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

Because of The extreme risk of a bushfire occurring in the vicinity of 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 extreme risk of a bushfire occurring in the vicinity of 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).

Moreover, according to the NSW Government, under Part 4 Bush Fire Prevention, Division 1, Section 63, Duty to prevent bush fires, “it is the duty of the owner, or occupier of land to take the notified steps (if any) and any other practicable steps to prevent the occurrence of bush fires on, and to minimise the danger of the spread of bush fires on or from, that land” (2025).
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 a buffer or Asses Protection Zone of only 11 metres. Furthermore, in Appendix J, Bushfire Risk Assessment Report, for the Jindera BESS, it also recommends that an Asset Protection Zone of “30 m from nearest BESS Site equipment” (p.26,
2025).

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).

Furthermore, as stated by Cool Burn Pty. Ltd., “BESS developments are not specifically considered” in the NSW RFS Planning for Bush Fire Protection,(PBFP) 2019, “however, the energy storage would be considered as a ‘hazardous industry’”(p.15, Yanco Battery Energy Storage System, EIS, 2024). With the NSW RFS (PBFP), 2019 stating that, “some developments are considered by their very nature to be hazardous, as much for their ability to start bushfires as their susceptibility to bushfire impacts. New developments of this nature should be avoided on Bushfire Prone Land (BFPL)” (p.79).

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).

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 Very high risk of toxic exposure to livestock in the surrounding farmlands because of fumes from a lithium-ion battery fire at 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 Very high risk of toxic exposure to livestock in the surrounding farmlands because of fumes from a lithium-ion battery fire at 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.

It is well noted that lithium-ion battery fire produces toxic and dangerous chemicals, such as hydrogen fluoride and carbon dioxide into the atmosphere, which can result in numerous health problems in livestock including “damage to the lungs, liver, and kidneys has been observed in animals acutely exposed to hydrogen fluoride by inhalation” (Hydrogen Floride-Hydrofluoric Acid, 7664-39-3), furthermore, “exposure to fluoride has caused impaired reproduction and malformation of fetal bones and teeth” (Hydrogen Floride-Hydrofluoric Acid, 7664-39-3). In addition, these heavy metals can also cause neurological, renal, reduced fertility, milk contamination and growth retardation in livestock (supplied by Professor B. Allworth, CSU, 2025).

It was recommended in the Territory Battery Energy Storage System (TBESS), located near Belconnen, in the ACT, that all residents within a “20km distance shall be notified to shelter in the event of a BESS fire” (Neon Territory Battery, EIS, 2024), it goes onto state that if exposed to “concentrations of hazardous airborne chemicals for one hour, most people will begin to experience health effects if exposed to these chemicals” (Neon Territory Battery, EIS, 2024). Furthermore, Umwelt Environmental & Social Consultants state that “mild health effects could be experienced by people within…10.5 km of the fire” (p.258, Neon Territory Battery, EIS, 2024), with Umwelt Environmental & Social Consultants going on to state that “the severe case would occur when a battery fire is exposed to water, e.g. from rain or during fire-fighting…HF gas would be dispersed up to 33% further…”(p.258, Neon Territory Battery, EIS, 2024). Additionally, these hazardous airborne chemicals can travel further in adverse windy weather conditions, as a result the evacuation, shelter notification area will need to be increased (Umwelt Environmental & Social Consultants, 2024).

Putting the livestock in the surrounding farmlands into shelter would be extremely difficult and totally out of the question, as a result all the livestock, and animals in the surrounding farmlands, will be greatly exposed to these toxic and dangerous chemicals, resulting in damage to the respiratory and nervous system, similar to human life. The question then being are the livestock that have been affected, will they need to be tested, will they be able to be sold through the normal channels, or will they need to be slaughtered on farm and disposed of in a certain way, yet to be determined, because fortunately this has not yet happened in Australia. The question is who is liable for the damages to the surrounding landholder’s livestock, according the Meat and Livestock Australia, these environmentally hazardous toxic fumes will have long term collateral impact affecting Australia’s livestock industries” (2001).

Notifying residents within the village of Mangoplah and surrounding landholders would be extremely difficult, as the question being firstly how the Rural Fire Service members are notified of these toxic chemicals leaching into the atmosphere, then the question is how does everyone get notified within the recommended time. In addition, around the area of Mangoplah and the surrounding landholders, there is poor mobile reception, as well as ‘black spots’, which will add to the inability for residents of Mangoplah and the surrounding landholders to be notified in the appropriate time frame.

It is of major concern in the event of a lithium-ion battery fire occurring within the BESS, which can be life changing for everyone in the village of Mangoplah and the surrounding area, resulting in major health problems including damage to the lungs and nervous systems. 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 is not a place to build such a project.

It is of major concern in the event of an explosion of a lithium-ion battery and fire occurring within the proposed Mangoplah BESS site, can be life changing for everyone in the village of Mangoplah, especially the farmers in the surrounding area with their livestock breathing in the toxic fumes from a lithium-ion battery fire, resulting in major health problems including damage to the lungs and nervous systems, in turn these animals will need to be slaughtered, resulting in loss of income for farmers. 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.

I object and do NOT consent to this project for the following reasons:

The fact that this project and other similar renewable projects are connected to potentially flammable and dangerous high voltage transmission lines and towers. For example:

Just over sixteen years ago, on the 7th of February 2009, 6 out of the 11 Black Saturday fires that took 173 lives and did untold damage to property, livestock and wildlife, were started by high voltage transmission lines. This was such a devastating, large scale catastrophe that a Royal Commission was called to investigate why these fires happened and how they could be prevented in the future - VBRC_Summary_PF.pdf, Remembering Black Saturday - 15th anniversary | Emergency Victoria. 

Cameron Stuart of Brittanica.com on the 20th of January 2025 (Black Saturday bushfires | Causes, Deaths, Map, & Location | Britannica), described the horrific, catastrophic, devastating Black Saturday fires in detail:

"On February 7 Victorians were told to brace for the “worst day” in the state’s history: weather forecasters warned of a record heat wave with temperatures soaring to 115.5 °F (46.4 °C), combined with gale-force winds of up to 56 miles (90 km) per hour. That day more than 47 major fires erupted across the state, 14 of them claiming lives or causing significant damage. The most deadly conflagration, known as the Kilmore East fire, which claimed 121 lives, was sparked by a faulty power pole near the township of Kilmore East, 37 miles (60 km) north of Melbourne. The flames quickly jumped a major highway and roared into a forest, where they turned into a giant fireball, dwarfing the resources of local firefighters, who could only flee in its path. Aided by steep slopes and powerful winds, this fire raced through a series of townships, including Kinglake (where 38 people died), Strathewen (27 perished), and St. Andrews (12 were killed), catching residents by surprise and trapping many in their homes. Some sought to escape by car as the fires approached, but dozens died on the roads as they were overtaken by the fire, which leapt 330 feet (100 metres) above the tree line and was powerful enough to kill with radiant heat from nearly 1,000 feet

Late in the afternoon a sudden change in wind direction pushed the fire to the northeast, bringing new towns into its path. A parallel fire, known as the Murrindindi fire, also blew to the northeast, swallowing the unsuspecting tourist town of Marysville, where 34 people lost their lives. Fire experts said that these two fires alone released energy equivalent to that of 1,500 atomic bombs like the one dropped on Hiroshima, Japan."

Fire experts said that these two fires alone released energy equivalent to that of 1,500 atomic bombs like the one dropped on Hiroshima, Japan."

Not only are lithium battery factories extremely dangerous, but they are also deadly Lithium battery factory fire kills 22 in South Korea. 

In California, it was reported that it was PG&E's powerlines that had sparked the recent horrific and deeply devastating fires - , How Did The California Wildfires Start? Officials Weigh Power Lines, Fireworks—And Arson (forbes.com), PG&E’s Lengthy Record of Starting Wildfires, and What the Company Is Doing to Change It (californialocal.com) and in fact, PG$E was found to be responsible for the worst fire in California history - the Camp Fire (Customers of PG&E, other utilities pay billions for wildfire prevention- CalMatters)

"POWER LINES AND ELECTRIC INFRASTRUCTURE
----------------------------------------

Multiple residents of Altadena sued Southern California Edison on Monday, alleging the Eaton Fire was started by the company’s electrical equipment. The lawsuits cite eyewitness reports of sparking power lines. The company has pushed back against the theory, saying in a statement Sunday its “analysis shows no interruptions or operational/electrical anomalies in the 12 hours prior to the fire’s reported start time until more than one hour after the reported start time of the fire.” One of the filed complaints reportedly alleged, “there is clear evidence from video footage, photographs, and witness accounts that the fire was caused by electrical equipment operated by Defendants Edison International and Southern California Edison.” Power infrastructure has been a leading cause of fires in California in the past—with eight of the state’s 20 most destructive fires having power-related causes—and the amount of fires started by equipment has grown recently, The New York Times reported."

Interestingly enough,, prior to the recent wildfires in California, PG&E had a mitigation plan, which as you can very plainly see did NOT stop the extremely horrific, deadly and destructive California Wildfires from happening, much less actually put them out, and so now, what will happen to all the taxpayers who lost their homes, livelihoods, pets, etc because of PG&E's powerlines sparking the tremendously fast moving fires throughout Southern California, doing untold damage, along with taking lives?  (TN13803_20240402T112956_PGE's_2025_Wildfire_Mitigation_Plan_Update.pdf).

And then there is the astronomical and, in my opinion, completely irresponsible and unjustifiable cost of these renewables:

Stated in the 2025 SUBMISSION TO CSIRO'S DRAFT 2024-25 GENCOST REPORT.pdf

"3.0 Capital Cost Factors GenCost defines future capital cost factors 6 for various generation and storage technologies. It observes recent years when freight and raw materials rapidly increased costs. Its use of a 2006 to 2009 price bubble to show prices returned to previous expectations is not entirely realistic since the industry was much smaller at that time and basic power costs affecting manufacturing have been recently escalating much more rapidly. GenCost’s contention that “…inflationary pressures for most technologies and the cost of some…such as solar PV and batteries are falling again” is contestable. We believe this is only a small part of the story. In our view: • Renewables are now relatively mature technologies after 30 years of intensive development, thus making assumptions of substantial future cost decreases too optimistic. • Labour costs have been hit with high inflation recently; these costs are not going to go down. • The dominance of one country, China, in the entire supply chain for renewables makes higher future prices likely as competition is stifled and hence deserves more careful analysis. • Increasing demand in global markets may cause price rises. • Shipping costs are being hit by increasing fuel costs. • Operating costs of renewables are greater than anticipated, as the UK and Germany have found. • Subsidies for the cheapest form of electricity generation, which surely should not still be necessary) could be reduced, adding to manufacturing costs. Compounding the uncertainties in predicting future costs are: a. realisation that the extraordinary costs involved are not affordable nor sustainable, b. the negative impact on national economies from unreliable intermittent power, c. many countries, including the largest, doing nothing or very little, to meet Net Zero goals, d. the withdrawal of the US from the Paris Accord, e. the mounting market failure of EVs, f. recognition that the science of climate catastrophism is overstated and overhyped, and g. the severe environmental impacts of solar and wind generation installations being regarded as unacceptable. 6 GenCost Section 5 P3"

This report/submission was written by 19 independent engineers and professionals who are all well qualified to comment on the true costs of implementing the government’s Net Zero 2050 policy for the National Electricity Market (NEM):

Professor Michael Asten, PhD, BSc (Hon), BLitt, FRAS Ben Beattie, BE(Elec), CPEng RPEQ Jeremy Barlow, BE, MBA, FAIMM William Bourke, BSc, BEng (Aero), MEng Sc. Michael Bowden IEng (Electronics-UK); CPL; CQP Rafe Champion, MSc (History and Philosophy of Science), B.Ag.Sc. (Hons) Arthur Day, PhD, BSc (Hon) Paul R C Goard, BSc, Physicist, M.A.I.P., M.I.of P., M.A.I.E., M.A.M.O.S. Peter J F Harris, BEng, Dipl. Prod Eng. Professor Emeritus Aynsley Kellow, BA(Hons) PhD Bryan Leyland, MSc (Power systems) DistFEngNZ, FIMechE, FIEE (rtd) John McBratney, B. Tech (Electronic Engineering), formerly MIE Aust, MIEEE John McLean, PhD Paul Miskelly, BE MEngSc Electrical Engineering Grant Piper, BE Aero UNSW, FRAeS, Chair NREN Peter Ridd, PhD, BSc James R (Jim) Simpson, (Ret., former business unit manager, OTC & Telstra) Bill Stinson, Dip.Tech(Building), B.AppSc.(Building), Dip Labour Relations & Law, Cert. Design Sc. (Facilities) James Taylor, PhD, MSc, BEng Elect (Hon), PEng, FCASI

In addition, developers, NOT landowners, farmers or people who host renewables should be made to not only pay full decommission costs of these renewables, they also should be held solely responsible, along with the planning commission and government to ensure that no electrical bushfires breaks out of the renewables, high voltage transmission lines and towers, wind turbines, Battery storage units, solar "farms" (farms is a misnomer indeed) and any other energy infrastructure, NOT landowners, farmers or people who host renewables. https://braddonbeagle.com/do-we-have-a-do-as-i-do-or-do-as-i-say-government-you-decide/

Australia’s manufacturing capacity has been sacrificed by the unreliable, unaffordable, weather dependent RUIN-A-BULL EXPERIMENT!

The collapse of Australia’s only battery manufacturer seemed designed to fail - leaving our nation fully dependent on imports - predominately from our most hostile enemy - wrecking our sovereignty and security.
Australian Financial Review, 2025
“Crying Shame: Inside the Demise of Australia’s Only Battery Maker”

THIS BESS IS OUR ENEMY!

There are no benefits whatsoever from this ruinable junk that’s a poisonous curse to the public, our essential energy security, food security, our economy and sovereignty.

The predatory vested interests are manipulating the market - profiteering at our expense - while we all suffering the Government inflicted Cost of Living Crisis - caused by intermittent RenewaBULLs and BESS that profits from price volatility and arbitrage, distorting electricity markets and increasing costs for consumers.

This CCP reliant, filthy rip-off, BESS plan’s ridiculously short 10 year life span and endless replacement makes no sense!
It defies all aspects of the National Electricity Law Objective regarding:-
(a) price, quality, safety, reliability and security of supply of electricity;
and
(b) the reliability, safety and security of the national electricity system

This BESS creates a cycle of constant replacement, contamination, ever escalating toxic waste and austerity from rising costs.