Restart of Redbank Power Station

1. 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;
2. 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;
3. 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;
4. 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.

Burning biomass is not carbon neutral, particularly if it is from the deforestration of land for farming.
Burning biomass is polluting, creating not only the release of Carbon Dioxide but also the release of particulate matter and many other chemicals. It is more polluting than burning coal.
Burning biomass from forestry operations will create a market for "waste" which will lead to more deforestration. Deforestration is already a problem in NSW.
Burning biomass will not contribute to the de-carbonisation we need to undertake to lessen the dangers of global warming. It is not renewable and it distracts from the cheaper and more viable options of solar and wind energy that already exist and are proven.
Creating a biomass burning powerstation will send the wrong economic signals to market players as to what actions are acceptable into the future. This is the fundamental problem with this proposal.

Regards,

Dr. Peter Sobey

I strongly object to the Verdant Earth Technologies (Verdant) proposal to re-open the Redbank Power Station (near Singleton, NSW) to operate as a biomass power station, using trees cleared on farms under woefully weak land clearing laws.

Despite putting an end to this project’s threat to native forests at the end of 2022, Verdant has honed in on weak tree clearing laws in NSW to find an alternative source of fuel. 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.

I am totally opposed to the proposal to generate electicity from biuomass at Redbank.
To supply the biomass plant will require hundreds of thousands of tons of native vegetation each year. Australia is in a biodiversity crisis with landclearing one of the major causes.Landclearing increased dramatically since the repeal of the NSW Native Vegetation Act and is currently out of control. This project if approved will become a driver for even more landclearing by providing government subsidised financial incentive for landholders to clear areas that would otherwise be left standing. The impact will be particularly high in the Upper Hunter in a region already considerably overcleared. I understand that power generated by biomass generates more carbon dioxide per unit energy than coal. When loss of native vegetation is included as well as loss of soil carbon from clearing and the emissions from transporting this low value material to the biomass plant it can hardly be considered carbon neutral.We need to reduce co2 pollution and this project will see it dramtically increase. For the sake of our dwindling biodiversity and the need to genuinely reduce our CO2 emissions I urge you to once and for all finally reject this proposal in its entirity.
Yours Sincerely James Morrison

I find it hard to understand any support for this proposal which will lead to further clearing of native trees, the loss of habitat for animals and birds, and an increase in greenhouse gases.
Australia has a lamentable record in terms of the loss of native trees and the highest number of wildlife extinctions in the world. This proposal certainly requires assessment under the Environment Protection and Biodiversity Conservation Act 1999 for its impacts on federally listed threatened species.
The increase in greenhouse gases from the clearing and the biomass burning must also be calculated.
This is a cynical and money focused proposal with no interest in the environment or the future.





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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;

Reviving the Redbank Power Station with biomass energy offers a pathway to a sustainable future by:
1. Cutting CO2 emissions, combatting climate change.
2. Boosting renewable energy use, ensuring energy security.
3. Creating jobs and stimulating the economy.
4. Protecting ecosystems by responsibly sourcing biomass.
5. Meeting renewable energy targets, driving progress.

In essence, this initiative aligns environmental, economic, and social goals, charting a course toward a cleaner, more resilient future.

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 vegetatio

This project will cause devastation of wildlife habitat. An enormous number of trees will be cleared from the area. There doesn't seem to be any requirement for this destruction to be approved by someone, which rings alarm bells for me. We are already damaging too much of our environment, and killing off too much of our wildlife. We ought to be doing less of that, and I recommend starting with cancelling this project.

This project will create a new market for wildlife habitat destruction and incentivise native tree clearing. It will encourage land clearing and emit more greenhouse gas than the coal which once burned there.
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 last thing NSW needs is another major driver of forest clearing, habitat loss and greenhouse gas emissions.

I find this proposal absurd:
at a time when we should be doing everything possible to reduce our emissions, here we have a project that will burn Biomass, a process that will emit more greenhouse gases per unit of energy than coal. Biomass burning is not GREEN
Added to this:
The project encourages the clearing of native vegetation, which destroys habitat and prevents desperately needed ecological recovery;
• 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;

Please, we need clean sustainable energy generating projects that move us forward in our quest t provide a safe future for our children! This project really is a backward, destructive move that needs to be shut down
Thank you

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;

“Tell ‘em they’re dreaming”

The words “Dept of Planning” implies a consideration for the future; a consideration for the lives our children and their descendants will live ( never mind the millions of other species threatened by decisions made today)

Burning biomass to make electricity has been shown (scientifically!) to be not:

Renewable: Something that takes 30 to 40 years to replace is not renewable..classifying it as such is cynical and convenient and NOT scientific nor is it considerate of future generations.

The sources of biomass proposed in Verdant’s revised EIS are so amorphous and loop-holey e.g. no limits to amount of sawmill “waste” they can use; this will of course mean that more and more trees get logged just for fuel…..it always comes down to this. The "native invasive species" are not specified.

Clean: Burning biomass to generate electricity has been shown to be worse for emissions than burning coal. 50% worse in fact. We can’t afford to let that amount of extra CO2 into the atmosphere. And once again (according to the EIS) Verdant are being very cynical, convenient and Spin doctoring about this – they claim that this extra atmospheric CO2 is absorbed by the regrowing of trees, but fail to mention that they will then be logged to be burnt again..the carbon is not sequestered permanently

Green: It is sooo not Green… All those truck trips..56 a day from an increasingly widening catchment area- Not Green
“Native invasive species” clearing for what? Ultimately more pasture and more emissions?-Not Green
All those extra emissions from the production? When it has been shown that keeping vegetation; especially forests is one of the most efficient ways to combat climate change....Not Green.
They are kidding themselves but hopefully not you people at Planning.
A State Significant Development?? I don't think so. What are they really after?? a place for their hydrogen fuel projects??
I could go on.

The Dept of Planning knows all this. Current thinking (both political and economic) needs to be mostly ignored in favour of the bleeding obvious environmental crisis that we are at the start of.
And who better to start the nudging than you people at Planning?

Please...be real...be brave...be scientific.
Thank you.


Jane Watson
11 Padmans Rd
Elands
NSW 2429

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;

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.
This same problem occurs with Biomass energy plant attached to Suger Cane factories in NSW. They initially start just to process the bagas ( Sugar cane waste) but then come under pressure to extend their operations by burning all sorts of other fuels.
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.
For these reasons, I submit that the project should be rejected.

Submission opposing the Redbank Power station DA

The National Trust Far South Coast Branch wishes to make a submission opposing the DA to recommence the Redbank Power station using biomass as the fuel.
This project and others like it being developed at present would undermine the objective of reducing Australia’s actual CO2 emissions, as biomass generates approximately 50% more CO2 than coal per thermal unit produced. Standing forests are also the most effective means of capturing and storing CO2 already in the atmosphere. This development would also be a catastrophe for biodiversity, as many of Australia’s aborial mammals are already facing an extinction crisis. Such projects are only financially viable because Forestry NSW significantly subsidises the native forest logs it supplies, making a substantial loss on their native forest operations, (Perkins and Macintosh, 2013, “Logging or Carbon Credits?”, http://www.tai.org.au/content/logging-or-carbon-credits).
Biomass is not a green or sustainable source of power. Native forests take at least 30 to 50 years to regenerate after logging, while wind and sun are instantly renewable. Logging also increases vulnerability to bushfires, further increasing these recovery times.

This project will not reduce greenhouse gas emissions in the electricity sector. While current international and national GHG accounting rules measure emissions from burning wood biomass as zero, its combustion actually produces 50% more CO2 than coal. Research we undertook in South East NSW found that logging native forests to produce 2 million tonnes of woodchips, double Redbank’s planned consumption, would generate 2 million tonnes of additional CO2 per annum compared to leaving the forest unlogged, (Perkins and Macintosh, 2013, “Logging or Carbon Credits?”, http://www.tai.org.au/content/logging-or-carbon-credits).
Redbank’s planned biomass fuel is not ecologically sustainable because it will largely occur under one of ten controversial Regional Forestry Agreements, which are still exempt from the Environmental Protection and Biodiversity Conservation, EPBC Act. The NSW Environmental Defenders Office recently argued the case before the Federal Court that when the North East Regional Forestry Agreement was renewed in 2018, the Commonwealth Government did not properly consult with the community nor have regard to the impact of logging on endangered species, the state of old growth forests or climate change (Environmental Defenders Office, website, 2022 ). If successful, this case has legal implications for all of Australia’s ten regional forestry agreements.

Several Australian coal fired generators are already substituting wood, possibly including native forest biomass, for coal. For example, Delta Electricity is co-firing at Vales Point Power Station with wood, as is Quinbrook Infrastructure at Cape Byron Power Plant. Stanwell Corporation is proposing to convert its coal-fired power stations in Queensland to woody biomass: "The use of wood pellets will be explored as part of Stanwell’s broader study into bioenergy options for co-firing at its power stations." There are several other proposals to convert large coal-fired power stations to woody biomass.
Verdant Earth the owners of Redbank Power Station in the Hunter Valley is the most high profile of these companies. It is proposing to burn more than 1 million tonnes of native forest wood per year, supplied by Forestry NSW from public native forests.
The CEO of Alinta Energy recently confirmed that his company is also considering converting its Loy Yang B power plant in Victoria from coal to wood biomass. Apart from Verdant, it is unclear how many of these generators propose using native forest biomass as a substitute for coal, but native forest biomass is by far the largest and cheapest source of wood biomass in Australia, and the current policy settings are encouraging this shift. As mentioned above, a major factor likely to encourage the burning of native forest biomass is that these native forest logs are supplied to the timber, firewood and biomass burning industries at heavily subsidised stumpage rates, at a significant cost to taxpayers, (Perkins and MacIntosh, 2013).
With world coal prices rising and international woodchip prices falling, driving the Australian export woodchip industry’s long term decline, native forest biomass burning for electricity generation is becoming increasingly attractive to the electricity generation and native forest logging industries. This is particularly the case as the electricity turbines, power plants and connections to the grid are already in place in power plants transitioning out of coal. Switching fuels is significantly cheaper than building biomass electricity generation plants from scratch.
Standing living forests are by far the cheapest and most widely available method of drawing down CO2 already in the atmosphere. Hence encouraging more logging, by encouraging native forest biomass burning as is already happening in Europe, would have a doubly negative impact on our actual CO2 emissions.
The shift in the relative prices of coal and wood biomass which seem to be the cause of these recent announcements by generators considering co-firing with wood biomass, indicate there is a very real chance that the native forest wood bioenergy industry will take off at a large scale in Australia as it has in Europe, leading to devastating environmental consequences. This is a very dangerous development.
Hence the National Trust believes this proposed must be rejected. Otherwise, we could see a rapid shift from coal to biomass burning for electricity generation in Australia, spurring a growth in our true emission levels and destroying biodiversity in the forests.

Yours sincerely,



Dr Frances Perkins
Chairperson Far South Coast Branch of the National Trust (NSW)
PO Box 352
Bermagui 2546
0423780498

I have outlined my comments in the attached document.

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 strongly oppose this project for two main reasons:
1. Burning tress will produce too much greenhouse gases which will add to long term climate change. We need to be producing less CO2 not more.
2. Clearing land of trees is bad for the environment and endangered species. We should be discouraging land clearing not rewarding land holders for clearing their land. Endangered birds such as Regent Honeyeaters need large areas of trees to survive. The Hunter Valley and surrounding bushland is one of the last areas that they are surviving. Clearing trees will make it more difficult for them and other endangered species to survive let alone thrive.
I strongly recommend not approving this project.

Thank You
Dan Vickers