4 capability land”

Samsung’s own EIS Soil Technical report goes on to actually state the following: -
“3.3. Site Observations
“The Project Site was observed to be gently undulating. The site is flat to gently rolling hills. The access track is devoid of plant growth; however, the edges of the track and the surrounding land have areas of dense native remnant vegetation of both grasses and overstory plant species. The Project site is predominantly covered in dense harvested crop with an opportunistic self-sown crop of canola emerging underneath. The land adjacent to the Project site on all sides has historically been used for dryland cropping and grazing enterprises.”

It is clearly obvious from Samsung's own soil report & the photos they have attached that the proposed site for the Mangoplah Bess actually meets the Class 3 Soil Classification as it has been continuously cropped for 8 years; has no signs of erosion; and has soil suitable for all crops including lucerne.

Here are the two class descriptions as regards to cropping capability, for your comparison.

LSC Class 3 Description Class 3 Class 3 land includes sloping land that is capable of sustaining cultivation on a rotational basis. This land can be readily used for a range of crops including cereals, oilseeds and pulses. Productivity will vary with soil fertility

LSC Class 4 Description Class 4. Class 4 land can be cultivated occasionally for sowing of pastures and crops. However, it has cropping limitations because of erosion hazard, weak structure, salinity, acidification, shallowness of soils, climate, wetness, stoniness or a combination of these factors. It is only suitable for intermittent cultivation with specialised practices. Class 4 land has a high potential as grazing land.

I also submit further evidence that the proposed use of the Mangoplah BESS site is not appropriate when you read the descriptions of various classes of land under The Agricultural Land Classification cited by the NSW Department of Agriculture in this Agfact cited below – I have quoted the specific relevant sections.

NSW Agriculture (2002) Agricultural Land Classification Agfact .25
https://www.makingmorefromsheep.com.au/globalassets/mmfs/manual/module-6/chapter-1/chapter-6.1-signpost/nsw-ag-land-classification.pdf

“Land used for agriculture is often taken for granted. The popular belief is that Australia possesses unlimited resources, including land for agriculture. Yet good quality agricultural land is a limited resource, and is under threat from a variety of sources. Urbanisation and land degradation alienate and deplete agricultural land resources. The reduced availability of lands highly suited to agricultural production reduces the sustainability of existing agricultural systems and encourages the use of more marginal lands for agriculture. A knowledge of the relative suitability of land for agriculture will help with the development of strategic plans, which protect land highly suited to agriculture and identify land more suited to non-agricultural activities.”
“NSW Agriculture’s agricultural land classification maps can be used to recommend the quality and quantity of rural land that should be zoned for agricultural production and protection from incompatible development.”

“Land use planning recommendations need to be drawn up on the basis of local government areas using the principle of protecting the land of greatest agricultural value, and directing non-agricultural uses onto lands less suitable for agriculture. Following are some general principles, which may help in formulating land use planning recommendations…

• Protect Class 3 lands for agricultural production if adequate and suitable areas of Classes 4 and 5 are available for competing uses.”

I have attached a word document with a table comparing the description of both Class 3 & Class for in the NSW Agriculture (2002) Agricultural Land Classification Agfact .25

This proposed BESS puts at risk the natural resources, such as groundwater, on which prime agriculture production relies and also puts at risk our international reputation as producers of safe food (e.g. by the risk of land, air and water contamination from the escape of toxic chemicals used & produced by the energy production process or in a fire event).

Governments & planning authorities need to recognise the importance of consulting the local communities which have a deep understanding of local issues, challenges and opportunities, especially for projects of significant scale and likely impact on their prime agriculture land and businesses. The consultation to date from Samsung has been subpar.

We all must recognise that prime agricultural land is an irreplaceable resource that must be protected from permanent loss for agricultural use.

Additionally, the legitimate prospect of farmer's land being devalued due to a neighbouring BESS must be compensated fully if this project gets approval. A property owners' land value must NOT be negatively impacted by reckless rezoning of land, just to accommodate, mostly international companies, wishing to avail themselves of the huge tax payer funded subsidies for renewable projects that our government is offering.