MOD 1 - Increased Generation Capacity

I object to the increase in size to this project. The CWO REZ already has enough planned installed capacity (as per the Major Projects portal) to power the whole of NSW. If wind/solar work as spruiked by the developers and government, then surely a project using reciprocal engines powered by mostly diesel should not be needed. Approval of this modification would prove that wind and solar do not work as advertised and will not be able to provide sufficient baseload power to provide NSW electricity needs.

Our community formally objects to the proposed Modification 1 for the Dubbo Firming Power Station Project.
This proposal, including the expansion from 64 MW to 180 MW, the introduction of reciprocating engine technology, and the hydrogen fuel scheme, represents a reckless and poorly substantiated experiment in energy generation with profound environmental, safety, and climate implications.

1. Hydrogen: a high-risk fantasy, not a solution
The project’s reliance on hydrogen, up to 30% blended with natural gas, is a perilous gamble disguised as innovation. Hydrogen’s extreme flammability, near-zero ignition energy, and high detonation velocity make it inherently dangerous.
The Preliminary Hazard Analysis only superficially addresses these risks and relies on unrealistic operating scenarios, assuming 100% utilization for all fuels simultaneously—a physical impossibility. The modeling ignores practical operational realities and fails to provide assurance that the surrounding community and workers would remain safe.
Hydrogen at the scales proposed—stored in high-pressure tanks at up to 400 barg and blended onsite—represents an unacceptably high potential for catastrophic release events, including jet fires, flash fires, and confined detonations. Treating this as “safe” under theoretical assumptions is a clear abdication of responsible risk management.

2. Escalating scale and complexity amplify hazards
Increasing capacity to 180 MW and adding reciprocating engine technology multiplies risk points: more high-pressure fuel systems, more failure modes, and more potential consequences.
The Hazard Analysis tables alone demonstrate a long list of credible accident scenarios involving natural gas, hydrogen, and biofuels.
The assumption that simultaneous high-risk events will not occur is dangerously optimistic.
This is not a minor modification—it is a major escalation of risk.

3. Biodiversity and ecosystem impacts remain unacceptable
The minor claimed reduction in native vegetation clearing (0.08 ha) and the trivial increase in planted native trees (0.01 ha) do not offset the project’s ongoing intrusion into critically endangered ecological communities such as Box Gum Woodland CEEC.
The net gain of one ecosystem credit is meaningless in practical terms and ignores the broader impacts of construction, high-pressure fuel storage, and potential fires on local flora and fauna.

4. Omitted greenhouse gas risk: SF₆
Most notably, the assessment fails entirely to account for emissions of sulfur hexafluoride (SF₆), a greenhouse gas thousands of times more potent than CO₂. SF₆ is commonly associated with electrical switchgear and high-voltage equipment. Given the scale of the proposed expansion, the project is highly likely to release measurable SF₆ through routine operations, leaks, or maintenance events. The absence of any mitigation, monitoring, or reporting measures for SF₆ constitutes a glaring and unacceptable gap in the environmental assessment, undermining the project’s claimed climate credentials.

5. Public safety and regulatory oversight deficiencies
The project’s safety assessment presumes industrial zoning and minimal risk to nearby communities.
However, it disregards secondary hazards such as emergency response constraints, cumulative risks of simultaneous fuel leaks, and unplanned renewable energy surpluses that could increase hydrogen production beyond model assumptions. Approving this project as proposed would be a serious dereliction of duty to protect public safety and the environment.

Conclusion
Modification 1 is an imprudent and high-risk proposal with no merit:
Hydrogen storage and blending is a high-risk, unproven scheme.
The scale increase and new technology exacerbate the potential for catastrophic incidents.
Biodiversity offsets are trivial and fail to account for cumulative ecological impacts.
SF₆ emissions—a highly potent greenhouse gas—have been completely ignored.

We urge the Assessment Panel to reject Modification 1 in its entirety.
Any expansion of the Dubbo Firming Power Station must first demonstrate credible, independently verified safety for hydrogen use, meaningful ecological protections, and full accounting of all greenhouse gas emissions, including SF₆. The community, workers, and the environment cannot be subjected to this experimental project under the guise of renewable energy innovation.

I am writing to formally object to the proposed Modification 1 to the Dubbo Firming Power Station Project (SSD-28088034), including the increase in generation capacity to 180 MW, the introduction of reciprocating engine technology, and the inclusion of hydrogen as a fuel source. The proposed modification represents a deeply flawed approach to energy production, safety management, and biodiversity protection.
1. Hydrogen as a “green” fuel: A dangerous fantasy
The project’s reliance on hydrogen blends (up to 30% by volume) is nothing more than a technocratic fantasy that ignores the realities of hydrogen production, storage, and combustion. Hydrogen is a highly volatile, extremely low ignition energy gas. Its use at the proposed scales—stored at pressures up to 400 barg, blended into fuel streams, and combined with natural gas for continuous power generation—is inherently high-risk. The Preliminary Hazard Analysis confirms this, yet the proponents continue to assert that risks are “within acceptable thresholds” under the unrealistic assumption of 100% operational efficiency for all fuels simultaneously. This scenario is physically impossible, yet the analysis conveniently treats it as if it were a credible operational scenario.
Hydrogen is not simply a “clean” alternative:
It has an autoignition temperature far lower than methane, with flame velocities eight times faster, making any accidental release likely to result in catastrophic detonation in congested areas.
It is a simple asphyxiant, capable of displacing oxygen and creating life-threatening conditions without warning.
The proposed hydrogen infrastructure—high-pressure compression, storage, blending, and transport—is concentrated in a relatively small footprint adjacent to administrative buildings and operational areas, multiplying potential consequences in the event of a leak.
Framing this as an environmentally progressive modification is dangerously misleading. The project’s safety modeling is based on overly conservative assumptions that cannot guarantee actual operational safety. The “hydrogen fantasy” is a clear example of regulatory capture masquerading as innovation.
2. The scale increase and technological modifications exacerbate risk
The proposal to increase capacity from 64 MW to 180 MW, combined with the addition of reciprocating engine technology, further increases complexity and cumulative risk. Each new unit introduces additional pressurized fuel systems, new failure points, and higher potential for catastrophic release events. The Preliminary Hazard Analysis tables confirm the multiplicity of scenarios where flash fires, jet fires, pool fires, vapor cloud explosions, and confined detonations are all credible. The risk assessment, however, downplays these dangers by assuming all operations are mutually exclusive in practice—a scenario that is both unrealistic and unsafe.
3. Biodiversity impacts, despite claims of minimal disturbance
The modification claims to reduce native vegetation clearing by 0.08 ha and increase planted native trees by 0.01 ha. These numbers are trivial in isolation but mask a fundamental problem: the project still targets critically endangered ecological communities (Box Gum Woodland CEEC) and sensitive grasslands. The biodiversity assessment frames minor changes as net positives, yet fails to account for cumulative impacts of high-pressure fuel infrastructure, increased traffic, construction activity, and potential accidental releases of flammable gases or fuels. Reducing ecosystem credits by “one credit” does not justify expanding the industrial footprint in a fragile environment.
4. Public safety and industrial prudence
The proposed Modification assumes risk contours are contained within industrial land and that surrounding facilities, schools, hospitals, and public areas are unaffected. However, these assumptions ignore secondary hazards such as:
Emergency response limitations in the event of hydrogen detonation or large biofuel fire
The compounding effects of simultaneous multi-fuel leaks
Human error, equipment failure, or unplanned renewable energy surpluses feeding hydrogen production beyond modelled assumptions
Accepting this modification as proposed would represent a failure of regulatory oversight and an abdication of public safety responsibility.
Conclusion
The Modification 1 proposal is unsafe, scientifically dubious, and environmentally negligent:
Hydrogen as a fuel at this scale is a failed fantasy with catastrophic risk potential.
Increasing generation capacity and introducing new technologies multiplies the danger to workers, local communities, and the environment.
Biodiversity impacts, while small on paper, compound the overall threat to sensitive and critically endangered ecosystems.
The proponents’ risk assessments are overly optimistic, based on scenarios that cannot exist in practice.
For these reasons, I strongly object to the approval of Modification 1. Any expansion of the Dubbo Firming Power Station must first:
Abandon the hydrogen proposal or fully justify its safety with independent, peer-reviewed engineering assessments.
Restrict power generation to the originally consented 64 MW footprint until risk mitigation can be independently verified.
Ensure biodiversity offsets are meaningful and not trivialized to a single ecosystem credit.
The Dubbo community, workers, and environment cannot be used as guinea pigs for a high-pressure hydrogen experiment masquerading as renewable energy progress. This modification should be rejected in its entirety.

I support the project

Please see attached documents (2).