Community for the Accurate Impact Assessment of the Dalton Power Station (CAIAD)

Director, Major Infrastructure Assessment
Department of Planning
Sydney NSW 2001 September 19, 2011

Dear Sir/Madam,

SUBMISSION IN RESPONSE TO THE ENVIRONMENTAL ASSESSMENT OF THE AGL DALTON POWER PROJECT 

The Community for Accurate Impact Assessment of the Dalton Power Station (CAIAD) hereby submits this response to the above Environmental Assessment report.

We object to the proposal on a number of grounds, as follows:

  1. Inaccuracies, inconsistencies and omissions in the Environmental Assessment (EA) report particularly regarding noise and air quality
  2. Excessive cumulative negative effects of building Stage 1 and Stage 2 which effectively amounts to building two power stations on the one site with commensurate impacts on air quality, noise levels and scarce water
  3. Insufficient account of the adverse meteorological conditions (such as temperature inversions) of the region in the noise and air quality
  4. The maximum cumulative 1 hour level of NO2 emissions exceeds the Australian standard summer temperature adjusted limit of 214μg/m3.
  5. Lack of verified noise emission data for the turbines and stacks which have never before been used in There is a track record of power companies incorrectly modelling noise impacts on communities, with people subsequently forced from their homes by intolerable noise levels, and therefore extensive empirical data needs to be obtained and independently and expertly assessed.
  6. There is no justification for the power station, and certainly not for one of this scale, on the basis of supply need in the electricity No additional capacity is needed in NSW for seven years.
  7. The proposal is inconsistent with the aims of Upper Lachlan Shire LEP 2010 to: “encourage conservation of natural resources”; and “promote the use of rural resources for agriculture and primary production”, as electricity generation at the location risks depleting water resources that are currently available for interdependent ecosystems and agriculture.
  8. Inadequate community consultation, with impacts on the community not properly identified and disclosed.

As such CAIAD asks for:

    1. An inquiry into the Uranquinty power station to determine why the actual noise and vibration impacts have exceeded those predicted in the Uranquinty Environmental Assessment report, and the resulting economic impacts for that community.
    2. An independent expert assessment of the noise, vibration and air quality impacts once specific turbines and stacks to be installed are confirmed. It is understood that the turbines have been confirmed as General Electric 9FA turbines. However actual stack configuration is uncertain. The community asks that prior to construction, the sound power levels of the actual plant is verified by ‘real world’ empirical data to ensure claimed outputs are achievable.
    3. An independent expert assessment of the appropriate acoustic model and modelling parameters for adverse meteorological conditions, given that worst case meteorological conditions for noise propagation and air quality occur frequently in the region.
    4. An enduring limit on the size of the power station to Stage 1 with operation not to exceed 15% of the time (and 5% of the time where water is required).
    5. Any approval to contain stipulations that noise (both A-weighted and C-weighted) and air emissions may not exceed NSW government limits during typical as well as adverse weather conditions. Given that the proposal is based on assumptions about emissions, there is considerable risk to the community, which means careful specification, monitoring and enforcement of limits will be essential.
    6. An independent expert assessment of available water in the area to ensure existing water users and interdependent ecosystems are not adversely impacted by the project.
    7. A letter to all residents within a 6km radius informing them of AGL’s proposal to build the Dalton power station. The letter needs to inform the public about the potential negative impacts for neighbouring properties and the measures AGL is taking to ensure negative impacts are minimised. Also we ask that residents 10 km away, identified as impacted with peak levels of pollutants from the power station, are contacted and given an assurance that pollution levels will be well below recommended levels.

It is appreciated that there needs to be a balance between development of industry and preservation of amenity. This balance can be achieved with an accurate assessment of the impacts, limiting negative impacts to NSW Office of Environment and Heritage (OEH) and the World Health Organisation (WHO) guidelines, and avoiding cumulative negative impacts by restricting the development to Stage 1.

Please contact me if I can be of additional assistance in relation to the information presented in this submission.

Yours sincerely,
Andrea Strong
For CAIAD 19 September 2011

Download the complete submission including appendices →

Read the CAIAD submission to the 2012 Renewable Energy (Excessive Noise) Inquiry