Homebush Battery Energy Storage System (BESS)

46706

Save Our Surroundings Riverina

New South Wales 2650

17/07/2026

Object

Website

Homebush Battery Energy Storage System IPCN Objection Submission Homebush 200 megawatt / 431 megawatt-hour BESS Represents an Unacceptable Risk to Public Health and Safety, Our Essential Air, Irreplaceable Land, Vital Water Sources and Surrounding Ecosystems. The Applicant and Department - who always fail by implicitly trusting the vested interest applicants - presents the Battery Energy Storage System as routine infrastructure supporting the electricity network. It is not. A utility-scale lithium-ion Battery Energy Storage System is a hazardous industrial facility capable of catastrophic failure through thermal runaway, prolonged fire, toxic gas release and widespread environmental contamination. Unlike many industrial hazards, these risks cannot be eliminated. They can only be managed after they arise. That reality alone demands an extremely high level of independent, expert scrutiny which has not been applied in the Environmental Impact Statement or the Department’s Assessment and Conditions of Consent. The Applicant has failed to demonstrate that the risks associated with this development have been comprehensively identified, independently assessed and shown to be acceptable. The Department has typically and unacceptably failed to do the essential, diligent Risk Research for this hazardous Homebush BESS and any of the toxic contaminating Solar/Wind Electricity Generating Works and Battery Energy Storage Systems they and the IPCN have already, unconscionably approved. Homebush Bay Drive Must Not Become a Hazardous Industrial Battery Precinct The site is inappropriately situated where lots of people are around, right next to the extremely popular DFO Homebush (Direct Factory Outlet,) positioned near major arterial roads - where’s there’s incessant traffic, bordered to the west by Homebush Bay Drive, with quick access to the M4 Motorway & bordered on the south by the ecologically precious Mason Park Wetlands conservation area. This proposal would permanently introduce an industrial hazard capable of releasing seriously toxic contaminants - including lethal Hydrogen Fluoride Gas plumes into the air, over the land, the busy venues, the travelling public, waterways, vegetation and surrounding ecosystems. The consequences of a major battery fire extend well beyond the project boundary. Unlike conventional industrial fires, lithium-ion battery failures generate toxic gases, contaminated smoke, metal particulates and contaminated firefighting water capable of affecting neighbouring properties. This is fundamentally incompatible with the long-term protection of the public, shopping venues, lots of travellers on busy roadways and wetland areas like Mason Park. International Experience Demonstrates That Catastrophic Battery Fires Are Real The biased, non-independent Environmental Impact Statement repeatedly seeks to reassure decision-makers through engineering standards, management plans and operational procedures. Recent international experience demonstrates that catastrophic battery failures continue to occur despite such measures. The January 2025 fire at the Moss Landing Battery Energy Storage Facility in California—the world's largest lithium-ion battery installation—resulted in a prolonged emergency response, evacuations and ongoing environmental investigations. Subsequent independent scientific research has documented deposition of cathode metals within nearby coastal wetlands following the fire, raising serious questions regarding the environmental consequences of large-scale battery failures and the persistence of contaminants beyond the immediate fire zone. The Department’s assessment and recommendation for approval before the IPCN gives insufficient consideration to these lessons. Instead, they carelessly and irresponsibly assume that engineering controls will perform exactly as intended throughout the project's operational life. History demonstrates that assumption is flawed and unsafe. Toxic Contamination Has Been Underestimated Thermal runaway within lithium-ion batteries generates complex mixtures of hazardous substances including hydrogen fluoride, carbon monoxide, volatile organic compounds, particulate matter and metal-containing aerosols. These emissions present acute risks to emergency responders, nearby communities, travellers and the fragile wetland ecosystem nearby. Recent research has also raised concerns regarding per- and polyfluoroalkyl substances (PFAS), commonly known as "forever chemicals", associated with lithium-ion battery manufacture and disposal, highlighting additional uncertainties regarding long-term environmental contamination. Thermal Runaway Cannot Be Prevented With Absolute Certainty No lithium-ion Battery Energy Storage System can guarantee prevention of thermal runaway. Failures may result from manufacturing defects, internal cell faults, electrical malfunction, mechanical damage, overheating, installation defects, maintenance failures, software malfunction or external fire exposure. Once initiated, thermal runaway rapidly propagates between battery modules despite sophisticated monitoring systems. The relevant planning question is therefore not whether thermal runaway is unlikely. It is whether the Applicant and the Department - who’s just trusting the vested interest Applicant - with NO diligent, independent Risk Research done at all - has demonstrated that the consequences of a worst-case failure will remain acceptable. That demonstration has not been made. Firefighting Capability Remains Highly Uncertain Large-scale lithium-ion battery fires present hazards fundamentally different from conventional fires. Fire and Rescue NSW has publicly acknowledged that there remains a general lack of guidance, standards and legislative provisions addressing the risks associated with these technologies, and that important uncertainties remain regarding failure mechanisms and consequences. Similarly, CSIRO has advised that it does not certify any portable fire extinguisher as capable of effectively extinguishing a lithium-ion battery fire. These statements should concern every decision-maker. As Australia's leading fire authorities acknowledge that knowledge gaps remain, the Department and the IPCN must stop their hasty, reckless approvals and exercise extreme caution before ever approving another large-scale Lithium-ion Battery Energy Storage System again! Emergency Services Cannot Be Assumed To Cope The Applicant and Department have not demonstrated: * availability of specialist hazardous materials teams; * prolonged firefighting capability; * availability of sufficient water; * contaminated water containment; * respiratory protection requirements; * long-duration incident management; * availability of medical/hospital facilities for mass poisoning event from lethal hydrogen fluoride gas; * firefighter fatigue management; * management to exclude traffic from lethal gas plumes within 5 kms for three days or more during an active BESS Fire event; * environmental monitoring and remediation following a major fire. Emergency response plans are not evidence that emergency response capability exists. Those capabilities must be independently demonstrated before any approval would ever be contemplated. Existing Standards Do Not Eliminate Risk Compliance with standards is necessary but it is not proof of safety. Published research has noted that utility-scale Battery Energy Storage Systems are being deployed at an unprecedented scale while engineering knowledge, emergency response capability and design standards continue to evolve. The existence of standards should not be confused with proof that catastrophic failures have been eliminated. Long-Term Environmental Liability Has Not Been Resolved The proposal also fails to provide adequate certainty regarding: * poisoning of the public from hydrogen fluoride gas plumes; * contamination remediation; * long-term hazardous waste management; * battery recycling capacity; * financial responsibility for decommissioning; * future ownership changes; * financial security should the operating entity cease trading. Without legally enforceable financial guarantees, future environmental liabilities will ultimately fall upon the Council, community or taxpayers. That outcome is completely unacceptable. The Precautionary Principle Must Apply The Environmental Planning and Assessment framework requires decision-makers to adopt a precautionary approach where scientific uncertainty exists and the potential consequences are serious or irreversible. This proposal presents precisely those circumstances. Significant uncertainty remains regarding: * catastrophic thermal runaway; * prolonged battery fires; * toxic gas releases; * lethal gas impacts upon the public - including babies and infants; * environmental contamination; * emergency response capability; * long-term waste management; * cumulative environmental liability. Where these uncertainties remain unresolved, approval must never be granted. Conclusion The proposed Homebush Battery Energy Storage System would introduce a hazardous industrial facility into an area teaming with families shopping and relentless travellers as well as containing sensitive ecosystems that has not been demonstrated to be safe under worst-case conditions. The Applicant’s biased and unacceptable Environmental Impact Statement and dodgy Department’s irresponsible assessment of it with callous recommendation for approval relies heavily upon assumptions, management plans and future operational controls rather than essential due diligence and independent, expert risk research evidence demonstrating that catastrophic failure consequences have been eliminated. The Department must not accept optimistic assumptions where public health and safety, our uncontaminated air, irreplaceable land, vital water sources and wetland biodiversity are at stake. Until independent, peer-reviewed, expert evidence demonstrates that these risks have been comprehensively assessed and can be effectively eliminated under Australian conditions, the proposal fails to satisfy the standard of certainty expected of State Significant Development, so must be rejected. References: **’Forever Chemicals’ used in Lithium Ion Batteries Threaten Environment, Research Finds | Lithium-ion batteries | The Guardian 14/7/24 https://www.theguardian.com/technology/article/ 2024/jul/14/forever-chemicals-lithium-ion- batteries-environment **Coastal Wetland Deposition of Cathode Metals from the World’s Largest Lithium-ion Battery Fire" (Moss Landing BESS FIRE) According to independent Experts this is actually worse than a radioactivity spill. A lot of this very toxic stuff is not easily located. Whereas, with radioactivity, one needs just a hand-held Geiger counter to locate the pollutant. https://www.nature.com/articles/ s41598-025-25972-8#Tab1 **Safety of Grid Scale Lithium-ion Battery Energy Storage Systems “The scale of Li-ion BESS energy storage envisioned at “mega scale” energy farms is unprecedented and requires urgent review. The explosion potential and the lack of engineering standards to prevent thermal runaway may put control of “battery fires” beyond the knowledge, experience and capabilities of local Fire and Rescue Services. BESS present special hazards to fire-fighters....” https://www.researchgate.net/publication/352158070_Safety_of_Grid_Scale_Lithium-ion_Battery_Energy_Storage_Systems **Grid Scale Batteries & Fire Risk https://static1.squarespace.com/static/656f411497ae14084ad8d03a/t/ 66fd2383b56dbc6906390297/1727865736681/Fannon-Batteries.pdf **Disaster at Moss Landing: The Risk of Battery Storage - YouTube - 16/1/25 https://www.youtube.com/watch?v=xuTaZFQA18E **https://wattsupwiththat.com/2025/02/20/massive-green-battery-plant-catches-on-fire-again-weeks-after-major-toxic-blaze/ **https://localnewsmatters.org/2025/02/13/environmental-tests-reveal-elevated-levels-of-toxic- metals-since-moss-landing-battery-fire/ **https://www.sfgate.com/news/bayarea/article/environmental-tests-reveal-battery-metals- around-20163514.php **https://www.cbsnews.com/sanfrancisco/news/elevated-levels-heavy-metals-elkhorn-slough- lithium-battery-facility-fire/ **Lithium-Ion Battery Fire Risks & Extinguisher Limitations 1.CSIRO ActivFire® Advisory Note AN-004 CSIRO explicitly states it "has not and will not certify ... that any fire extinguisher can effectively extinguish a Li-Ion battery fire." Verification Services **”There is a General Lack of Guidance and Provisions in Building Codes, Standards, and Legislation in Relation to Safety to Address the Potential Risks From These Technologies. Part of the problem is that we do not yet know enough about their probability of failure, their mechanisms of failure and potential consequences of failure.” https://www.fire.nsw.gov.au/page.php?id=940

Combined attachments.pdf (PDF, 242.91 KB)

46871

Redacted

17/07/2026

Object

Website

Please see attached the word document containing my submission. Thank you.

Homebush Battery Energy - IPC.docx (DOCX, 30.19 KB)

30046

New South Wales 2145

06/07/2026

Comment

Website

Responce to Homebush BESS The documents available for this Review of the EIS by the Independent Planning Panel Still have not adequately answered my initial submissions plea for a Fire Safety Study being made available for the consideration in his Planning process initially. The Documents from AECOM and in the EIS mention the availability of this FIRE SAFETY Study as part of the conditions of approval. But this document, which I consider to be essential for the Initial EIS process, Is absent. Two possible reasons for its absence. a. The review of EIS for BESS or High Energy Infrastructure does not value the Fire Safety Study as essential to determining the suitability of this still not fully proven energy retention systems. Why? The proponent didn’t deem it as prudent for its rollout to continue. b. The second is the increasing overseas experience where BESS are of a hazard that the knowledge is still significantly untested as being SAFE for all locations Safety can onlybe determined in its location where all risks and factors are on the table. {safe is absent here} Especially for this type of Critical location. Given the US Fire community trying to get a separate Standard for High energy systems including all types - Solid state as well. So, Location is key to risk mitigation. As time passes Knowledge builds with this new technology storage containers and incidents are highlighting the risks are not being managed adequately. 1. Key though missed in EIS Locations of BESS and High energy - Battery recycling locations are a Incident Critical / high-risk hazards. EIS infers it is Simply. Building a wall or finding a vacant piece of Ground is sufficient. But is not a simple fix! The answer is the right Location, Great reseaarch : wind studies and intelligent Planning for at scale BESS installations of 10MW/ 50 Mwh and over as they are Very High Risk - Low Occurrence in our land use laws. 2. Missed data / research assumed safety Instances of Thermal runaway of Lithium-Ion phosphate batteries are occurring and the outcomes of our tradition view of fire safety at these sites have been at best unremarkable. Forget about the locking down of Whole suburbs in the US and BESS system left to burn for Days, as they are un extinguishable without huge volumes of water. Toxic resudues, The smoke drift likely at this site is not even mentioned in the Documents provided as they are highly hazardous. But none of the documents acknowledge to environmental hazards to theusers of the 3 major access arteries at the Homebush site in event of a thermal runaway minor or major. The project is couched as being safe? BESS are worldwide so we have nothing to be concerned about? Anyway we built them at other locations,Right? Key observation: This Whole EIS process is Not suitable for the hazards that BESS installations posse It is 200MW/431mwh BESS Yes, the nature of installation proposed is to a standard that would in theory isolate the whole 200 MW into smaller units. But this is not regulated or failsafe as far as documented. But there is NO standard that the Installation is complying to that in its proposed setting. I would want to be down wind off in a battery incident that Off Gasses is likely. Thus the Project premise is usernand regulators ignorance or Just don’t go to the parkland at Homebush Bay, sporting facilities at Olympic Park or DFO in the event of a incident. Because the project sponsor EIS doesn’t consider the High Risk / Low occurrence to be of consequence for any BESS installations in NSW Notification requirements Given that B29-B33 and subsequent B34 Are ineffective requirements for the site specifically giving 24 hr notice of an incident. So, no instant suburb wide notice or CRITICAL Incident Proticol required . So, Days later after you have respiratory damage. You will be told not to get exposed to the life threating gasses of a thermal runaway that has happened. Clyde VIVA has more stringent proticols. Closing thoughts Finally, the plan in the EIS is to rely Totally on: NSWFR and NSW PF and Ambulance get response call / Instantly or earlier. so, they get the nasty Job of closing Homebush Bay Drive M4 West and evacuating and treating /locking up the inhabitants of DFO, Homebush, and Olympic Park residential areas. Hope, Someone tells Westconnex/ Tfor NSW to shut down the M4 Tunnels ventilation within minutes of this happening. As proposed this is Some new kind of Risk Analysis/ mitigation? - This is what the EIS process is meant to do?

29501

New South Wales 2112

03/07/2026

Support

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As I wrote in my EIS submission, I express my strong support for the proposed Homebush Battery Energy Storage System (the Project). I believe that the Project will bring numerous benefits, both in terms of environmental sustainability and economic development. As we continue to prioritise renewable energy sources, the implementation of energy storage solutions is crucial to ensuring a reliable and efficient energy grid. The ability to store surplus energy from renewable sources, such as solar and wind, will help balance supply and demand, reduce energy waste, and increase grid stability. This, in turn, will lead to a cleaner and more resilient energy grid. Additionally, the Project has the potential to create new local jobs during construction, maintenance, and operation, attract investment to the local area, and ensure lasting benefits for the community through the 100 construction jobs and $215 million in capital investment. I also understand that the Project will provide significant cost savings by reducing the need for expensive and unreliable peaking power plants, which rely on expensive fossil fuels, and will assist with meeting Australia’s 2030 and 2050 net-zero emission targets at the lowest cost to consumers. This will help reduce energy costs for residents and businesses, supporting affordability and sustainability in the community. It is unfortunate that the 34 objectors >100 km away from the Project and the 19 interstate objectors have pushed the Project's approval pathway to the IPC. This Project is one of countless projects where their EIS exhibitions have been hijacked by organisations or groups who have broad objections to renewables and don’t live, and will never be directly impacted, by those projects. They have exploited the system, which can be a tool for genuine discussion and assessment of environmental impacts, to hold up the approvals process of any renewable energy project and discount the views of local stakeholders who will be directly impacted by the project, either positively or negatively. I fear if nothing changes about how submissions are considered for SSD projects, organisations and groups who have a vendetta against renewables will continue to indiscriminately submit objections. Not because they will be significantly impacted by the projects directly, but because of their ideology or political stance. It seems they will do whatever it takes to slow the renewable energy transition to the detriment of any climate change action and the need to hastily replace our aging fossil fuel generators at the lowest possible cost to consumers. The irony is the impacts of climate change and the resulting higher energy prices from continued use of fossil fuel generators will affect everyone, including the objectors. If these types of objections remain unchecked there is a genuine risk our emissions reductions targets will not be met which is critical in mitigating the negative effects of climate change. As such, I fully support and encourage the IPC to approve this Project. I also encourage all local stakeholders to continue working together to make this important Project a reality and to ensure the Project's benefits flow into the community. I believe it will be a significant step forward for both the local economy and Australia's transition to net zero.