Attachment – Summary of NPA Submission on Snowy 2.0 Main Works EIS
Kosciuszko National Park (KNP) was gazetted as a conservation reserve to ensure that Australia’s rare alpine landscapes are protected in perpetuity. The concept of perpetual protection is not simply a function of the NSW National Parks and Wildlife Act (NPW Act), but represents an internationally binding commitment to future generations.
National Parks are not held in trust for undefined future purposes. The act of declaring a national park confirms that area’s essential role in conserving our nation’s natural and cultural heritage. Proposals that diminish a park’s conservation, recreation and education values are inherently inconsistent with the purposes for which National Parks are declared. In planning terms, this imposes an especially high level of sensitivity to any proposals that threaten the ecosystem processes or conservation values.
NPA has carefully reviewed Snowy Hydro’s case for the Snowy 2.0 proposal. Rather than finding a compelling argument for damage to the National Park, we conclude that the exhibited EIS trivialises the environmental impacts on KNP while overstating the claimed benefits to the Australian community. The EIS does not provide a thorough assessment of energy storage that avoid major impacts on the National Park. Instead, the proposal is framed as though Snowy Hydro holds exclusive landowner rights over KNP and has no obligation to consider other ways of delivering the project’s energy storage outcomes. We conclude that the EIS is driven by Snowy Hydro’s commercial interests rather than the national interest.
Snowy 2.0 represents the single largest and most destructive development ever proposed for a NSW National Park. Approval would undermine the integrity of the state’s reserve network and set a powerful precedent for large-scale development in conservation reserves. We are particularly concerned by the implication that reserves are available for development provided a project makes claims for climate abatement.
NPA concludes that the EIS systematically understates the environmental costs and overstates the benefits of the project, and that when the principles of Ecologically Sustainable Development are applied, the costs significantly outweigh the benefits. We recommend that Minister Stokes refuse approval for the Snowy 2.0 Main Works EIS.
The major environmental impacts of Snowy 2.0 are listed below:
Area of impact on Kosciuszko National Park
- the ‘project area’ (as defined by Snowy Hydro) covers 250,000 ha, one-third of Kosciuszko National Park (twice the area of Greater Sydney, greater than the area of the ACT)
- physical disturbance to 1,680 ha, with a total loss of 1,053 ha of native vegetation including 992 ha of habitat for 14 threatened species
- permanent broader impact to 10,000 ha (100 square kms) of the Park through depressed water tables and stream flows, new or expanded roads and tracks, altered aquatic environments in the two reservoirs, transmission lines, spread of pest species (even beyond Snowy 2.0 and the Snowy Scheme)
- 14,000,000 cubic metres of excavated rock dumped in the Park (enough to cover a football field by 3 kilometres high)
- approximately half having naturally occurring asbestos and/or being acidic
- unbelievably, 8,000,000 m3 to be dumped in Talbingo and Tantangara Reservoirs, decreasing their storage capacities
- 6,000,000 m3 dumped on Park land (minor amount for roadworks and structures)
Major construction works and infrastructure
- major infrastructure at Tantangara, Marica, Lob’s Hole and Talbingo
- involving land clearing and reforming, 3 accommodation camps (over 2,000 workers), rock dumps, electricity substations, works areas and permanent infrastructure
- 100 km of new, widened or upgraded tracks and roads
- a major two-lane sealed road down the precipitous mountainside to Lob’s Hole, requiring extensive cutting and land-reforming
- two side-by-side high voltage transmission lines traversing 10 km of the Park
- associated access tracks
- easement swathe 120 metres wide
Depressed water table above the 27 km tunnel
- in some sections by over 50 m
- up to 2 km either side of the tunnel
- drying up streams and bogs, killing off habitat and native species (some threatened)
- reducing inflows to Snowy reservoirs and downstream rivers
Spread of pests, weeds and pathogens
- pests spread throughout the Snowy Scheme and downstream
- transporting pest fish, including Redfin Perch (a Class 1 Noxious Fish), Eastern Gambusia and Wild Goldfish (and fish diseases), from Talbingo up to Tantangara Reservoir (pest-free) and the Murrumbidgee catchment, and thence throughout the Snowy Scheme and downstream rivers
- fluctuations in the water level of Tantangara Reservoir of up to 5 metres a day, resulting in shoreline movements of hundreds of metres, dramatically affecting the aquatic ecology and public amenity:
- when empty Tantangara will be a puddle surrounded by an extensive mud/dirt shoreline over 2,000 ha
- the reservoir will become nothing more than a holding tank and an eyesore
- transmission lines, roads and tracks, infrastructure and landscape scars seen from over tens of thousands of hectares