Restart of Redbank Power Station

I strongly object to the proposed re-opening of Redbank Power Station to burn biomass. This proposal is the antithesis to addressing the biodiversity and changing climate crises that we face.
The greatest ongoing threat to the loss of biodiversity is loss of habitat amid the consequences of global heating. The 300km radius circle about Redbank P.S. encompasses critical habitat for endangered species and crucial biodiversity corridors to enable adaptation to the changing climate over the next decades. There has been no actual environmental impact assessment of the consequences of this proposal. It should be rejected on this basis alone. The proposition that the assessment of the activity is adequately covered through land clearing compliance certificates issued by Local Land Services is unsustainable.
Part 5A of the Local Land Services Act 2013 contains the self-assessment loopholes largely responsible for habitat clearing tripling since 2016. The approval process requires no surveys to identify habitat of threatened species.
It is equally unsustainable to try to use the concept that the production of the energy in Redbank P.S. is a near net zero carbon emission project. The clearing and burning of so-called invasive native species does not result in carbon being captured; and it does not amount to net zero because it was going to be burnt anyway by the landholder! In fact, the burning of greenwood with a moisture content generates more emissions per megawatt hour of energy than coal.

The remnant native vegetation in this already overcleared region also plays an essential role in ecosystem function. Ecological sustainability in fact demands that we severely limit any clearing, including of so-called invasive native species. The remnant vegetation helps soil stability, provides cooling through shade and water retention through less evaporation, provides habitat and the biomass break down in situ over time includes supporting the invertebrate populations’ contribution to ecosystem stability.
The establishment of a market for burning biomass has absolutely no place in Australia. It is totally inappropriate to encourage land clearing. It is outrageous that the changed legislation in 2016 has already resulted in a threefold increase in clearing in NSW. Any economic incentive to clear land for bioenergy (sic) generation that would otherwise not be cleared is patently short sighted and clearly not in the public interest. The recent reviews of both the Federal and State environmental protection laws recognise that they are failing. Land management needs to carry the framework of reparation and restoration of ecosystems. The era of exploitation at any cost to the environment is coming to an end. The extreme weather events will become even more frequent and intense at even greater cost to the economy.
The Redbank Power Station proposal would add over 1.3 million tonnes of CO2 each year to the atmosphere. Investment in energy production should be directed towards wind and solar projects, not the burning of biomass.

I support this project to go ahead to support the need for infrastructure to maintain power/electricity to the communities due to the closing down of other power stations in the area

I strongly oppose the burning of forest biomass at Redbank Power Station, makes no environmental sense to keep destroying native forest and threatened species habitat.

I object to this proposal because it relies on land-clearing and suggests that burning the biomass is near net zero emissions, which I believe to be a fraudulent claim.
The proposal does not provide any transparency around the origins of the biomass, how it will be gathered and stockpiled, and takes no account of the emissions generated during this process.
These do not appear to be counted in the Scope 3 emissions, but as there is no methodology provided as to how the Scope 3 figure has been derived, who would know.
What we do know is that burning biomass generates more CO2 than coal for unit of energy generated, because significantly more biomass is needed, being a less carbon dense material.
Similarly, the proposal alludes to a range of biomass sources, each of which will have a different bulk density and will thus require a different number of trucks to transport a particular tonnage. Grass for example will be bulkier than hardwood woodchips. And yet the number of trucks delivering the biomass doesn’t vary.
The suggestion that it is economical to bring biomass from Cobar and the Western District is a joke..It would involve a truck journey of more than 6 hours one way. A return journey is too long to be done legally in a 24 hour period, suggesting that twice the number of trucks would be needed to keep up the daily supply.
With bales of hay selling for $100, how could the company possibly compete for crops that were purpose grown.
We know from the AFR article of April 9, that the creditors and lenders are knocking at Verdant’s door. With good reason. Many promises have been made about what will be delivered, but the details for implementation are thin on the ground.
This power station will generate more than 1m tonnes of CO2 emissions/year. Only a sleight of hand accounting trick could possibly suggest this is ‘net zero’
It will doubtless result in biodiversity loss and habitat fragmentation.
The employment figures provided are assertions, with no detail behind them.
What NSW needs is genuine renewable energy that doesn’t depend on hundreds of thousands of truck movements and more environmental degradation. Proposals like this don’t pass the pub test.

Verdant is proposing to reopen the Redbank Power Station to operate as a biomass power station using trees considered "waste" products from land clearing, thus wasting valuable timbers that could be used in composite building material production and emitting more greenhouse gas the the original coal. I object to the weak land clearing laws that allow mass clearing of rural land. I object to the use of trees for this purpose at a time when the preservation of habitat and eco systems that support our unique birds and animals is critically important. I object to the restart of an old power station using fossil fuels for energy at a time when 87% of the population wants to move to clean and sustainable energy. The NSW Government needs to analyse the gross level of emissions attributable to tree clearing over the life of the project and realise that there are better solutions, cleaner solutions to providing energy. The NSW Government also needs to rewrite the laws that allow landholders to clear forests and eco systems to laws that protect habitat systems, provide natural carbon sinks, and leave a sustainable healthy environment for Australia's beloved wildlife.

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.

I really can't believe that in 2024 this project is even being considered. It is truly ridiculous. Yet it seems like individuals such as myself, who frankly have better things to do with my time must state the obvious. No, it is not a good idea to destroy forests to fuel a power station!

I don't know how this project has even gotten this far to be up for such absurd consideration. Someone somewhere has no doubt gotten in the pocket of the relevant ministers and politicians to get this idea this far.

I am a born and bred NSW resident and I do not want our forests being burned for fuel. This is a totally antiquated and outdated suggestion from ye olden days.

To the government ministers and employees who have let this idea get this far, please do not approve this absurd proposal. Thank you.

We are in a climate crisis and must de-carbonise the economy immediately. Whichever way you cut it, burning carbon (plants) for electricity creates CO2 (and incidentally, CH4 and N2O which are many times more destructive). In fact, it’s worse than burning coal because it emits 50% more CO2 per MWh of energy produced than coal, due partly to higher moisture content.
The proposal is predicated upon the pretense that burning 850,000 (wet) tonnes of wood on site to generate electricity will result in no CO 2 emissions, whereas it will actually result in the release of some 1.3 million tonnes of CO2 each year. There will be additional emissions from debris and soils at the clearing sites, and from processing and transporting of woodchips.
Australia is one of the few countries that has not gone down the biomass burning path and we need to keep it that way! If you think about how long it takes to burn a tree and how long it took to grow that tree, you can easily see that this can never be sustainable!

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;

Dear Minister,
We are currently witnessing the profits of businesses take precedence over the sustainability of our planet. If we do not urgently start using ecology economics then we will be leaving future generations with a barren planet.
Reopening Redbank Power Station for Verdants biomass power station incentivises the decimation of native forests.
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;
We cannot continue down this path if we wish to create a sustainable planet.
There are better ways and we have solutions.
Please do not pass this project. Thank you.
Kind regards
Richard Jones

NSW already has an abysmal track record of unrestrained habitat clearing. Habitat clearing on freehold land is now the biggest cause of environmental loss in NSW.

This proposal will make the problem exponentially worse as Verdant want to burn 850 000 tonnes of habitat and woodchips per year – more than the entire native forest logging industry in NSW produces.

Here are some of the main points you can include in your submission:

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 have attached my submission as PDF attachment.

The EIS fails to indicate the fuel source species and the fuel source location, albeit to state that it is possibly within 300 or 400 kilometres of the Redbank site. Without this information the environmental impact cannot possibly be assessed.
This appears to be a deliberate obfuscation as the project would otherwise appear to be a deliberate incentive to further land clearing and environmental degradation.
It would also appear that the results of community consultation are in complete contradiction to being able to be resolved by further "community education and engagement".

The proposal seeks to exploit NSW land management rules that are unequivocally failing nature and that are currently under review. This project will result in more habitat being destroyed.

Renewable energy projects must be given priority if we are to make a substantial difference to our carbon emissions. This proposal is a distraction from real renewable energy projects. Burning cleared vegetation is not carbon neutral and the project would create a new source of greenhouse pollution.

Biomass has negative and unjust health impacts including releasing dangerous air pollution.

There is no assessment of the external loss and damage costs of the ACTUAL greenhouse gas emissions from this proposed project. The Australian government allows a CO2 emission factor of zero for burning biofuels, on the basis that the emissions would have been accounted for in the LULUCF sector. However, Verdant are not engaged in this sector and, in any case, this does not excuse the lack of accountability for loss and damages from the actual CO2 emissions. Moreover, were the actual projected CO2 emissions added to the other CO2-e emissions, both the NGER threshold of 25,000 tCO2-e/annum and EPBC Act referral threshold of 100,000 tCO2-e/annum would be exceeded. Please see the attached letters currently under review.

The proposal seeks to exploit NSW land management rules that are unequivocally failing nature and that are currently under review.

We are writing to express our opposition to the proposed restart of the Redbank Power Station in New South Wales (NSW) for energy production using waste wood residues. Our opposition stems from significant concerns about the environmental, ecological, and public health implications of such an initiative, especially considering the context of NSW's current environmental challenges.
1. Intensification of logging in NSW: NSW is recognized as a logging hotspot, with considerable areas of its native forests already subjected to extensive logging operations. These activities have placed immense pressure on biodiversity and ecological balance. The Independent review of the NSW Biodiversity Conservation Act confirmed that both logging and landclearing are major drivers of habitat loss, fragmentation, and damage. The State Government agrees that legislation to protect native vegetation must be strengthened. By creating a demand for wood residues as a fuel source, even with the exclusion of native forestry residues, there is an incentive for increased logging. This will further endanger the state's forested areas and increase extinction rates. The substantial volume of wood projected to be cleared in the first four years of the project (1,480,000 dry tons) warrants classification as a matter of National Environmental Significance, necessitating an assessment under the EPBC Act for its impact on federally listed species. This is especially pertinent considering the targeted areas currently span 112,530 hectares in the Central West Local Land Service area and 528,179.66 hectares in the Western Local Land Service Region.
2. Acceleration of land clearing rates: NSW has one of the highest rates of land clearing in Australia since in 2016 land clearing regulations were weakened. This is leading to increased habitat destruction, loss of biodiversity, and higher carbon emissions. In NSW, 95,000 ha, has been cleared annually (Statewide Land and Tree Study – SLATS) over the last four years. Most of the land is cleared without any government oversight.
The adoption of biomass energy production, relying in theory on waste wood residues, poses a risk of further accelerating land clearing. Landowners may be encouraged to clear land more aggressively under the guise of generating biomass fuel, exacerbating the already critical situation of habitat loss in NSW. The current legislation around land clearing already has demonstrated it is not fit for purpose, adding the extra pressure of clearing for biomass would exasperate the issue even further.
3. Contribution to greenhouse gas emissions: Biomass burning for energy, including from waste wood residues, is a significant source of carbon dioxide and other greenhouse gases. This mode of energy production undermines efforts to combat climate change and contradicts NSW's commitments to reducing its greenhouse gas emissions and transitioning to cleaner energy sources. Emissions from deforestation in Australia are among the highest in the world already (State of the Environment Report 2021).
It would be advisable for NSW to evaluate the total emissions linked to tree clearing (deforestation) throughout the project's duration, particularly emissions from clearing up to 2030. It's important to exercise caution regarding selective citations from the IPCC AR6 WGIII. The same document indicates that bioenergy can be carbon-neutral only if bioenergy crops are cultivated on pre-cleared land. Other pertinent sections from IPCC Working Groups III and II, highlight that the most effective mitigation strategy in the Agriculture, Forestry, and Other Land Use (AFOLU) sector is protection. For government planning, it's critical to acknowledge the urgency of preserving and restoring diverse, resilient natural carbon sinks to bolster natural ecosystems' role in keeping warming below 1.5 degrees and reducing the risk of carbon loss to the atmosphere as the likelihood of severe drought and catastrophic fire increases with climate change. Notably, risks of severe fires are heightened by disturbances from logging and clearing (www.bushfirefacts.org).
4. Threat to NSW's biodiversity and ecological integrity: NSW's native forests support a wide range of biodiversity, including threatened and endemic species. The indirect support for logging and land clearing from biomass energy production threatens these ecological communities, leading to irreversible biodiversity loss and ecosystem degradation. Additionally, the EIS's inability to adequately identify target areas and species for clearance, along with its failure to consider the cumulative impacts of extensive clearing throughout the project's duration, represents a significant flaw. Relying solely on the use of "biomass from invasive native species control on agricultural lands" – for which clearing certificates have been issued under the current, insufficient regulations – without evaluating the short, medium, and long-term effects of this new wood market on biodiversity, ecological connectivity, and overall landscape integrity, exposes the project to considerable risk.
5. Negative impact on air quality and public health: The pollutants released by the burning of biomass severely affects air quality, leading to increased public health risks. Communities near the Redbank Power Station would be particularly vulnerable to respiratory and cardiovascular diseases associated with air pollution, placing an unnecessary burden on NSW's public health system.
6. Diversion from truly renewable energy solutions: Focusing on biomass as an energy source diverts attention and resources from genuine renewable energy opportunities. NSW has the potential to be a leader in solar and wind power, which provide cleaner, more sustainable, and more efficient energy solutions without the environmental downsides of biomass energy production.

We strongly urge the NSW Government to deny the proposed restart of the Redbank Power Station using waste wood residues. We advocate a focus on genuine renewable energy sources that align with environmental conservation, climate action, and the protection of public health and biodiversity in NSW.

Dear Sir/Madam

I submit this objection in the strongest possible terms. The proposal by Verdant Earth Technologies Ltd. to restart Redbank Power Station by burning 850,000 tonnes of native forests obtained from landclearing begggars belief.

While the NSW Government has an obligation, under current legislation, to consider this proposal it cannot under any circumstances or conditions show such a degree of wilful blindness to give approval.

This ill-conceived proposal will require significant increases in the rate of landclearing, at a time when the overwhelming scientific as well as public consensus is that the unacceptable amount of land clearing must not only be stopped but the necessary resources must be directed towards repairing much of the damage which has already occurred.

The claim 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 complete distortion of the facts. 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 drastically reduce our emissions of CO2, not increase them as this proposal will undoubtedly do. 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 the climate crisis. 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 of our unique native forests are not in the public interest.

This proposal is an absolute anachronism. Surely 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.

It is long past the time to abandon the wilful ignorance shown to the profound disastrous effects of native forest destruction.

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

Sincerely
Gregory Gill

I have visited the Redbank Power Station on 3 occasions and Foster Stockbroking has helped raise capital for the project.
We strongly believe the proposal as outlined would be a major positive to the renewal energy space , create employment and be an improvement over leaving the project sitting idle as it is presently.

We agree that coal should not be used as an energy source but the proposal as w e understand it by using biomass as an energy source seems to be an excellent way to create power and be pro the environment