NO BTS66 - Fact Sheet 1

At the residents meeting held on 7th February 2011 the residents voted No BTS66.
This is why and what can you do to help STOP the BTS66.
Have your say, submit your comments prior to 15th April.

Fact Sheet
March 21 2011
Brunswick Terminal Station 220/66 KV, proposed for 46 King Street Brunswick.

What does BTS66 mean?
Brunswick Terminal Station 220/66KV is the new electrical facility required to supply more electrical power to the CBD and inner Northern suburbs, and proposed for Brunswick. It is actually new TS that could be located anywhere given suitable conditions within 10km’s of the CBD. The incoming electrical power is supplied at 220,000 volts (220KV) and transformed in the facility down to 66,000 volts (66KV) and then distributed to zone substations and eventually into businesses and homes.
It could just as easily be BRTS66 (Brooklyn Terminal Station 66KV).

Does the new Terminal Station have to be located at Brunswick?
No, it can be located at a number of different locations, if the precautionary principal is used; it would not be located in a residential area like Brunswick. An alternate site has been identified in Brooklyn, in a heavy industrial area, not close to residences. If it is located at Brunswick it would be a world first for a Terminal station of this size to be located in such a dense residential area.

Why is it needed and when?
A new terminal station is required to provide more power to the CBD and to the inner northern suburbs. The requirement for a new Terminal Station was financially viable in 2006. New TS is now long overdue.

Where is the site in Brunswick?
The proposed site at 46 King Street is zoned Residential 1 and covered by an ESO1, directly opposite 38 Homes, Sumner Park Soccer ground (450 junior members) and the Merri Creek bicycle path and Merri Creek valley of state significance. There are hundreds of residents in the immediate area, parklands, High schools, Primary schools and kindergartens and sporting grounds all within 500m of the site. The parkland is used by thousands of people for recreational purposes.

Why was Brunswick selected as the site for the New TS66?
In the 1950’s a decision was made to demolish Stony Park Mansion (located on 4Ha of land on the Merri Creek) and construct a 220/22KV terminal station now known as BTS22 to service the inner northern suburbs. There is a high voltage power supply into the site, overhead along the Merri Creek Valley, which then proceeds underground to Richmond and then to the CBD.
Brunswick is regarded as an option by the power companies because of an existing, old infrastructure currently on site. The New TS proposed will be in addition to the existing facility, not an upgrade, nor maintenance works as described in the initial planning application which was subsequently refused.

Is Brunswick the most economical location for the new TS?
Currently according to the figures released by the power companies, Brunswick is the most economical location to locate the new TS. Currently it is forecast that Brunswick can be delivered in 2015 and all other options can be delivered in 2016. If this assumption is not right, and it takes 6 months longer to deliver Brunswick than the others, then Brunswick drops to N0. 3 on the most economical alternatives and North Fitzroy and Brooklyn then become more feasible.
There is significant risk that the deliverable date at Brunswick being extended by more than 12-24 months to resident protest and the planning permit process.

What are some of the risks to human health with a New Terminal Station located at Brunswick?
A fourfold increase in capacity at the Brunswick site would cause a fourfold increase in current in the supply line, i.e. the high-voltage power lines from the Thomastown terminal station in Mahoney’s Rd, Thomastown. This high-voltage power line does not have a 30 m easement along its whole length. Instead crosses over private residential properties in Reservoir.

Living in the vicinity of high-voltage power lines has been associated with a two-fold increase in the incidence of childhood leukemia. While the mechanism for this increased incidence is currently unknown, the precautionary principle would dictate that any increase in high-voltage power exposure should be avoided in residential areas.

One of the alternative sites, Brooklyn, is in an industrial site and receives its power supply from the South Morang TS via the Keilor TS. These high-voltage cables appear to have an easement and so would be more suitable for an increase in current to supply the inner Melbourne area.

Is this risk to people living under the HV line in Reservoir assessed during the Reg Test?
No.

Who decides where the new terminal station will be located?
The Australian Energy Regulator decides where the new terminal station will be located after receiving submissions from AEMO and Citipower and to a lesser extent SP AusNet trough the Regulatory test prepared by the power companies.
The Australian Energy Market Operator plans the transmission system, Citipower plan the distribution system and together they plan where new terminal stations will be located. SP AusNet then becomes the owner of the infrastructure and it is their responsibility to build such facilities. The Regulatory Test is not subject to independent assessment.

Why is it not a good idea to locate the new TS in a residential area such as Brunswick?
It is proposed to increase the output of the Brunswick site four-fold from 225KW to 900 KW. This will result in a four-fold increase in the EMF on the current site.
There are no definitive standards anywhere in the world that have determined it is safe to expose humans to long term electromagnetic Fields. Living in the vicinity of high-voltage power lines has been associated with a two-fold increase in the incidence of childhood leukemia. While the mechanism for this increased incidence is currently unknown, the precautionary principle would dictate that any increase in high-voltage power exposure should be avoided in residential areas.

Does the Regulatory test assess the effects of living under or next to high-voltage power line or high-voltage electrical equipment?
No. It only measures the strength of the electromagnetic field. If the mechanism causing the increase in childhood leukemia incidence was indirect, measuring the electromagnetic field would give a false impression safety where there is danger (e.g. via chemical reactions caused in close vicinity of the high-voltage power equipment and then distribution of the product of the chemical reaction in the neighborhood).

Is there a risk of these large scale oil transformer failure such as the ones proposed for the new terminal station?
Yes

Are systems to contain the resultant fire and smoke foolproof?
No, all industrial facilities are associated with risk, especially where safety measures have been compromised.

Is the Brunswick site a sensitive location?
Yes, zoned Residential Zone 1, bordered by 76 Homes, a soccer ground utilized by 450 junior members, the Merri Creek and the Merri Creek bicycle path.
The site is also covered by an environmental significant overlay.

What is the proposed form of the New Terminal station at Brunswick and at what cost?
The proposal is for all equipment to be housed inside buildings ranging in height from 7, 9, 10 and 12 meters high for some $300 million. Not to mention 6-9 months of rock drilling and excavating required to sink these buildings meters into the rock. No information about the aquifer and the impact on the aquifer these substantial earthworks have been revealed to date.

What are the limitations of the Regulatory Test?
Does not measure risk of failure to be able to be built due to planning permit application refusal or delay.
(The 2008 Reg test determined that the new TS be located at Brunswick over a site in Bouverie Street, CBD. The Bouverie St option was costed at $110m. The current cost estimate for Brunswick is $300m, some $190m more than the rejected Bouverie Street option. Planning Permit considerations were not considered in 2008, just as they are not considered now.)
• The Regulatory Test is a self-managed process, not subject to independent scrutiny.
• The reg test is a process the power companies are bound to follow a predetermined process that assesses various options on a dollar amount with little or no consideration to benefits/risks to community
• Assumes all options are similar and can be distilled down to a dollar amount for selection. Purposes. Site sensitivity, appropriate zoning nor optimum use of land is not considered.
• Long term benefits of options are not considered, i.e.: is a site available for future expansion
• Assumes current infrastructure locations are appropriate and consolidation appropriate
• Does not consider cultural heritage of the sites
• Does not consider peculiar geographical features which could increase risk of danger to health.
• Does not consider effects of additional EMF exposure for residents living within the current HV easement in Reservoir.
• The process is very difficult to understand and information is closely guarded by the power companies resultant in a process that does not appear transparent and independent and is confusing.
• The selection process is very sensitive to deliverable dates, and there is more risk associated with the timing of the Brunswick site due to the variable nature of the planning permit process. Planning permit process not required at Brooklyn. The Reg test does not rate the risk of deliverable dates.

Are there peculiarities with the Brunswick site that cause a safety concern?
Yes. The levee bank along Alister st protecting the 8 residences from flood water also forms a barricade that would trap any toxic heavy gasses escaping from the facility in the right atmospheric conditions and affecting the residents. The regulatory test does not consider this.

Are Planning permit conditions being considered now?
No, pre-application meetings with the planning officers at Moreland have not taken place.

What is the maximum height for buildings in a residential zone and does the current proposal comply?
9 m. The proposal exceeds the maximum building height in a residential zone by 3 m.

Have the friends of the Merri Creek been consulted over the plan to build a 12 m high industrial building on the banks of the Merri Creek?
No, the height of the proposed buildings exceed the trigger height for buildings to be considered under the ESO1 by 6 m.

Will the Proposal be visible from St Georges Road, from the Merri Creek and from the sporting grounds on the eastern side of the creek?
Yes, because the site is elevated and very visible from surrounding areas.

Does Reg. test require the current proposal at Brunswick to preserve the cultural heritage of the site?
No. As the former home of Sarah Sumner and site of Stony Park Mansion, “the Ripponlea of the north”, there is no preservation of the cultural heritage of the site proposed. The site is not listed on the heritage register, but neither has it been considered for listing on the register.

Has due consideration of sites alternate to Brunswick been considered?
No. The residents introduced an industrial real estate company to the power companies in late December 2010. The Real Estate Company was not formally approached by the power companies until February 2011, 4 weeks prior to the release of the draft Reg. Test. Due consideration of the alternate sites could not have followed due diligence in only a 3 week window. Given this limited time , Brooklyn has been identified which can proceed given a decision to do so.

Are alternate more appropriate sites available than the Brunswick site that have yet to be explored?
Probably, alternate sites have only been listed for consideration in the 3 weeks prior to the release of the draft Reg report.
Alternate options could not have been exhausted in the 3 weeks prior to the release of the draft report; therefore it is reasonable to conclude that alternate options have yet to be explored fully.

Where to from here?
Comments to the draft regulatory report are currently being received by Citipower, they will then be collated and the regulatory test will be presented to the Australian Energy Regulator.
The public are invited to submit their comments before 15 April 2011 and they may be published. If you do not want your comments published please stipulate that clearly on your submission.

Comments should be directed to:

Mr. Neil Watt
Manager Network Strategy Electrical Networks- Citipower
Locked bag 14090
Melbourne, Victoria, 8001 or
info@brunswickts.com.au

After the close of the comment period on 15 April, a final report will be finalized on 13 May and which will be made available to registered participants and interested parties. Once the final report is published, registered participants will have 40 business days to dispute the recommendations contained in the report.

What happens then?
If Brunswick is still the preferred site for the power companies to build the New Electric Terminal Station, and the Australian Energy Regulator tells the power companies to build the new TS at Brunswick then the next step for the power companies is to lodge a Town Planning Permit application with the City of Moreland for consideration and assessment. This will probably be in the months following 40 day deadline expiration. Last time an application was submitted to Moreland back in December 2009, the application was for maintenance and upgrade works to the existing terminal station, (even though the real scope of works was for a new terminal station). We all acknowledge that the description of the works was misleading, that the advertising was below standard exposure and that the officers report body and conclusions left a lot to be desired.
Swift and strong local resident action then, saw that application refused. Swift and strong local resident action saw the 1989 proposal for overhead High Voltage power lines from Brunswick to Richmond placed underground. We are not saying don’t put the New TS in our back yard, we, the residents, are saying “Don’t put the TS in anyone’s back yard, it should be placed in a suitable heavy industrial area, not a dense residential area like 46 King st, Brunswick”. There is too much risk to place The New TS at Brunswick, and the Reg Test does not adequately consider the risk, nor the impact on our community this heavy industrialized facility will have on our community for the next 50 years and beyond.

Placing the New Terminal Station on the King Street site is wrong and a detriment to our and any community.

The Merri Creek Residents Group will be strongly opposing any plan to place the new TS at 46 King Street, Brunswick or any other residential location and will continue the opposition to such a proposal until it is relocated to an industrial location.

For updates and to follow the campaign, please log into and register at http://powergridsolutions.blogspot.com