I object to this proposal because the proponent has not adequately assessed the likely and significant greenhouse gas (GHG) risks and impacts to NSW. They have not adequately described the scale and impact of recent emissions from the existing HVO facility. Their projected emissions for the proposal make a mockery of any statement or commitment they may make pertaining to mitigating or reducing GHG emissions. They have not attempted to credibly mitigate likely and significant economic, social or environmental costs and impacts of emissions. They have not demonstrated that they can effectively manage and minimise emissions either now or in the future. The projected emissions demonstrate that the proponent will breach the reformed federal Safeguard Mechanism and fail to support NSW Net Zero Plan or legislated emissions reduction targets.

The proposal represents continuing activities that are a leading cause of physical impacts and economic costs already observed and experienced in Australia and documented in recent State of the Environment, State of the Climate, and UN reports. The observed impacts have led the International Energy Agency to declare that there should be no new coal proposals. The Department should reject this proposal because the proponent has not offered any credible mitigation of likely and significant impacts, and has not adequately observed the principles of ecologically sustainable development. The likely impacts of the proposal are unacceptable and it is not in the public interest. The proposal directly conflicts with state and federal policy objectives, the federal Climate Change Act, and international commitments such as the Global Methane Pledge.

I attach my observations of the proponent's assessment to further explain why I am objecting to this Project.

See attached preliminary advice.
Council is working towards providing a detailed submission following a briefing by the Proponent on 7th March 2023. Council reserves its right to provide Councillors with adequate time for review of the proposal and the staff submission. It should be noted that amendments to council’s submission, or a subsequent submission, may occur as a result of this process.