Restart of Redbank Power Station

I object to this project. We are in a climate and biodiversity emergency. We cannot continue with these reckless behaviours. We must place forests under protection

The new proposed fuel source for Redbank power station will create a market to destroy even more habitat.
This project is an unnecessary distraction from 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.
A massive increase in truck movements to deliver fuel to Redbank is another source of emissions and a far-reaching disturbance.
The proposal seeks to exploit NSW land management rules that are unequivocally failing nature and that are currently under review.
Biomass has negative and unjust health impacts including releasing dangerous air pollution.

I am a retired engineer, living in the Lower Hunter. I am concerned about the impact human activity is having on the natural environment, as I observe the enviornment around me changing dramatically as the area becomes more developed to provide a lifestyle which can never be sustainable.

I object to this proposal for the following reasons:

1.Verdant Earth Technologies (VET) seem to think that by calling their proposed timber fuel, "invasive native species", it will become acceptable even though the burning of wet timber is far less efficient than burning coal and emits 50% more CO2 per MWH than burning coal, partially due to the moisture content. This alone should be enough to reject this proposal.

2. There are hardly any invasive native species in the Greater Sydney, Hunter and Coastal districts, certainly not enough to fuel a power station, so fuel would have to come from much hundreds of kilometres away, transported by at least 56 B double trucks coming and going each day. This in itself, would produce large amounts of CO2, not considered in the EIS. Also, damage to roads would be huge.

3. VET claim that their project would help "help decarbonise electricity generation" and be "ecologically sustainable", but the above examples demonstrate that this is untrue. Clearing, transporting and burning would all produce CO2 and other pollutants. Clearing would also require development approval in some circumstances. This is not mentioned in the EIS

4. Building waste burnt as fuel, might contain many unknown polluting substances as the recent Sydney asbestos in garden mulch situation has demonstrated.

5. The EIS predicts that burning 850,000 tonnes of wet timber will produce zero CO2 but in fact it will produce 1.3 million tonnes of CO2 ( plus CH4 and NO2 which are hazardous) plus all the emissions of the associated activities.

6, There has been no assessment of the environmental impact of the land clearing which could have large effects on biodiversity and threatened species, already under great stress from habitat loss due to drought, clearing and fires.

7. Creation of a market for cleared native species biomass will only encourage more clearing and should be discouraged.
Native vegetation should be left in the ground to store carbon, as far as possible.

8. Air quality issues can result from burning biomass which can produce particulate emissions, volatile organic compounds (VOC'S), nitrous oxide, sulphur dioxide, lead and mercury, not mentioned in the EIS.

9. The NSW State of the Environment Report states that land clearing is " the main threat to the suvival of species" which must be reduced.

10. In 2019, scientists from accross the world signed a letter condemning the burning of biomass for electricity:
http.//www.pfpi.net/wp-content/uploads/2018/04/UPDATE-800-signatures_Scientist-Letter-on-EU-Forest.pdf

For the above reasons and many more not mentioned, this proposal should not be approved.

I strongly object to all levels if the project - cutting down native trees destroying habitat then burning these trees and calling it green sustainable energy. We need to keep trees in the ground and plant more for species preservation both the trees themselves and all the other species that live in, on or near them. Trees also sequester carbon while cutting them down releases more carbon.
It is a lie to call cutting down trees and burning them “green energy”. It creates more carbon in the atmosphere in two ways removing the trees in the first place snd then burning them in second place. I find it almost beyond belief that this needs to be pointed out.
If anything is to be done with Redbank it needs to be renewable energy
Yours sincerely
Helen Kvelde

Australia has enormous resources of end-of-life woody biomass with no alternative higher end use that could be utilised for renewable energy. This huge untapped green energy resource should be utilised to enable Australia’s energy industry to reduce its high carbon dioxide emissions and to help the nation to meet its carbon targets by 2050.
Green energy projects utilizing end-of-life woody biomass such as Redbank Power Station at Warkworth in the Hunter Valley, besides significantly lowering the carbon emissions, will also provide hundreds of new direct and indirect jobs for the region. Red Bank Power Station would also provide crucial continuous baseload for the grid that is badly needed. It will help to stabilize the grid and therefore stop black outs occurring. According to government’s own experts report, Red Bank Power Station project will also create a 2.5M tonne carbon sink through Redbank's own purpose-grown biomass crops.
In Europe purpose grown energy biomass and end-of-life woody biomass without any higher end use, play decisive role in Europe's green transition away from coal, gas and oil. Some European renewable energy power plants are even importing purpose grown energy biomass from Australia! In my opinion Australia should first of all utilize this valuable resource for its own carbon free future instead of shipping it away.
For the above reasons I strongly support the restart of Red Bank Power Plant in the Hunter Valley.
Yours sincerely
Minna Vilkuna

• 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.

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 find updated submission for Hunter Environment Lobby Inc. The updated submission is more detailed - please advise of receipt.

The forests of eastern NSW are part of one of the world’s 35 biodiversity hotspots because of their exceptional species endemism and extensive habitat loss.
There is nothing ecologically sustainable about clearing tens of thousands of hectares of native vegetation inhabited by millions of native animals in the midst of a biodiversity crisis, and converting it into carbon dioxide to worsen climate heating.
Landclearing and associated habitat fragmentation are the single greatest threat to biodiversity in NSW, and yet most clearing is unapproved and the approval process requires no surveys to identify habitat of threatened species.
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.
Land clearing has rapidly escalated over the past decade, making NSW part of one of the of the world’s 24 deforestation fronts.
To supply the 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.
Creating a market for large volumes of biomass will provide an economic incentive to clear land that would otherwise not have been cleared.
Land clearing needs to stop, not expand.
Claims that over four years 56,000 ha of biomass crops will be planted to provide 70% of feedstock have not been planned, are not credible and unlikely to eventuate.
It is recognized that the current proposal does not include logging residues, though the other sources of biomass are so poorly assessed and unlikely to provide the feedstock required, that there is a high risk that a variation to include logging residues will be made soon after approval.
The pretense that burning 850,000 tonnes of biomass for electricity every year will result in no emissions of CO2, and is thus clean energy, is a nonsense.
The power station will release over 1.3 million tonnes of CO2 each year, with increased emissions from debris and soils at the clearing sites, and from processing and transporting woodchips.
Burning wood for electricity is far more polluting than coal.
We need to reduce our emissions of CO2, not dramatically increase them as intended by this proposal
The use of solar and wind as alternative power sources need to be considered, rather than just comparing the proposal to coal.

Re. Restart of Redbank Power Station
Application No. SSD-56284960

I write to object to this devious development application proposed by Verdant Earth Technologies Limited, for the following reasons:

1. The name of the company itself is misleading, the word "Verdant" suggesting that the company is committed to green, environmentally-friendly technological solutions. Clearly, what the application proposes is neither green, nor environmentally-friendly.
2. The project will incentivise clearing of forests and ground vegetation, and impact on native wildlife habitats.
3. The amount of wood (1.48 million of tonnes) expected to be produced from clearing in the first four years of the project alone is disconcerting, and should be assessed under the Environment Protection and Biodiversity Conservation Act 1999 for its impacts on federally listed threatened species.
4. Biomass burning is not clean and environmentally friendly, and emits more greenhouse gases per unit of energy than coal.
5. The ongoing impact of fragmentation of native forests by logging has been well documented in south-east Asian countries, where islands of remaining forests have ever-shrinking numbers of native wildlife species and biodiversity. It is not in the interest of either the environment or the Australian public to have such huge amounts of forests and vegetation cleared. Australia already occupies the shocking first place in the world for its land-clearing practices.

I have not made any reportable political donations in the last two years. I acknowledge and accept the Department’s disclaimer and declaration.

This project depends on tree clearing as its source of fuel. It will promote native tree clearing by providing a new market for wood. Biomass burning is not clean; it produces a high level of greenhouse gases per unit of energy. The EIS does not sufficiently identify the areas and species to be cleared. The project is underpinned by broadscale tree clearing which destroys wildlife habitat and prevents ecological recovery. It is unlikely to be restricted to using trees that would be cleared for other reasons. Its long-term effect would be an environmental disaster and contribute to greenhouse gas emissions.

Logging of native forests is a completely unsustainable and destructive practice. Native forests are a finite resource that take hundreds of years to recover from logging activity, and the impacts to remaining forest is immediate and long term.

Native forests provide habitat for our unique Australian fauna, flora and provide personal and economic benefits to our community through personal experiences, outdoor activities such as hiking, camping and fishing, tourism, education and research.

Native forests are proven to protect and clean our waterways, lift water from the ground to generate rain, prevent and reduce the impacts of bushfires, lower the impacts of temperature and climate change, reduce the impacts of high wind and erosion and much more. Logging immediately introduces hot spots through a forest canopy that kills off these benefits in the surrounding area, introduces weeds and undergrowth.

Logging increases the frequency and intensity of bushfires as a result of drying out the forest floor, introducing dry fuel loads and excessive undergrowth.

Logging increases sediment runoff and erosion into our waterways, increases the risk of flood events, and impacts our native forest's ability to generate rain through transpiration.

Despite this native forest logging continues at incredible taxpayer expense, operating at losses under the false narrative that it is necessary to log native forests for building resources and timber products. In reality our native forests are being ripped out at an alarming rate, for no economic benefit, at a commercial loss for pulp, small timber and now - unbelievably - to burn.

It is absolutely inconceivable that our native forests are proposed to be harvested simply to burn them for energy, where has the common sense, commercial sense, or any thought process come from to form such a short sighted conclusion?

Burning native forests for energy is going to further impact the limited native growth we have left. It will increase bushfire risks and intensity. It will damage our waterways and increase the risk of flooding. It will permanently destroy native forest ecosystems well beyond the logging zones.

And worst of all, tax payers will be footing the bill to uphold this activity so it can continue to operate at a loss and at the expense of one of the most invaluable resources and environments we have left.

Complete disregard for future generations, I oppose this strongly. Please reject this proposal and value our most precious resources. There are more jobs and economic benefit in conservation, forest management and tourism than logging. Native forest logging should be stopped entirely and moved to increased plantations for timber production.

This submission is made by the Southern NSW Branch of BirdLife Australia. We welcome the opportunity to comment on the ‘Restart of Redbank Power Station’ using biomass.

BirdLife Australia is Australia’s largest bird watching, bird research and conservation organisation. For more than 100 years BirdLife has been a leading advocate for native birds and for those who value them. We are an independent not-for-profit organisation with over 190,000 supporters nationally. We have many regional Branches, Special interest Groups, Reserves and Observatories, and a single aim: creating a bright future for Australia’s birds.

The use of trees to fuel this power station will lead to more clearing of forests and woodlands by landholders. These forests and woodlands are vital to the survival of birdlife that inhabit them, as well as other wildlife. There has been a large reduction in the number of birds (up to 60% in some areas) in the last 30 or so years and this is directly due to land clearing. Further loss of habitat will lead to more species becoming endangered and for some species becoming extinct.

Regent Honeyeaters and Swift Parrots are critically endangered (EPBC Act) and under particular threat. In the last six weeks an estimate of Swift Parrot numbers left in the wild has been made and it appears that it may be only 500 in total. Just 5 years ago it was estimated that there were about 1500 in the wild. This dramatic decrease in numbers is due to habitat loss, from logging, fires and land clearing. The use of trees to fuel this power station will realistically only encourage further logging and land clearing.

In addition there is concern that the burning of trees will produce emissions that will lead to the worsening of climate change, despite assurances to the contrary.

We ask that the Restart of Redbank Power Station not be approved.

Yours sincerely
Dan Vickers
Conservation Subcommittee
BirdLife Southern NSW
[email protected]
https://www.birdlife.org.au/

I object to the reopening of the fossil fuelled Redbank Power Station.
Burning timber or ‘waste’ of any kind including household waste, is not the solution.
Only careful use , avoidance of wasting energy and use of renewable energy such as solar, wind and wave will give us opportunity to save ourselves from this climate chaos which is upon us.

Australia has a shameful reputation for clearing bushland and habitat for native species.
It is known that clearing bushland increases drying and heating of the earth and drives the increase of severe bushfire danger.
Do not allow this crazy proposal to go ahead.

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, Greater Gliders and all other native wildlife. You are clearing native forests at rate unsurpassed in the would expect for the Amazon - lungs of the planet. You are encouraging and financing the slaughter of our precious kangaroos who have been here for 20 million years and are the ecological engineers who regenerate native bush.
Why are you allowing greedy profiteering companies to destroy our country and the planet. YOU NEED TO STOP THIS MINDLESS CORRUPTION BEFORE IT IS TOO LATE.
It is ludicrous to approve a project that depends on retaining, not fixing, weak clearing laws.
• 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;

Retaining vegetation is a crucial element in stabilising the impacts of climate change. This project depends on the removal of existing vegetation that will take decades to replace.

Burning undried biomass for fuel releases more greenhouse gases than burning coal. It’s a huge step backwards in our moves toward reversing global warming.

This is a cynical technology seeking profits under the guise of being a green solution. It is not a green solution by any metric.

In spite of the situation our extractive approach to the natural environment has led us into, we seem to continue to ramp up the rapacious consumption of natural resources.

We have a shamefully high rate of species extinction in this country and one of the main drivers of that is habitat destruction. This project depends on wide scale further loss of wildlife habitat in order to fuel an industry that emits more greenhouse gases than the industries it purports to improve upon.

The EIS fails to consider the greenhouse gas emissions from the clearing of vegetation required for this project. Nor does it identify the specific areas to be cleared or the wildlife affected by that clearing. Nor does it address the ongoing cumulative impact of the project over its anticipated lifespan.

It would be a gross derogation of responsibility for this project to be approved and, in my opinion, would directly harm every individual in NSW.

When are we going to face reality and start behaving responsibly in relation to the environment that we have already had such a devastating impact on in such a short time? This project ramps up those very impacts

This is a very well thought out project that will provide valuable power using renewable energy. Projects like these are desperately needed for Australia to reach their net zero emissions target.

It would increase emissions to higher levels than coal.
Native trees would be even more endangered.
Native animal species would also find themselves in more danger than they are now.
The regulation on what can and cannot be cut down to use as fuel are way too obscure and vague.

We support the timber industry and the use of any surplus or designated waste biomass in other productive ways. This seems a good use of the approx 2mill tonnes of residue biomass pa.

Forrest waste to make the biomass feedstock will help contain bush fires.