Tarrone BESS planning application submission

31 March 2025 

Mr Michael Juttner Manager, Development Approvals and Design, Renewables State Planning Facilitation Department of Transport and Planning

Dear Mr Juttner

Application number: PA2403305 TARRONE BESS | 574 TARRONE NORTH ROAD TARRONE VIC 3283 (Tarrone BESS)

Thank you for notification of the planning application for the proposed development known as the GPG Tarrone BESS.

The application proposes the use and development of the land for a utility installation (battery energy storage system and associated infrastructure), associated buildings and works, and the removal of native vegetation.

Please find below Council’s comments and concerns regarding a number of matters relating to the proposal.

Council officers can provide further detail if required or meet with planning officers and the applicant’s representative to discuss further.

Traffic Impact Assessment – 26 June 2024 (Impact)

Errors and requests for clarification

  • Page 5 states that an ‘on-site desktop’ assessment of sight distances for Tarrone North Road and Riordans Road was undertaken. Clarification required.
  • Page 6: 81 daily (two way) movements should be stated as 162 daily movements. Similarly, all predicted daily movements in the document should be stated this way.
  • Page 9 regarding Woolsthorpe Heywood Road traffic volumes: VicRoads Open Data available through arcgis.com suggests that the section of Woolsthorpe-Heywood Road between the Hamilton-Port Fairy Road and Penshurst-Warrnambool Road only carries 290 AADT. The section with 800 AADT is between Penshurst-Warrnambool Road and Warrnambool-Caramut Road.
  • Page 14 Section 4.1.4.1: Multiple road naming errors.
  • Page 15 Section 4.2.1: Is this referring to the northern section of Tarrone North Road between the proposed site entrance and the Woolsthorpe-Heywood Road?
  • Page 23 Section 6.2 refers to ‘Tarrone Regional Council’, which doesn’t exist, instead of Moyne Shire Council.

Local roads in the vicinity of the site

Terms such as ‘no material impact’ and ‘additional traffic can be comfortably accommodated by…’ are used throughout the TIA in relation to construction impacts on local roads. In contradiction, elsewhere the TIA acknowledges that predicted impacts will trigger the need for road upgrades.

The TIA states ‘It is noted that the anticipated construction traffic can be comfortably accommodated temporarily by Tarrone North Road and Riordans Road without any material impact on the operation or safety of this road.’ Council disagrees. The estimated construction traffic for Tarrone North Road exceeds the level of service (and associated standards) to which the road has currently been constructed. The TIA is unclear on the level of usage proposed for Riordans Road. Therefore, under the Infrastructure Design Manual Version 5.4 – Table 6, Rural Road Characteristics, recommended volumes for these classes of municipal roads would be exceeded and upgrade requirements triggered.

The section of Tarrone North Road between the Tarrone Substation access road and Riordans Road will need upgrading as it is too narrow to accommodate 162 extra vehicle movements per day, and will need to be sealed along with the intersection and approach on Riordans Road, prior to BESS site mobilisation.

The section of Tarrone North Road (southwards) between Riordans Road and the Tarrone Lane intersection is not fit for purpose for construction traffic, and Council will not support its use as a site access route for any heavy or light construction-related vehicles.

The sight lines south of the intersection of Tarrone North Road and Riordans Road referred to in Section 4.3.2 should be verified.

Council would support a speed restriction proposal in the vicinity of the main site entrance during construction.

Delivery routes

Only one quarry source and one concrete source are listed in the TIA, and proposed delivery routes from these sources and the water bore in Koroit are not discussed.

Council’s recent experience gained from a BESS currently being constructed in the Shire is that having only one quarry source for quarry materials and concrete may not be sufficient for the construction of this BESS. To avoid having to add other sources during construction via amendments to a TMP, this TIA could have presented at least 2 options (and routes) for quarry materials and concrete.

The municipal road sections of any quarry and other heavy vehicle delivery routes identified in a Traffic Management Plan will in the least require regular inspection and repair during project construction.

Any quarry or other heavy vehicle deliveries must not approach or leave the site via the southern end of Tarrone North Road.

Construction related traffic must not use the western section of Tarrone Lane between the Holcim quarry entrance and the Hamilton-Port Fairy Road.

The route for component replacement haulage should be the same as the approved route for heavy construction vehicles. It is recommended that the applicant uses the NHVR route assessment tool before any proposed over-dimensional delivery routes are referred to DTP and Council.

Requirement for a Traffic Management Plan

Council requests that any approval for the project includes a condition that before the development starts, a Traffic Management Plan (TMP) be prepared in consultation with Moyne Shire Council to the satisfaction of the Minister for Planning. The TMP must provide a robust process for the upgrading, monitoring and repair of relevant sections of Tarrone North Road and Riordans Road, the identification of quarry and other construction vehicle delivery routes, and a monitoring and repair regime to be followed for local-road sections during project construction, all in consultation with Council.

Council notes that as for other major energy projects constructed in the Shire, the TMP must include provision for a suitably qualified independent road quality auditor to be appointed at the cost of the proponent, to carry out the required road inspection and reporting regime during construction.

Staging

Stages of construction are referenced several times throughout the TIA.

Sections 3.3.5 and 5.3.2 discuss a scenario that is now out-of-date.

In Table 1, do the predicted construction traffic movements for Stage 1 include vehicles associated with any external road upgrades for Tarrone North Road and Riordans Road?

Section 5.1.2 lists Stage 1 as including early works and site preparation. Any external road upgrades required by Council should be acknowledged as a separate stage preceding the commencement of any ‘Stage 1’ onsite mobilisation and early works.

The proposed use of Riordans Road

The TIA is contradictory regarding the intended use of Riordans Road for project construction vehicles. Section 5.2.2. states that Riordans Road is expected to carry up to 131 daily vehicle movements. However, the Snapshot, Section 4:2:2 and Section 4:3:2 all state that Riordans Road is to be used for emergency access only. Clarification is required.

Regarding Riordans Road, the Snapshot – Haulage Routes section states ‘At a minimum, we suggest that this road be provided to an 'all weather' standard, with passing areas provided every 200m (or at a selected nominal distance).’ If Riordans Road is to be used for site access, Council will not support a single lane with passing areas every 200m.

Bushfire Risk Assessment Report: 21 June 2024 (ABPB Ltd)

Council is concerned that the document refers to the Northern Grampians Planning Scheme 2024 instead of the Moyne Shire Planning Scheme. The applicant has since informed Council that the assessment was carried out against the Moyne Shire Planning Scheme and its relevant requirements for bushfire assessment and protection, and the reference to the Northern Grampians Planning Scheme was an error.

In Section 4.6 Occupation of the BESS during Total Fire Ban Days, the statement regarding hot works should specify that ‘No hot works should be undertaken without the appropriate Use of fire in the open air on a day of Total Fire Ban Permit issued by the Country Fire Authority’.

Council submits that if the project is approved, prior to and during construction the proponent and construction contractor/s engage directly with local CFA Brigades including Orford, Willatook, Toolong, Kirkstall and Broadwater as well as the CFA District 5 Assistant Chief Fire Officer and Commanders.

Unfortunately, the application does not contain an emergency management plan framework (or similar) nor a hydrology assessment. These should have been prepared to detail, amongst other things, how contaminated water and chemicals used for onsite firefighting can be managed by bunding and other appropriate containment and treatment methods to mitigate the risk of contamination of catchments and waterways. If a permit is to be issued, Council requests this be addressed with a condition requiring the preparation of a detailed environmental management plan.

Flora and Fauna Assessment: June 2024 (Nature Advisory)

If a permit is to be issued, Council requests a condition requiring measures to protect native vegetation alongside permanent tracks from any post-construction vehicular and/or laydown impacts.

General

If a permit is to be issued, Council requests a condition requiring a copy of the permit and all endorsed plans under the permit be displayed on the project’s website.

If you require any further information, please do not hesitate to contact Kirsty Miller, Manager Development Services on mobile 0499 433 844 or email Kirsty.miller@moyne.vic.gov.au.

Yours sincerely

Mark Eversteyn
Chief Executive Officer

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