NPA submission guide for the Snowy 2.0 Main Works EIS

The Environmental Impact Statement (EIS) for the Main Works phase of the Snowy 2.0 project, released on 26 September 2019, proposes immense and permanent damage to the rare montane habitats of Kosciuszko National Park.

National Parks Association of NSW (NPA) strongly urges everyone concerned about the unique flora and fauna of Kosciuszko National Park and the principle that National Parks are for conservation, not commercial development, to make a submission on the EIS.

NPA is not opposed to pumped hydro storage.  There is no question that additional electricity storage capacity is needed as renewable generation expands.  However, this doesn’t mean that pumped hydro projects require any less scrutiny than any other construction projects, especially when they are proposed in one of the most precious and delicate parts of our nation. The case for Snowy 2.0 simply doesn’t stack up on environmental or economic grounds.  There are better alternatives, ones that avoid catastrophic impacts on Kosciusko National Park.

Snowy 2.0 is the wrong project in the wrong place.

Submissions close on 6 November 2019


Making a submission

Unfortunately, the process for making a submission requires you to first register with the NSW Department of Planning and Environment. You can create an account here: https://majorprojects.planningportal.nsw.gov.au/prweb/IAC/

NPA has prepared a summary of the major impacts of Snowy 2.0 along with a sample submission. We encourage you to write the submission in your own words using these as guides.

The full EIS (many 1,000’s pages) and Snowy Hydro’s summary of the environmental impacts of Snowy 2.0 can be viewed at: https://www.planningportal.nsw.gov.au/major-projects/project/12891


Key talking points on the predicted impacts of Snowy 2.0

  • The ‘project area’ described in the EIS is 250,000 ha, one third of Kosciuszko National Park and three times the size of metropolitan Sydney.
  • The EIS seriously understates the full environmental impact on the Park, which, when vegetation clearance, earthworks, dumping and damage to streams and water-dependant ecosystems are included will exceed 10,000 ha. 
  • Even the EIS admits that the Main Works will ‘disturb’ 1,680 ha, clear 1,053 ha of native vegetation and destroy 992 ha of threatened species habitat.
  • 14 million cubic metres of excavated spoil, some of which contains asbestos and/or is acidic, will be dumped in Kosciuszko National Park. Most of the spoil will go into Talbingo and Tantangara Reservoirs, decreasing their storage capacities, with the remainder to go into roads or to ‘landscape’ the park.
  • Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Under normal circumstances these would not be allowed within a National Park, so why under Snowy 2.0?
  • Two side-by-side high voltage transmission lines for 10 km through the Park, with a 120m wide easement swathe.
  • Snowy 2.0 requires tunnelling through 27 kms of rock. This will depress the water table in some sections by more than 50 m and have an impact for up to 2 kms either side of the tunnel. This will lead to montane streams and water dependant alpine bogs drying up, further impacting upon vulnerable habitats and native species. It will also lead to a reduction of inflows to Snowy reservoirs and downstream rivers. These river systems are already under threat from feral animals and global heating. Any works that threaten water quality and quantity must be avoided. 
  • Noxious pests and weeds will be spread throughout the Snowy Scheme and downstream, including Redfin Perch (a Class One Noxious Pest) and aquatic weeds.  These pests and weeds will be transported from Talbingo Reservoir up to pest-free Tantangara, the Upper Murrumbidgee catchment, and then to Eucumbene and throughout the Snowy Scheme and downstream rivers.
  • Kosciuszko National Park is one of the most loved and frequently visited Parks in Australia. Snowy 2.0 will put off future visitors by its visual blight on the pristine montane landscape from vantage points over thousands of square kilometres.  Who wants to see transmission lines and major civil engineering structures in a natural landscape? And who will want to fish in Tantangara anymore, with introduced pest species?
  • The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0.  How can such an environmentally destructive development be proposed without an exhaustive exploration of viable alternatives? Kosciuszko is a National Park, not an industrial park!
  • Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector.  Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. Worse still, Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
  • Not only is Snowy 2.0 environmental vandalism, it isn’t economic.  The original $2 billion cost estimate is now approaching $10 billion, including transmission.
  • Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why were these alternatives, together with batteries and other forms of storage, not explored before proposing construction of such a huge project within a National Park?
  • Never before has a project of such immense size and environmental destruction been proposed within a National Park.

Sample Submission

Snowy 2.0 ‘Project Area’ (Main Works EIS)

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