Restart of Redbank Power Station

Please find the submission from the Australian Foundation for Wilderness (Wilderness Australia) attached below. Supporting material is also attached, as referenced in the submission.

I object to the project and kindly request that you do not approve the application by Verdant.
This project will create a new market for wildlife habitat destruction and incentivise native tree clearing;
- 1,480,000 dry tonnes of wood is anticipated to be produced from clearing in years 1-4 of the project. This high volume should make it a matter of National Environmental Significance and require assessment under the Environment Protection and Biodiversity Conservation Act 1999 for its impacts on federally listed threatened species;
- The EIS fails to sufficiently identify the specific areas and species to be cleared or reflect on the cumulative impacts of intensive clearing over the life of the project;
- The EIS fails to account for greenhouse gas emissions from the broad scale tree clearing that underpins this project. The NSW Government should analyse the gross level of emissions attributable to tree clearing over the life of the project;
- Biomass burning is not clean. It emits more greenhouse gases per unit of energy than coal. Biomass burning is not GREEN. Clearing native vegetation destroys habitat and prevents desperately needed ecological recovery;
- Over time, the effects of land clearing - through fragmentation and disturbance - further degrade the condition and habitat values of remaining vegetation;
- The NSW Government has committed to reigning in excessive land clearing and acknowledges that the State’s environment laws fail to protect biodiversity, including our endangered Koalas and Greater Gliders. It is ludicrous to approve a project that depends on retaining, not fixing, weak clearing laws.

Please can you consider how this negative and irreversible downstream effects that logging and land clearing will have on future generations and our inability to cope with a worsening climate crisis.

Biomass Burning to produce power is not a Green process. "Verdant" is cynically using weak tree clearing laws in NSW to try and implement a flawed idea. Biomass burning emits more greenhouse gases per unit of energy than coal. 98% of the world's top scientists agree that burning fossil fuels must be rapidly phased out and no new projects started if we are to address runaway global overheating, therefore it makes no sense to approve a project that has a larger emission than the one it is replacing.
Burning biomass for power would create a new market for wildlife habitat destruction and create an incentive to clear more native trees.
The NSW government has committed to stop excessive land clearing because our current environmental laws fail to protect
our wildlife habitat and biodiversity. Here is a chance to act on your promise.

Given the anticipated amount - approx. 1.5 million tonnes - of wood required in the first four years of this project, this surely is a matter of National Environmental Significance requiring assessment under the Environmental Protection and Diversity Conservation Act because of it's impacts on Federally listed threatened species, especially since the EIS fails to sufficiently identify the specific areas and threatened species which would be impacted.
The EIS also fails to account for the greenhouse gas emissions from the broad scale clearing that would be required for this project. The analysis needs to also include the GROSS level of emissions caused by the tree clearing over the life of the project.

The IPCC has clearly outlined exactly what we must do to stop the harm caused by global overheating and the resultant devestating
weather patterns which have become more frequent and more severe resulting in the death and distress and destruction of infrastructure of large numbers of people across the world, and the enormous resulting costs to Goverments. THIS PROJECT MUST NOT GO AHEAD, there are many better alternatives. Please think of our grandchildren.

Burning Biomass from clearing land is not acceptable. Redbank Power station should be left decommissioned and the money instead allocated to renewable energy projects.

I support the project to restart as it will be good for the local economy , a step in the right direction for renewables and good for stability of electricity supply

Submission re Redbank Power Station operating by biomass combustion

I am against the approval of Redbank Power Station for many reasons.

In haste, I describe a few as I have had little time to prepare this submission. The time frame has been far too short for the considered and in depth technical response required for a proposal of such far reaching consequence.

Inherent risk in every aspect of wood biomass combustion
The combustion of forest derived (wood) biomass for energy, and/or any cellulose based material, whether it be wood biomass is derived from native forest clearing or planned plantations for burning, or clearing activities or any other form of wood organic waste, poses inherent air quality, climatic, human health and other risks; it guarantees environmental, economic, legal and/or reputational damage.

AIR QUALITY: Wood biomass is an inherently inefficient power source emitting at least as much, and up to one and a half times more C per unit of energy than coal, dependent on the wetness of the biomass feedstock, this makes it an immediate target for climate action litigation. Hence, the legal, economic and reputational risk for all involved in developing, approving, operating or benefitting from such a source of energy.

Biomass burning creates toxic compounds:
Concentrations of the nitrous oxides which will be produced by this proposal would not be allowed in some jurisdictions, and soon are unlikely to be allowed by Federal govt. Carbon monoxide and other products of incomplete combustion, such as benzene and formaldehyde, are also common in biomass burners.

Recent Chinese research highlights damaging interactions between point source and ambient emissions as a result of biomass burning.
There are international precedents for class action re air quality in relation to these toxins.

Most importantly biomass plants emit Particulates Matter 2.5, the size that penetrates deep into the body inflaming lung and respiratory tract leading to cardiovascular disease, respiratory problems and weakened immune systems

By 2020 the World Bank was warning about the link between air pollution and Covid transmission

The International Journal of Research into Public Health reported the relationship between PM2.5 and the Spread and Increase of Covid-19 Morbidity and Mortality.

An Italian study correlates Covid incidence with PM 2.5 levels.

July this year the Indian Institute of Tropical Meteorology reported that not all PM 2.5 particles carry Covid; it’s specifically the black soot from biomass burning, PM 2.5 black carbon. These aged biomass particulates aggregate and react with other compounds to grow in size providing temporary virus habitat.
Which penetrate deep into the body inflaming lung and respiratory tract leading to cardiovascular disease, respiratory problems, weakened immune systems, which in turn heighten Covid impact.

This proposal’s air quality assessment methodology is inadequate It relies on a govt document, when the EPA specifically states NSW govt guidance should be a last resort.
http://www.npi.gov.au/system/files/resources/3ae8d11b-1ece-ff74-5dc5-cbc7d27a4aa6/files/boilers.pdf

"The EPA's preferred methods are direct measurements for existing sources and manufacturers' design specifications for proposed sources.

Emission factors are generally used when there is no other information available or when emissions can reasonably be demonstrated to be negligible." (not the case here).

Examples of CFB boilers burning wood pellets with similar mitigation aren’t provided, nor trial results. The boiler could at least be fired up with wood pellets for a few hours and measurements taken of what actually comes out the stack. Or the boiler manufacturer's specifications re wood burning should be cited.

The proposal doesn’t refer to changes to federal air quality standards, likely to change again soon with the info coming out of the rapidly expanding field of research re Covid transmission and air quality and mortality links with air quality diminution.

REPUTATIONAL RISK: LACK OF SOCIAL LICENCE
Industrial scale wood combustion power is completely rejected by most Australians. Current carbon accounting loopholes that permit subsidisation on which this industry relies will be closed. There is zilch social licence for burning any trees for power.

150 organisations have endorsed The National Position Statement against the use of FB for power. Lack of social licence is beginning to cross party political boundaries. In 2019, The Australian published an article called: Biomass fuel: the great carbon con. The Australian Religious Response to Climate Change—every denomination bar one—and the Climate and Health Alliance of Australia are only 2 of those 150 organisations which endorsed a submission only last year calling not only no native forest biomass combustion but no wood combustion power at all. Owing to the global nature of emissions generated, calls are also being made for export controls to prevent export of our forest biomass for this industry.

LEGAL CHALLENGES
Parliaments elsewhere have had to retract biomass approvals or increase conditions for existing biomass plants to continue operating. Air quality, biomass storage dangers, noise and dust issues manifest when the paper blueprint translates to the real world. The new restrictions impact energy output thus profit, resulting in legal battles that can consume public funds. Taxpayers don’t like it especially when the evidence was already there that this is a dangerous industry likely to be subject to rapid regulatory ‘catch ups’. Approving burning forests at this stage of climate crisis is to ask for litigation and/or reputation damage.

ECONOMIC RISK
The Task Force on Climate-related Financial Disclosures (TCFD) was established by the G20, through the Financial Stability Board (which is the central banks and finance ministries of each participating country). The Task Force considered how companies should report financial exposure to climate change. and recommends reporting under the four headings of: governance, strategy, risk management with indicators and targets; it’s promoting that disclosure move from optional to mandatory. The Australian Prudential Regulatory Authority, the Australian Securities and Investment Commission [ASIC] and the Reserve Bank of Australia are now involved.

Soon biomass power plants will need to disclose climate related risk reporting on governance, strategy, risk management with indicators and targets and there could be penalties for misleading information. Pressure will rise on industries/technologies open to climate related risk.

Challenges by Investors to information provided by companies and particular industries in relation to CC have already occurred.
In the US 27 INVESTMENT ORGS PETITIONED THE SECURITIES AND EXCHANGE COMMISSION (sec) to require companies making and using biomass, wood pellets, biochare, etc to substantiate their claims of climate benefits so that investors won’t be misled. (2019)
Legal challenges to both biomass combustion and wood pellet manufacturing plants are already on the rise, as are challenges to liquid cellulosic fuels from forest biomass.
The risk of litigation from these activities is high and can increasingly involve class actions, be it on human health or CC angle or resource misuse and amenity destruction.
Policy change means a big risk for investors and governments spending taxpayer funds on accommodating any aspect of FB facilities.
As the European Academy of Sciences and the IPCC are respectively against and becoming extremely wary of FB, it’s likely that quite soon there will be a reversal of international policy regarding the so-called carbon neutrality of FB. Along with that will come the cessation of subsidies for it as a renewable. This will almost certainly make Redbank unviable, a big loss-maker, a stranded asset.
ECONOMICS, ENERGY AND EFFICIENCY:
Global emphasis on energy efficiency accelerates. The United Kingdom has introduced stricter provisions so is now looking at emissions from transport and harvesting of bioenergy feedstocks. This is totally changing the investment environment. In Japan the feed-in tariff scheme has been adjusted to reflect the indirect emissions from feedstock sourcing. Japan's Ministry of Economy, Trade and Industry [METI] is looking closely at emissions and sustainability from biomass with further changes expected.
South Korea has changed its subsidy regime to clamp down and in some cases remove some incentives for forest biomass because of inefficiency
An engineer’s assessment of this proposal, based on the proposal’s own figures puts net efficiency of just 31%, (calculation can be supplied). This means wastage of 69% of all the wood burned will be wasted entirely.

The EU Renewable Energy Directive (Article 29(11): only allows biomass energy to count towards renewable energy targets and to be subsidisidised as renewable energy if it's either generated in a small plant or it meets minimum efficiency standards. The minimum net efficiency standard for a plant with an energy input of at least 100 MW (i.e. similar to Redbank) is 36%. This is already pitifully low for a 100 MW plant. 31% for an even large plant is shocking. A plant that's linked up to district heating (obviously not an option at that site) easily achieves way over 70% net efficiency.

HEALTH AND SAFETY RISKS
Risks of fire and explosion are high. Redbank doesn’t have experience with handling and burning wood. There's nothing in the planning statement that acknowledges fire risks and sets out fire safety measures.

Ironbridge and Tilbury B burned wood pellets and Hunter Energy want to burn woodchips which are less dry but storing large quantities of woodchips (e.g. 40,000 tonnes at any one time – which would be just over 3 weeks' worth of woodchips for the plant) carries risk of self-ignition or self-combustion of the woodchips. Once sponta

This project will create a new market for wildlife habitat destruction and incentivise native tree clearing;
1,480,000 dry tonnes of wood is anticipated to be produced from clearing in years 1-4 of the project. This high volume should make it a matter of National Environmental Significance and require assessment under the Environment Protection and Biodiversity Conservation Act 1999 for its impacts on federally listed threatened species;
The EIS fails to sufficiently identify the specific areas and species to be cleared or reflect on the cumulative impacts of intensive clearing over the life of the project;
The EIS fails to account for greenhouse gas emissions from the broad scale tree clearing that underpins this project. The NSW Government should analyse the gross level of emissions attributable to tree clearing over the life of the project;
Biomass burning is not clean. It emits more greenhouse gases per unit of energy than coal. Biomass burning is not GREEN. Clearing native vegetation destroys habitat and prevents desperately needed ecological recovery;
Over time, the effects of land clearing - through fragmentation and disturbance - further degrade the condition and habitat values of remaining vegetation;

The NSW Government has committed to reigning in excessive land clearing and acknowledges that the State’s environment laws fail to protect biodiversity, including our endangered Koalas and Greater Gliders. It is ludicrous to approve a project that depends on retaining, not fixing, weak clearing laws.

See attached PDF.

This project would result in very extensive clearing of native trees and loss of wildlife habitat. The remaining native vegetation in the state is already quite fragmented particularly in the Hunter Valley region so we shouldn't allow further clearing on the scale required by this project.
The state government has committed to better control of land clearing but this proposal would only accelerate land clearing.
The EIS doesn't provide enough information about what areas and tree species are proposed to be cleared or the impacts over the life of the project.
This project should be considered a Matter of National Environmental Significance and be assessed under the Environment Protection and Biodiversity Conservation Act 1999 for its impacts on Nationally listed threatened species because nearly 1.5 million tons of wood is expected to be required over the first 4 years.
The EIS doesn't account for the greenhouse gas emissions from tree clearing. The gross emissions over the life of the project should be considered.
I don't believe that biomass burning produces 'clean energy'. Instead it produces more emissions than coal. If we can't meet our energy needs with renewables it would be better to use coal for longer and retain our forests for their various values such as storing carbon, catchment protection and biodiversity conservation.

I would like to object to the project of Redbank power station burning fuel from logged .Letting Verdant burn 850 000 tonnes of habitat and woodchips per year is not an action of a first world country. We currently have a lot of endangered species that are pushed by the brink of extinction by logging and this proposal which has an even destruction of current logging would end them. Victoria and Western Australia have banned native forest logging and NSW goes ahead with backwards and insane proposals like this. The new proposed fuel source for Redbank power station will create a market to destroy even more habitat.

This proposal seeks to exploit NSW land management rules that are failing to protect natural habitats and are so broken and weak that are currently under review. This project is an poor attempt over the better other real renewable energy solutions. It will not help, but hinder decarbonisation of the energy system. Burning cleared vegetation is not carbon neutral and the project would create a new source of greenhouse pollution.

The proposal is to use cleared habitat and forest biomass from land that has been stripped for farming, not regrowth, meaning there will not be any future carbon sequestration to theoretically reduce the power plant's emissions.Burning biomass due to it releasing dangerous air pollution has a range negative health impacts to the nearby population such as such as allergies and chronic obstructive pulmonary disease (COPD).

Great initiative to reuse existing sites for other uses. Hoping this will create jobs for the local Singleton and surrounding communities

Australians for Animals NSW Inc finds the EIS extremely deficient and devoid of adequate analyses and evidence. Noting the proposed use of 850,000 tonnes annually,fed from biomass within a 300km radius, no evidence has been provided which would indicate surveys of potential biomass, locations, transport arrangements, noise, traffic, time of year. The charity notes the inclusion of " Mallees and Certain Gums (DPI trials) "as biomass with no information or evidence of where Mallees are currently located, what species of eucalypt are " Certain Gums", what is the growth pattern of these gums, in what part of the growth cycle would the gums be used for biomass burning ? How many hectares are planned ? Where ? Who logs them ? without any proper details of the proposed gums, proper responses can't be made. There is no evidence of the potential amounts of other suggested biomass fuels, where they would be located in the 300km radius ( which also must include some part of the required 850,000 tonnes of fuel annually. What are " purpose grown biomass crops"? What are the growth cycles, how many hectares are available? Where is the evidence of " waste cleanups" from Floods, bushfires, earthquakes that could give an average over say the last decade? What quick rotation crops are proposed? Where will they fit into the 300 km radius? Who owns the land within that area ? What are " approved clearing activities?". The vagueness, lack of detail, failure to adequately cover critical issues such as evidence of the extent of fuel available within a 300 km radius, what type of biomass, land ownership, environmental considerations of proposed 300 km radius, what species, what clearing. As a state significant development, the extent of information provided by the EIS is poor, fails to adequately research biomass fuels, relying on motherhood statements with zero evidence to support.

I oppose the restarting of Redbank Power Station for many reason - the main reason being that we are in the midst of a climate crisis! The burning of biomass to create power is not a carbon neutral option and we need to divest from this as soon as possible. The burning of biomass creates CO2. This process actually emits 50% more CO2 than the burning of coal.
It is my understanding that VET is proposing to get a significant amount of its biomass from invasive native species on private property, which indicates that there is no intention of replacing this vegetation.
Other issues with this are:
- there is a significant amount of construction waste produced in this process, this is not sustainable.
- the biomass needs to be transported by B-double trucks - this is not sustainable.
- air pollutants from this process include volatile organic compounds, methane, nitrous oxide, lead, mercury and sulphur dioxide - this is not sustainable!!!
It is really disappointing and scary to see investment in projects like this rather than investment in genuine renewables like solar and wind.

Please do the right thing and think of the world you are leaving for the generations to come. It is not too late
Thank for you for your time

This will create more jobs for locals and help feed electricity onto the grid.

I refer to Verdant Earth Technologies proposal to repurpose the closed Redbank power station (near Singleton) to burn 850,000 tons of north-east NSW's forests every year for electricity, and to increase land clearing to meet their needs.

Native forest biomass is not a renewable energy source. This proposal would be disastrous for climate change abatement, contribute to the extinction risks for our native wildlife, and impact the health of local citizens. It has no social license.

The NSW Parliamentary inquiry into “Sustainability of energy supply and resources in NSW” in August 2021 found that “Native forest biomass isn't a renewable energy source due to the fact that “it reduces the ability of NSW forests to absorb atmospheric carbon and produces carbon emissions”.
They recommended that the NSW government exclude native forest biomass from being classed as renewable energy, and ensure that it is not eligible for renewable energy credits.
They asked that the definition of native forest biomaterial under the Protection of the Environment Operations (General) Regulation 2009 be amended to prevent the burning of wood from native forests to generate energy.
Burning native forest biomass is inconsistent with the objectives of the Renewable Energy (Electricity) Act 2000 in that it produces more emissions than coal per equivalent amount of energy generated and thus does not reduce greenhouse gas emissions in the electricity sector or make a genuine contribution to the achievement of Australia’s greenhouse gas emissions reduction targets.
The health of local citizens will be impacted in that “wood smoke contains tiny particles and gases that can have serious health effects when breathed.” https://apps.ecology.wa.gov/publications/publications/91br023.pdf
Logging native forests and burning them has no social license. In 2018, a study commissioned by the Forest Wood and Products Australia found that 65% of rural based respondents found native forest logging unacceptable, with only 17% of those in the bush supporting logging in native forests. Since 2018, awareness of the plight of our endangered species has increased. Further the climate has worsened and people are becoming aware of the cooling value of trees. Now more and more people want to see our native forests protected for biodiversity and their ecosystem services rather than logged for what are increasingly low-value commodity products such as pulp and potentially biomass for combustion.
Allowing native forest wood to be included as a fuel source provides an incentive for intensified logging and more land-clearing. It then creates an additional carbon cost with the hundreds of thousands of additional truck movements required to get the wood to the power stations creating further adverse impacts on Australia’s greenhouse gas reduction progress.



With a Climate Code Red, our forests are the best technology we have for removing carbon from the atmosphere. We need them to be allowed to get on with the job.

I support this project and its ability to provide low-emission baseload power to the National Energy Market (NEM).

Australia's growing population coupled with industrial development and the imperative of decarbonisation has resulted in an increased demand for electricity. However, the accelerated closure of coal-fired power stations and the intermittent nature of existing renewable generation will continue to pose a challenge to maintaining consistent baseload capacity, leading to potential supply shortages and price volatility, especially during periods of high demand or low renewable output. Therefore, supplementing the renewable energy mix with additional low emission baseload capacity is a good idea to maintain a reliable and secure energy supply in the National Energy Market (NEM).

Repurposing the Redbank facility to operate on biomass will provide much needed baseload generation while assisting Australia in meeting its renewable energy objectives. Moreover, the reduction in greenhouse gas emissions associated with repurposing the site is significantly lower compared to constructing a new plant with equivalent capacity.

The commitment to not use residues from native forest logging and solely use biomass sources that have no higher use, until their own plantations are established, demonstrates a responsible approach. Redbank claims to be reducing greenhouse gas emissions by approximately 96% compared to the currently approved fuel (coal tailings). If this plant displaces output from other coal fired baseload stations, then any emissions reduction is a good outcome for Australia.

Australia's green power accreditation provides standards and criteria for sourcing biomass for electricity production. Key elements of these criteria include considerations such as land use, prioritising higher-value reuse over burning the fuel, minimising habitat disruption, and mitigating air and water pollution, as well as reducing greenhouse gas emissions.

The focus of the discussion should not be on whether the plant should be restarted, but rather on ensuring the sustainability of its fuel source. It is the responsibility of the department to impose appropriate conditions on the permit to ensure that only sustainable fuel sources are utilised for the power plant, rather than halting the project altogether.

Please see attached submission.

I submit my objection & oppose this development in the strongest possible terms. 
We are in a climate and biodiversity emergency and a development like this will only exacerbate these problems.

In light of the alarming & escalating impacts from climate change & the extinction of our wildlife, this proposal could be regarded as negligent at this time and place.

The scientific evidence regarding the urgency which should be shown to reducing our carbon emissions and protecting the precious remaining habitat of our unique endangered wildlife cannot be ignored or overlooked any longer.

We know without urgent action, our Koala populations could be extinct by 2050.
This proposal will only exacerbate that extinction process for Koalas & other endangered species.

The proposed supply of 850,000 tonnes of biomass required each year, will require a major increase in the rate of land clearing, especially in the Hunter valley and on the tablelands.

This proposal will creat a market for large volumes of biomass that will provide an economic incentive to clear land that would otherwise not have been cleared.

Most land clearing is unapproved & unregulated and if there is an application for an approval to clear land, there is no requirement for surveys to identify habitat of threatened species.

It is undeniable that burning wood to fuel this converted coal burning power station will produce more CO2 and other pollutants than coal to produce an equivalent amount of electricity. 

This proposed polluting power station will release over 1.3 million tonnes of CO2 each year, while increasing emissions from debris and soils at the clearing sites, and from processing and transporting woodchips.

There will be unacceptable negative impacts of sourcing 850,000 tonnes of woodchip  on our already overexploited  and stressed native forests in terms of habitat loss and disruption to the water cycle. 

Landclearing and associated habitat fragmentation are the single greatest threat to biodiversity in NSW.

Landclearing and logging are not in the public interest – they do not have a social licence, and do not require public consultation through a Development Application process like other developments on private land.

In this day and age with extreme weather events becoming normal, native forests are worth more standing for biodiversity protection, carbon capture & storage and water catchment integrity.

Moreover, the added negative effects of bushfire, air quality and disruptions to neighbouring communities from the hugely increased truck movement required to transport this material must be given serious consideration, particularly in light of the high levels of air pollution in the Hunter Valley.

A recent NSW Parliamentary Inquiry recommended that native forest biomaterial not be classed as renewable energy or eligible for renewable energy credits as it is not a renewable or sustainable source of energy.

This proposal is a strong echo of the disastrous, now abandoned, woodchip export activity from Newcastle by Sawmillers Exports Pty Ltd.  They too proposed to source their product from forest logging waste, sawmill waste and silvicultural thinning. This was proven time and time again not to be the case. Instead the company was shown to be using young healthy trees which should have been left as part of a healthy regenerating forest to be utilised for future sawlogs. This must not be allowed to happen again.

It is time to abandon the wilful blindness to the profound disastrous effects of native forest destruction.

Even though not mentioned, I completely oppose any use of burning any form of plastic as an energy source.

We should be at a point where we have evolved to circular economy, instead of the destructive, consumptive linear and recycling economy, that exists using raw resources with a single use.

For the sake of our future and that of future generations I urge you to exercise your due diligence & duty of care and reject this unacceptable proposal.

1. We argue that burning biomass is not a ‘green’ initiative as claimed;
2. This project claims there are a number of selling points yet a key plan still needs approval;
3. We are concerned that approval to burn cleared native forests for energy will see an increase of clearing of koala habitat;
4. The impacts of clearing for biomass have not been adequately addressed.

Pls see attached submission.