No to Burning Native Forests for Power

Dear Commissioners 
I am writing to make a submission in strong opposition to the proposal to restart Redbank Power Station  (SSD-56284960), which would involve burning up to 850,000 tonnes of native vegetation each year for electricity generation.
This proposal is not renewable energy. It is an industrial-scale deforestation project that will lock in rising emissions, destroy native habitat, and worsen both the biodiversity and climate crises in NSW.
The fuel source is native vegetation, not waste biomass.
The feedstock for this proposal would be sourced primarily from vegetation cleared under Invasive Native Species (INS) framework in western NSW. These are not weeds. They are native shrubs and trees that are critical habitat for many species, including threatened wildlife. The system permits their clearing is self-assessed, poorly regulated, and widely misused.
According to the available data:
<ul>
<li style="font-weight: 300;" aria-level="1">Around 145,000 hectares of native vegetation are approved for clearing each year under the INS provisions, but only 11% of that is actually cleared</li>
<li style="font-weight: 300;" aria-level="1">To meet Redbank’s demands, clearing rates would need to increase five to seven times current levels</li>
<li style="font-weight: 300;" aria-level="1">In 2021 alone, more than one third of all woody vegetation clearing in NSW was unexplained, meaning it was either unauthorised or unrecorded</li>
</ul>
I am seriously concerned that the claimed sources of the vegetation for the project are based on expired approvals, outdated mapping, or reliance on partnerships with companies that no longer exist. There has been no on-ground assessment of whether the necessary volume of native vegetation can be legally, economically or ecologically sourced.
The carbon accounting is fundamentally flawed. 
The Environmental Impact Statement (EIS) wrongly assumes that burning native vegetation is not emissions intensive, or at all net-neutral in terms of the carbon cycle, and does not reflect real-world outcomes. In reality:
<ul>
<li style="font-weight: 300;" aria-level="1"> Burning 850,000 tones of vegetation will release over 1.3 million tonnes of carbon dioxide annually</li>
<li style="font-weight: 300;" aria-level="1">Additional emissions will occur from the clearing process, soil disturbance, transport, and processing</li>
<li style="font-weight: 300;" aria-level="1">The vegetation being cleared will not regrow. These are permanent land use changes, and the lost carbon will stay in the atmosphere for decades</li>
</ul>
There has been no life cycle analysis of emissions from this proposal, and no accounting for the carbon stored in vegetation, soils, or habitat that would otherwise continue to function as a carbon sink.
No environmental assessment of the source areas. 
The EIS only considers the power station site itself. There is no biodiversity assessment of the landscapes where the vegetation will be cleared. This means the impacts on threatened species, ecological communities, connectivity, and local ecosystems have not been evaluated.
<ul>
<li style="font-weight: 300;" aria-level="1">Most of the vegetation clearing will occur on private land, outside any formal planning or development application process</li>
<li style="font-weight: 300;" aria-level="1">No surveys are required to identify threatened species or ecological values before clearing occurs</li>
<li style="font-weight: 300;" aria-level="1">The satellite processing facilities proposed for dying and chipping native vegetation have not been identified, assessed or approved</li>
</ul>
The risk of project expansion or variation is high. 
Although the proponents currently state that they will not use logging residues, the project is clearly designed to allow for future variation to include them. The proposal itself states that if other fuel sources prove uneconomic, they may seek approval for alternatives. Given the unreliable nature of the INS resource, it is likely this will occur.
This proposal will damage public trust and set a dangerous precedent. 
Creating a commercial market for burning native vegetation will incentivise deforestation and land clearing across NSW. It will increase pressure on ecosystems already in decline, particularly in the context of drought, land degradation, and invasive species. It also risks undermining genuine renewable energy by channelling public and private investment into high-emissions, low-efficiency technology.
This project must be assessed on the full environmental ecological and climate consequences of its operations - including what it takes to supply the fuel.
I ask the Commission to reject this proposal.
<ul>
<li style="font-weight: 300;" aria-level="1">Burning of native vegetation is not clean energy</li>
<li style="font-weight: 300;" aria-level="1">Logging residues must not be approved in the future as feedstock</li>
<li style="font-weight: 300;" aria-level="1">Environmental impacts must include clearing locations, not just the power station site</li>
<li style="font-weight: 300;" aria-level="1">Emissions must be properly accounted for and assessed under current climate goals.</li>
</ul>
This proposal is not in the public interest, it does not have a social licence, and it contradicts the urgent need to reduce emissions and protect what remains of NSW’s biodiversity.
Please reject SSD-56284960 and protect NSW from becoming the first jurisdiction in Australia to power its grid by clearing and burning native vegetation.

No to Burning Native Forests for Power

The Redbank Power Station in the Hunter Valley is the test case for an ecological disaster.

A company with links to the fossil fuel industry, Verdant Earth Technologies, has proposed to restart this disused coal power station by burning 850,000 tonnes of cleared native vegetation each year. They claim this is clean and renewable energy. The truth is, it is a dangerous step backward, and the NSW Labor Government is on the verge of letting it happen.

This is not green energy. It is another climate bomb that will accelerate the extinction crisis.

To supply Redbank, Verdant will rely overwhelmingly on vegetation cleared from private lands under Invasive Native Species authorisations. These authorisations do not require biodiversity surveys and have been widely abused to clear intact bushland. Many of the species they target are critical habitat for native wildlife, including threatened species found nowhere else.

The Government's own data shows:

145,000 hectares of native vegetation are approved for clearing each year

In 2021, over one third of all woody vegetation clearing had no legal explanation

Only 11 percent of approved INS clearing is currently acted upon, meaning the Redbank project would drive a five to seven fold increase in land clearing

The power station would emit over 1.3 million tonnes of carbon dioxide each year, not including emissions from soil disturbance, debris left on site, and the transport and processing of feedstock. This would significantly increase NSW's emissions footprint.

This project would:

Accelerate the destruction of critical habitat in one of the world’s 35 biodiversity hotspots

Create a perverse economic incentive to clear bushland

Avoid any environmental assessment of source areas

Risk project creep by opening the door to include logging residues in future

The Redbank proposal is based on false carbon accounting. It treats the release of millions of tonnes of carbon dioxide as zero emissions, simply because the fuel is technically of biological origin. But unlike regrowth, cleared vegetation has no carbon sink to offset the damage. Once those trees are gone, so is their carbon storage and habitat value.

This is not a climate solution. It is industrial scale deforestation for energy.

Submissions close 5.00pm Monday 18 August.

Make your voice heard. Object to SSD-56284960 and tell the Independent Planning Commission this proposal must be rejected.

No to Burning Native Forests for Power

No to Burning Native Forests for Power

DEATHS IN CUSTODY CRISIS

DEATHS IN CUSTODY CRISIS

END ABORIGINAL DEATHS IN CUSTODY NOW

END ABORIGINAL DEATHS IN CUSTODY NOW

MORE CAMPAIGNS

Native Forest Logging's Time Is Up

Native Forest Logging's Time Is Up

Protect Peaceful Protest

Protect Peaceful Protest

Support the Cat Containment Bill

Support the Cat Containment Bill

We demand stronger climate action and real climate leadership!

We demand stronger climate action and real climate leadership!

Native forests are not offsets, stop the carbon credit con

Native forests are not offsets, stop the carbon credit con

Repeal the Draconian Youth Bail Laws

Repeal the Draconian Youth Bail Laws