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We ask you to make a submission and urge rejection of the proposal in favour of investment in sustainable net-zero energy generation. 

Why this matters

Verdant Earth Technologies proposes to restart the Redbank Power Station near Singleton to burn native vegetation for fuel. They will burn up to 700,000 tonnes of dry biomass annually, primarily from land clearing and potentially from native forests. This project threatens biodiversity, isn’t carbon neutral, and will ultimately undermine NSW’s climate and conservation goals. 

Native vegetation, primarily from land clearing, will provide the bulk of this in the first four years of operation. Alarmingly, loopholes for the use of native forests and cleared vegetation for power generation still exist and could be utilised by future governments to allow native forests to be burned. To fuel their project long term, Verdant proposes converting up to 72,000 hectares1 of land to produce biomass crops.  

Land clearing and associated habitat fragmentation is one of the biggest threats to biodiversity in NSW. 

This proposal will provide further financial incentives for land clearing, all to feed its furnaces for electricity generation. 

In short, a strong case for rejection exists. The project faces multiple critical risks; especially around biomass sourcing, policy compliance, and environmental integrity. These provide legitimate and evidence-based grounds for the IPC to refuse consent. 

How to stop the proposal

During initial public consultation on the project there were so many objections that the project has now been referred to the Independent Planning Commission for decision. The Commission will decide whether or not the project proceeds. The Commission makes their decision based on evidence presented in submissions and at public hearings. 

How to make a submission

Send your submission as an email, or attachment, to [email protected] 

Make it clear that you do not support the current Redbank Power Station Biomass proposal. 

Your submission should clearly describe why you do not support the project. 

There is no limit on words – you can write 100 words or 1000 words! But keep it polite, professional and convincing.

We've provided some key points for you to consider below. If you want to dive deeper - you can access the project information on Independent Planning Commission's website.

Concerns to talk about in your submission

Unacceptable environmental and biodiversity impacts

According to the Australia Institute the environmental impact statement for this project has vastly underplayed the greenhouse gas emissions and other potential environmental impacts that the project could have, not least what a large new customer for woodchips would mean for logging operations

The Fuel Supply and Characterisation Study - Restart of Redbank Power Station claims “It is proposed that Redbank will be fuelled with ecologically sustainable biomass”. The clearing and burning of tens of thousands of hectares of native vegetation cannot be described as ecologically sustainable. 

• The proposal relies heavily on the clearing of “Invasive Native Species” (INS), which is poorly regulated and overseen. ‘Invasive native species’ is a term that’s been used to let farmers clear abundant native vegetation on their property with little oversight, for the purposes of increasing agricultural productivity. 

• Land clearing and "INS” will provide 71% of fuel in the first year and 64% in the second year. Based on information provided by Verdant, at least 20,000 hectares of “INS” will need to be cleared to provide the required fuel levels during the projects first year.  

• The proposal seeks to exploit NSW land management rules that are unequivocally failing nature and that are currently under review by the Natural Resources Commission. 

• Providing a market for dead native vegetation will drive increases in land clearing. The demand creates the risk that “INS” is managed in an ecologically unsustainable way.  

• The Environmental Impact Statement (EIS) fails to assess off-site impacts – The EIS only considers impacts on the 18ha of land the power station sits on, ignoring the potential biodiversity impacts from the thousands of hectares of land clearing required off-site.  

• The project says they would establish biomass fuel crops to sustain the project long term. Verdent state ‘in order to meet the total required biomass demand, a total planted area of 72,000 hectares would be required’ and seeks to convert grasslands to crops. The project plan specifies it will target marginal agricultural lands. The project should only use degraded agricultural lands. It does not specify how native vegetation, like biodiverse grasslands, will be protected. 

• Land clearing and associated habitat fragmentation is already one of the greatest threats to biodiversity in NSW, threatening endangered species and ecosystems. 

Carbon accounting under-represents emissions from land clearing

• The claim of “near-net zero” emissions, due to the regrowth of feedstock, is not supported. Trees cleared for land clearing will not grow back, future growth and carbon storage is lost and other emissions from soils and processing are not counted.  

• Verdent claim that burning vegetation bulldozed from agricultural lands will have a neutral effect on greenhouse gas levels; this is false. Burning vegetation will release instantaneous bursts of carbon dioxide in the air. There is no plan to replace the woody vegetation that has been cleared – resulting in a net loss. Burning vegetation is very different to the slow carbon release that occurs when vegetation falls to the ground and rots slowly over time.  

• The emissions from biomass burning is compared to high emitting coal plants rather than wind and solar, significantly overestimating the emissions benefits. 

• The lifecycle analysis of the project shows that the release of ‘CFCs’ which contribute to ozone depletion are more than four times higher than burning coal. 

• True net-zero projects should be prioritised over projects that add increased carbon to the atmosphere.

Local impacts will worsen air quality and increase road traffic

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

• Burning biomass can have even more significant public health impacts than burning coal.  

• The proponent's plans for sourcing fuel assumes that 42 tonne capacity B-double trucks move to and from the power station 112 times PER DAY to haul the required biomass feedstock in and the resulting ash out. That is more than one truck in and out every half hour on average and equates to 20,238 trips per year. 

Future burning of native forests not ruled out 

• Although excluded from the current proposal, the loophole that allows the use of native forest trees for biomass energy production still exists. There is no guarantee that native forests won’t be allowed for use under future governments. 

The banning of any native vegetation for electricity is a commitment from the NSW Government 

• NSW Labor has had a longstanding commitment to close the loophole that allows the burning of any native vegetation for electricity “Labor recognises that burning timber an cleared vegetation for electricity is not carbon neutral and is neither clean or renewable energy” 

Better alternatives 

• To reach our renewable energy goals NSW should focus on high value cleaner energy solutions like solar and wind power.  

• While biomass energy may have potential in NSW in the future, further scoping is needed to determine the best opportunities in NSW that will not have unnecessary impacts on ecosystems and biodiversity.  

• In ‘Appendix L: Life Cycle Submission’ Verdent mention that ‘if biogenic carbon emissions are captured before being released to the atmosphere, e.g. through bioenergy with carbon capture and storage (BECCS) this could result in an overall greenhouse gas removal’ yet it is unclear from their proposal whether this technology will be used. For any biomass project – carbon capture should be a requirement.
   

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Doublespeak with a devastating impact – proposal to destroy and burn forest bad for nature and the climate (18 March 2024)