Restart of Redbank Power Station

5466

19/08/2025

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Email

Hello I wish to send my strongest opposition to the above project. Here are my reasons: 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. Kind regards Katherine McDermott

5471

19/08/2025

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For starters a power plant that uses mass fossil fuels in transporting the reusasble bush is not the solution to a sustainable power source.

5481

19/08/2025

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Please consider climate change which is causing floods and fires. There is no need for polluting power stations when we have natural wind, solar and water sources of power. Burning native forest for power is causing these climate catastrophes, as well as polluting the air. We need our native forests for air quality, habitat for our dwindling wildlife and for our own sanity and safety. Yours sincerely Vivienne Duncan

5486

Fenner School of Environment and Society

19/08/2025

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Dear Commissioners, Please find attached my submission in relation to the proposed restart of the Redbank Power Station. As a statistician and ecologist, I have examined the project’s stated energy generation claims and fuel assumptions. My analysis indicates a significant discrepancy in the expected energy output relative to the fuel volumes disclosed. I also raise concerns about the ecological implications of large-scale biomass harvesting, even from regrowth vegetation. I would be pleased to provide further comment or clarification if needed. Kind regards, Maldwyn (John) Evans Dr. Maldwyn John Evans Senior Research Fellow Fenner School of Environment and Society ANU College of Systems & Society The Australian National University

Dr. Maldwyn John Evans Redbank Power Station Proposal - Submission_Redacted.pdf (PDF, 177.04 KB)

5756

Redacted

18/08/2025

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Dear Commissioners I can't believe after decades of scientific warnings about climate change that anyone is seriously considering cutting down native forests to burn in power stations. I would try to imagine a worse idea, but sadly it might be taken as a suggestion. Please don't do this, it is a terrible idea, invest in renewable energy, energy efficiency and batteries. Please. 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: • 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 • To meet Redbank’s demands, clearing rates would need to increase five to seven times current levels • In 2021 alone, more than one third of all woody vegetation clearing in NSW was unexplained, meaning it was either unauthorised or unrecorded 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: • Burning 850,000 tones of vegetation will release over 1.3 million tonnes of carbon dioxide annually • Additional emissions will occur from the clearing process, soil disturbance, transport, and processing • The vegetation being cleared will not regrow. These are permanent land use changes, and the lost carbon will stay in the atmosphere for decades 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. • Most of the vegetation clearing will occur on private land, outside any formal planning or development application process • No surveys are required to identify threatened species or ecological values before clearing occurs • The satellite processing facilities proposed for dying and chipping native vegetation have not been identified, assessed or approved 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. • Burning of native vegetation is not clean energy • Logging residues must not be approved in the future as feedstock • Environmental impacts must include clearing locations, not just the power station site • Emissions must be properly accounted for and assessed under current climate goals. 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.

5761

Redacted

18/08/2025

Object

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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 proposal seems flawed in at least some of its assumptions, justifications and messaging. 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: • 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 • To meet Redbank’s demands, clearing rates would need to increase five to seven times current levels • In 2021 alone, more than one third of all woody vegetation clearing in NSW was unexplained, meaning it was either unauthorised or unrecorded 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: • Burning 850,000 tones of vegetation will release over 1.3 million tonnes of carbon dioxide annually • Additional emissions will occur from the clearing process, soil disturbance, transport, and processing • The vegetation being cleared will not regrow. These are permanent land use changes, and the lost carbon will stay in the atmosphere for decades 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. • Most of the vegetation clearing will occur on private land, outside any formal planning or development application process • No surveys are required to identify threatened species or ecological values before clearing occurs • The satellite processing facilities proposed for dying and chipping native vegetation have not been identified, assessed or approved 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. • Burning of native vegetation is not clean energy • Logging residues must not be approved in the future as feedstock • Environmental impacts must include clearing locations, not just the power station site • Emissions must be properly accounted for and assessed under current climate goals. 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.

5766

18/08/2025

Object

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The attached submission was received by the Commission between 08/08/2025 and 18/08/2025 from 436 people.

Campaign Now submission.pdf (PDF, 176.92 KB)

5461

New South Wales 2786

18/08/2025

Object

Email

To whom it may concern, RE: Redbank Biomass Electricity proposal I would like to express my opposition to, and great concern about the Redbank biomass electricity project, a proposal to convert Redbank power station in Singleton to one designed to burn biomass, for several reasons: • Land clearing in NSW has already degraded the natural environment, and pushed many birds and animals to the brink of extinction. This proposal encourages more land clearing, and gives the false impression to land holders and the public that land clearing is an environmental positive. • the notion of ‘invasive native vegetation’ is a misnomer. It is dependent on the definition of ‘invasive’, who is making the assessment , and what financial advantage is given by labelling plants as ‘invasive’, as ‘scrub’ or of ‘no use’. This proposal risks more habitat loss and loss of valuable plant diversity. • the proposal for plantations of quick growing vegetation for fuel is a misuse of land - it need to be cleared first. As any crop, success would be dependent on adequate rainfall in a drying climate and absence of bushfires. A better use of land would be the considered, diverse and permanent planting for habitat renewal. • The argument that biomass-fuelled power has less greenhouse emissions compared to the previous coal-fuelled power - in a given time period - would only be because green waste is a less dense source of carbon. Carbon dioxide is still emitted. The idea of the need of a ‘transitional’ form of carbon- based energy is an appealing argument only to delay investment and establishment of real and sustainable renewables. • The proposal is dependant on the applicant following its own environmental guidelines , and following the approval conditions. Redbank will always have a conflict of interest - the business imperative would always be to ignore any restrictions on its primary resource of plant material. • The proposal depends on the continued oversight and checking by the EPA which requires continual inspections over an huge area, and vigilance of the public to trigger alarms over any non-compliance. This is always is a long bureaucratic process, and occurs long after the damage has been done to the environment. In conclusion, this is a flimsy and dangerous application. The risk of environmental damage and habitat loss is too great. I urge you to reject it. Yours sincerely, Mandy Burgess

5156

New South Wales

18/08/2025

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Good morning I am writing in opposition to this proposal. My objections are as follows. Environmental and biodiversity impacts The proposal to burn up to 700,000 tonnes of dry biomass annually, primarily from land clearing and potentially from native forests, will threaten biodiversity. The proposal is not carbon neutral and will ultimately undermine the NSW government’s climate and conservation goals. The Australia Institute has advised that the environmental impact statement (EIS) for this proposal has vastly underestimated the greenhouse gas emissions and other potential environmental impacts that the project could have. The proposal will have unacceptable environmental and biodiversity impacts. The Fuel Supply and Characterisation Study - Restart of Redbank Power Station - claims that: '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) that is poorly regulated and overseen. ‘Invasive native species’ is a term that has been used to allow farmers to clear native vegetation on their properties with little oversight, for the purpose 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 the proponent, Verdant Earth Technologies, at least 20,000 hectares of ‘INS' will need to be cleared to provide the required fuel levels during the project's 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. The demand creates the risk that 'INS' is managed in an ecologically unsustainable way. By providing a market for dead native vegetation, it will drive increases in land clearing. The EIS fails to assess off-site impacts. It considers only impacts on the 18ha of land that the power station sits on, ignoring the potential biodiversity impacts on the thousands of hectares of land clearing required off-site. The proposal aims to establish biomass fuel crops to sustain the project long term. Verdant Earth Technologies’ proposal states: ‘in order to meet the total required biomass demand, a total planted area of 72,000 hectares would be required’. The proposal seeks to convert grasslands to crops and the project plan specifies it will target marginal 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. Emissions from land clearing are under-represented 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. Verdant Earth Technologies claims 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 breaks down slowly over time. The emissions from biomass burning are 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. Such an increase in heavy traffic is completely unacceptable. 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 to be used in this project under future governments. The banning of any native vegetation to be used 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 to produce electricity. Labor has stated its recognisition that burning timber and cleared vegetation for electricity is not carbon neutral and is neither clean nor renewable energy. Better alternatives There are much better alternatives to this proposal that will enable NSW to reach its renewable energy goals. The NSW government needs to focus on high value, cleaner energy solutions like solar and wind power. While biomass energy may have potential in NSW in the future, much further research is needed to determine the best opportunities in NSW that will not have highly negative impacts on ecosystems and biodiversity, as this proposal does. Thank you Dr Caroline Cosgrove Historian Member, Professional Historians Association NSW & ACT

5161

18/08/2025

Object

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Dear Planning Panel Regarding: Proposal to restart RedbankPower Station using so-called biomass I am very concerned about the proposal to feed trees - our remaining forests - into the Redbank Power station, and strongly object to the proposal. We are in the midst of climate and extinction crises for which we need healthy and functioning forests. The overriding imperative must be to stop degrading forests and rehabilitating them to restore their natural resilience and allow them to mitigate the worst impacts of climate heating by sequestering our CO2 from the atmosphere and storing it out of harm’s way in their wood and soils. We urgently need to stop logging the homes of threatened species if there is a genuine intent to save them from extinction. I make the following points: 1. The proposal to feed 850,000 tonnes of trees per year into Redbank is gobsmacking, to say the least. It would seem that the intent is to obtain most of the trees through ramping up land clearing, which is the biggest single threat to biodiversity. 2. The proposal will incentivise logging and land clearing to meet the insatiable demands of burning them for power. 3. The burning of these trees will result in CO2 emissions of some 1.3 million tonnes of CO2 per annum, and total emissions twice that. This is contrary to NSW Government policy and I cannot believe the NSW Government has approved the project. 4. The logging of public native forests is unsustainable because it prioritises inflated timber yields above ecological needs and driving species to extinction, is depleting essential resources provided by old trees, is degrading forests, spreading weeds, causing ecosystem collapse, increasing fire risk, degrading soils, reducing streamflows and polluting waters. 5. Our forests have significant environmental and cultural values, including providing some of the last refuges for threatened species, which far outweighs the value in logging and degrading them further. Please do not approve this proposal. Yours sincerely Natalie Meyer

5166

for Byron Environment Centre

New South Wales 2481

18/08/2025

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We strongly oppose the Redbank Power Station Biomass proposal in favour of investment in sustainable net-zero energy generation. Verdant Earth Technologies' plan to reactivate the Redbank Power Station close to Singleton would involve incinerating as much as 700,000 tonnes of dry biomass each year, largely sourced from the clearing of native vegetation and possibly from native forests. This initiative poses a huge risk to biodiversity, is not carbon neutral, and will ultimately compromise New South Wales’s climate and conservation objectives. Native vegetation, primarily from land clearing, would provide the bulk of this in the first four years of operation. Native vegetation is not invasive, it occurs in naturally forming ecosystems that prevent soil erosion & provide essential habitats & food sources for native fauna. Land clearing is occurring at an alarming rate across NSW, which is threatening the survival of native animal & bird species, many of which are now listed as threatened & endangered. There are currently over 2,000 species of native animals threatened in Australia. Australia has the highest rate of mammal extinctions in the world. Habitat loss from agricultural clearing & the resultant fragmentation is a major driver of this extinction crisis. Providing a market for cleared vegetation will drive increased & unsustainable land clearing which will be devastating for our wildlife. The fact that there are still loopholes for using native forests and cleared vegetation for electricity generation raises great concerns since they could be exploited by future governments to permit the burning of native forests. Verdant proposes converting up to 72,000 hectares of land to produce biomass crops to fuel their project long-term seeking to convert grasslands to crops and specifies it will target marginal agricultural lands whereas the project should only use degraded agricultural lands. How native vegetation, like biodiverse grasslands, will be protected is not specified. The Environmental Impact Statement also fails to assess off-site impacts as it only considers impacts on the 18ha of land the power station sits on and ignores the potential biodiversity impacts from the thousands of hectares of land clearing required off-site. The assertion of "near-net zero" emissions due to the regrowth of feedstock lacks evidence. Trees that are removed for land clearing will not regenerate, leading to a loss of future growth and carbon storage, while other emissions from soil and processing are overlooked. Verdents statement that burning vegetation cleared from agricultural lands will have a neutral impact on greenhouse gas emissions is incorrect, as the act of burning releases immediate spikes of carbon dioxide into the atmosphere. They have not suggested a plan to replant the woody vegetation that will be removed, resulting in a net deficit. The process of burning vegetation differs significantly from the gradual carbon release that occurs when vegetation decomposes slowly on the ground. The emissions resulting from biomass combustion are compared to those from high-emission coal plants instead of wind and solar energy, leading to an inflated perception of the emissions advantages. The lifecycle assessment of the initiative indicates that the emission of CFCs, which are linked to ozone layer depletion, is over four times greater than that from coal combustion. Furthermore, the advocate's strategy for obtaining fuel presupposes that 42-tonne capacity B-double trucks will travel to and from the power station 112 times daily to transport the necessary biomass feedstock in and dispose of the resultant ash. This amounts to over one truck entering and exiting every half hour on average, which totals 20,238 trips annually. The NSW Labor Party has consistently pledged to eliminate the loophole permitting the incineration of native vegetation for electricity generation and acknowledges that the combustion of timber and cleared vegetation for power is not carbon neutral and cannot be considered clean or renewable energy. Priority must be given to true net-zero initiatives over those projects that contribute additional carbon to the atmosphere. For all of the reasons outlined above, we request that you reject the Redbank Biomass Powerplant proposal. Renee Engl for Byron Environment Centre

5171

18/08/2025

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I wish to express my opposition to the Redbank proposal because I believe this, although touted as an environmentally friendly way of using "waste" products from logging, will in fact lead to prolonging and extending clearing of native vegetation. As a volunteer bushcarer for the past 30 years, aiming to restore our valuable biodiversity in various sites across Sydney, I am upset at my work being reversed in another part of the state. This is not "ecologically sustainable" - it involves clearing and burning of tens of thousands of hectares of native vegetation. 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. Further, the project is a dodgy accounting exercise in carbon accounting. At a time that we need to make REAL cuts in our carbon emissions, both to have a chance of a liveable world and to meet NSW legislated emissions reduction targets, we cannot be distracted by highly questionable attempts to paint this project as "renewable energy". As the Nature Conservation Council says, 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. Thank you for the opportunity to comment. Angela Michaelis

5176

New South Wales 2450

18/08/2025

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Dear Sir/Madam, I am making a submission to oppose the re-opening of the Redbank Power Station (SSD-5628-4960. The NSW Government promised to introduce legislation (an election promise) prohibiting the burning of any forests and cleared vegetation for electricity and has long recognised that burning timber and cleared vegetation for electricity is not carbon neutral, nor is it clean or renewable energy. The Federal Labor Government promised in 2022 and when elected soon after ruled out the use of native forest wood as a source of renewable energy under the Renewable Energy Act. Australia is committed internationally to reverse forest loss and land degradation and reverse the extinction of native wildlife by 2030. Invasive Native Species is the result of sheep and goat farming, trees that are cleared to retain pastures regenerate in the absence of clearing. Australia has the worst reputation in the World for our Native Wildlife decimation. Woodland Forests are necessary for healthy native plants, wildlife and birds, they all contribute to healthy Forests. If land clearing laws are not reversed native plants, wildlife and birds will all be extinct in the not too distant future. The next generation of humans will not thank the NSW Government for this atrocity. Jobs can be created protecting Woodland Forests, tourism is a huge contribution to the economy. The NSW Government has not provided a landscape assessment of the biodiversity impacts of tree clearing that will supply the Redbank Power Station or no requirement to reveal the CO2 emissions from projects associated from biomass burning and clearing. Clearly, climate change will only accelerate if land tree clearing laws are not reversed as a matter of urgency. Sincerely, Rhonda Green,

5181

18/08/2025

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Submission in response to a development application for the conversion and restart of the Redbank Power Station to generate energy from biomass Biomass as a renewable energy source Biomass and fossil fuels are fundamentally different in that burning fossil fuels releases carbon that has been locked up in the ground for millions of years whereas biomass carbon was recently removed from the atmosphere during plant growth. Utilising sustainably grown biomass, and biomass residues that would otherwise be burned or decompose in the field, does not contribute extra CO2 to the atmosphere. To ensure balanced greenhouse gas accounting, reflecting that biomass is part of the short carbon cycle, the carbon uptake during plant growth must be included when assessing climate impacts of bioenergy. (Cowie et al., 2021) Strategically-utilised bioenergy is an important contributor to climate change mitigation. In the Intergovernmental Panel on Climate Change Sixth Assessment Report all of the scenarios that meet the temperature goal of the Paris Agreement include a substantial fraction of bioenergy in the energy mix, while emphasising the need for strong regulation to ensure sustainability of bioenergy. The IPCC’s modelling anticipates bioenergy use to rise from 30 Exajoules (EJ) currently to between 75 and 248 EJ by 2050 (IPCC, 2022). In the International Energy Agency’s Net Zero Energy roadmap, 5% of electricity production comes from bioenergy, important source of low-emissions flexibility to complement variable generation from solar PV and wind, while the majority of bioenergy use is in industrial heat and liquid transport fuels (IEA, 2021). Role of bioenergy in supporting clean electricity transition Coal still supplies more than one third of NSW electricity (DCCEEW, 2024). Meeting the NSW emissions reduction targets will require continued rapid expansion of wind and solar, which hindered by a range of challenges. Biomass use for electricity generation can support expansion of intermittent renewables, to accelerate decarbonization. Specifically, biomass can play a key role towards a 100% renewable grid by firming up power to the grid. Li et al (2022, 2024) demonstrated that biomass is highly competitive against other (non-fossil) dispatchable options. Cape Byron Power provides an example of an effective strategy: when there is plentiful solar and wind generation, the power station provides behind the meter power to the adjacent sugar mill. When solar and wind power generation is limited, electricity generated from biomass is sent to the grid. GHG reporting for bioenergy in the NSW GHG inventory The treatment of bioenergy in national GHG inventory reporting (and applied in the NSW inventory) is sometimes described as “assuming carbon neutrality”, because CO2 emissions from bioenergy are reported as zero in the energy sector. This may appear to be an inaccurate simplification, however, this approach is necessary to avoid double counting, because all carbon emissions associated with forest harvest are already counted in the “Land use, land-use change and forestry” (LULUCF) sector. Fossil CO2 emissions from biomass production and bioenergy facilities are included in energy sector emissions in the NSW GHG inventory. (Cowie et al., 2021) Biomass production as a sustainable land use Removal of thinned stems and residues from plantations, as practiced under sustainable forest management, rejuvenates the forest system, sustains tree growth and carbon uptake from the atmosphere, improves forest health and reduces risks of wildfires and other natural disturbances. Invasive native scrub is regularly removed to restore native grasses and open woodland, preventing environmental degradation through woody thickening that reduces habitat diversity (NSW LLS, 2014). INS is currently burned or decomposes in the field. Utilisation of forestry and INS residues for bioenergy is a beneficial use of these biomass resources. Rehabilitation of Hunter Valley mine sites is particularly challenging due to poor quality topsoil and low rainfall. Establishment of native hardwood plantations, in conjunction with use of recycled organics, is an effective means of mine site rehabilitation, stabilising the site, increasing fertility and soil OM, and reducing erosion in nutrient-poor overburden, while returning the site to sustainable land use, as required under NSW legislation (Kelly, 2008). Establishment of perennial grasses or short-rotation woody crops for biomass production for bioenergy is a viable and productive land use for mine site rehabilitation. Similarly, short-rotation woody crops can be integrated with agricultural systems, on low productivity sites, providing carbon sequestration, soil stabilisation, increased biodiversity and income to landholders. A range of native tree species have been trialled across NSW, including in the Hunter Valley. These trials have demonstrated promising growth, and will identify the most productive species under coppice management (NSW DPIRD, 2024). Beneficial use of end-of-life wood products Use of end-of-life wood products for bioenergy is promoted in Europe, through “cascading” policies – that is, using wood first for material applications then for energy at end of service life. Cascading is consistent with European and NSW circular economy objectives. Measures for managing quality control – for example to ensure CCA-treated wood is excluded – are well-developed internationally though sorting protocols, testing (eg handheld XRF) and severe penalties, for example. Divergent results on climate effects of bioenergy The scientific literature contains contrasting findings about the climate effects of forest bioenergy, due in part to the diversity of bioenergy systems and associated contexts, but also due to differences in methods. The climate effects of bioenergy must be accurately assessed to inform policy-making. The temporal and spatial system boundary and the reference (counterfactual) scenarios are key methodology choices that strongly influence results. Focussing on carbon balances of individual forest stands and emissions at the point of combustion neglects systems-level interactions that influence the climate effects of forest bioenergy. The most important climate change mitigation measure is the transformation of energy, industry, and transport systems so that fossil carbon remains underground. Narrow perspectives obscure the significant role that bioenergy can play by displacing fossil fuels now and supporting energy system transition. (Cowie et al., 2021) Mark Brown GAICD Director – Forest Research Institute Chair – IEA Bioenergy TCP References Anthesis (2025) Comparative Carbon Footprint of Uses of Wood Residues and Low Grade Roundwood. DR1907-4_Comparative-carbon-footprint-of-uses-of-wood-residues-and-low-grade-roundwood_AS_V004.pdf Cowie, A. L., Berndes, G., Bentsen, N. S., Brandão, M., Cherubini, F., Egnell, G., George, B... & Ximenes, F. A. (2021). Applying a science‐based systems perspective to dispel misconceptions about climate effects of forest bioenergy. GCB Bioenergy, 13(8), 1210-1231. https://doi.org/10.1111/gcbb.12844 DCCEEW (2024) Australian Energy Statistics Department of Climate Change, Energy, the Environment and Water https://www.energy.gov.au/publications/australian-energy-update-2024 Doerr, V. A. J., E. D. Doerr, S. McIntyre, G. Howling, J. Stol, M. Davies, A. Drew, G. Warren and D. Moore. (2009) Managing Invasive Native Scrublands for Improved Biodiversity Outcomes in Agricultural Landscapes. CSIRO https://www.researchgate.net/profile/Erik-Doerr/publication/265928049_Managing_Invasive_Native_Scrublands_for_Improved_Biodiversity_Outcomes_in_Agricultural_Landscapes/links/54b84c3d0cf269d8cbf6caec/Managing-Invasive-Native-Scrublands-for-Improved-Biodiversity-Outcomes-in-Agricultural-Landscapes.pdf IEA (2021) What does net-zero emissions by 2050 mean for bioenergy and land use? https://www.iea.org/articles/what-does-net-zero-emissions-by-2050-mean-for-bioenergy-and-land-use IPCC (2022) Climate Change 2022: Mitigation of Climate Change https://www.ipcc.ch/report/ar6/wg3/ Kelly, G. (2008) Application of Recycled Organics in Mine Site Rehabilitation. Department of Environment and Climate Change NSW. https://www.epa.nsw.gov.au/sites/default/files/080371-mine-site-rehab.pdf Li, M., Keck, F., Lenzen, M., Ximenes, F. (2024) Flexibility options in a 100% renewable grid for Australia. Materials Today Sustainability DOI: https://doi.org/10.1016/j.mtsust.2024.100736 Li, M., Middelhoff, E., Ximenes, F., Carney, C.,Madden, B., Florin, N., Malik, A., Lenzen, M. (2022) Scenario modelling of biomass usage in the Australian electricity grid, Resour Conserv Recycl 180. https://doi.org/10.1016/j.resconrec.2022.106198 NSW DPIRD (2024) Forest Science Matters Issue 10 https://mailchi.mp/dpi.nsw.gov.au/nsw-dpird-forest-science-newsletter-issue-10 NSW LLS (2014) Managing invasive native scrub to rehabilitate native pastures and open woodlands. Central West and Western Local Land Services. https://www.lls.nsw.gov.au/regions/western/articles,-plans-and-publications/managing-invasive-native-scrub-to-rehabilitate-native-pastures-and-open-woodlands Porritt, J. (2024) BECCS: If something’s worth doing, it’s worth doing well https://jonathonporritt.com/beccs-if-somethings-worth-doing-its-worth-doing-well/

5186

18/08/2025

Object

Email

Dear IPC Members, I am emailing this submission to urge you to reject the current Redbank Power Station Biomass proposal by Verdant Technologies. 1) Introduction This submission is informed by high level professional work experience in climate change/energy policy areas, including former duties as the Principal Greenhouse/Energy Policy Officer in the NSW Environment Protection Authority (EPA), entailing representing NSW on the National Greenhouse Gas Inventory, requiring extensive knowledge of carbon accounting and energy technology issues. I have gained a B.Sc.(Hons 1) and Ph.D. in Science, and so am able to provide a scientifically-informed critique of this proposal. I provided a submission on this ill-advised proposal back in 2021 when it previously came before Singleton Council, and erroneously assumed that the proponents had seen sense and dropped the idea. Unfortunately, I was sadly mistaken, and now find it is back, like a zombie that refuses to die. Verdant Technologies really should stick to large battery projects such as at Warkworth, and discard this ill-advised idea. Redbank Power station has always been a problematic plant since it was commissioned in 2001 on the premise that it would be burning coal tailings from nearby coal mines. In practice, the plant incurred repeated problems when trying to effectively combust coal tailings, and was frequently run on the same coal as used in other thermal power stations in the Hunter Valley, thereby negating its purported environmental advantage. Redbank eventually ceased operations in 2014, and was then purchased by Verdant Technologies, who have sought to power the plant by burning trees ("biomass"), trying to claim that this use was "substantially the same" as that under which its original approval was granted. This argument was rejected by Justice Duggan in the NSW LEC. While my key objections are outlined below, there are other deficiencies in the proposal, but lack of sufficient time precludes their consideration. 2) Vehicle Pollutant Emissions & Road Damage The proponent is now trying to use the State Significant Development pathway and a loophole in NSW's lax land clearing regulations (which are currently under review) to source 850,000 tonnes of cleared biomass per annum within a 300 km radius of the plant to provide fuel for power generation. Given this extensive area of impact, it is ludicrous that the proposal limits considerations of its environmental impacts to the 18 hectare Redbank site, when its environmental impacts can extend throughout this 300 kilometre radius. The proposal indicates it will use B-Double and other trucks to transport the cleared vegetation, creating additional extensive and ongoing traffic impacts (and attendant accident risks), as well as further additional sources of both greenhouse emissions and conventional pollutants. The B-double and other trucks required by this proposal will also create disproportionate additional road damage across a wide area of NSW, given that damage to a road surface is proportional to the fourth power of the axle load of a vehicle. Eight hundred and fifty thousand tonnes to the 4th power equates to around 5.22 septillion (no, this is not a typo) tonnes of load which then needs to be multiplied by the distance travelled by the trucks to derive the total amount of road pavement damage associated with this proposed activity. (Unfortunately, the proponent has not provided an estimate of the total road distance travelled per year, so the total damage impact can't be calculated at this stage.) However, on the basis of information available this will be a significant factor which raises the question - who is expected to cover the costs for this additional road damage created from 850,000 tonnes per year of axle load on NSW roads? Have NSW ratepayers and taxpayers been informed of this additional burden? This issue is not considered at all in the environmental impacts assessment submitted by the proponent, and constitutes a significant omission in the environmental documentation submitted for this proposal. 2) Greenhouse Gas Emissions The alleged "near net zero" emissions claimed by the proponent are not credible, and at odds with fundamental biophysical realities - they are simply an accounting "sleight of hand". In essence, it is assumed that burning vegetation will create the same emissions as if the vegetation had decomposed slowly and released its carbon back to the atmosphere. However, this is not a valid comparison. Natural long-term decomposition of vegetation returns significant amounts of carbon to the soil and other life forms through its digestion by fungi and other organisms, which in turn provide significant carbon-derived nutrients to a variety of other life forms both above and below the soil, thereby preventing the carbon's immediate return to the atmosphere. In contrast, the complete combustion of biomass immediately releases most of the biomass' carbon back into the atmosphere, increasing greenhouse gas concentrations in the short term, thereby amplifying climate change. The proponent's environmental analyses neglect this significant difference in the rate of carbon emissions over time between natural decomposition versus complete combustion. In essence, it ignores the emisssions profile over time of the 2 different pathways, which is a key consideration in climate change strategic policy considerations. This means the proponent's claim of near zero emissions is specious, and should be ignored by the IPC. It is also notable that the proponent's SEARS makes no mention of soil carbon, which will be released by the land clearing activities used to obtain the biomass fuel. This is a significant omission, given that soil carbon is the single largest stock of carbon in the earth's biosphere, and reduction in soil carbon is a recognised major risk factor with the potential to significantly amplify climate change. Maintenance and enhancement of soil carbon is widely recognised as a key response to climate change, and is currently supported via means of a varirty of policy reponses. This proposal is at odds with this inconvenient truth. The proponent's omission of soil carbon considerations is another major flaw, further highlighting the totally inadequate and irresponsible approach to climate change policy considerations embodied in this proposal. 3) Biodiversity Impacts This proposal is seeking to create an activity dependent on ongoing consumption of biomass. The clearing of native vegation is already recognized as creating severe environmental and biodiversity impacts, and this proposal will simply exacerbate our current problems. While the proponent claims that over time they will use biomass derived from dedicated plantations, they provide no consideration of what the alternatives would be if these plantations failed to produce the required amount of plant material or were impacted by natural disasters such as bushfires or droughts. Where would the substitute fuel feedstock come from under such circumstances? No credible analysis is provided - only vague undocumented assertions lacking any systematic analysis or specific details. In summary, the documentation provided for this proposal is not a credible or sufficient basis to give the green light to a proposal which has serious ongoing negative biodiversity impacts. 4) Summary Current efforts to effectively reduce global emissions are already hampered by use of carbon accounting frameworks which are not aligned with fundamental biophysical realities. The Redbank proposal provides an excellent example of such scientific sophistry. Any proposal which seeks to normalise the systematic destruction and burning of 850,000 tonnes of biomass per annum cannot be considered a credible souce of electric power with low environmental impact. It is an unncessary and wasteful diversion from implementing the genuine energy transition required by our current circumstances. This proposal relies on omissions and evasions to build its case, which cannot withstand any rigorous analysis. It is clearly evident that this proposal would create significant additional greenhouse gas emissions via three pathways - direct combustion of biomass, disturbance of soil carbon during the harvesting of biomass, and additional emissions from the transportation of 850,000 tonnes of biomass annually by trucks. As a consequence, this proposal will also create widespread negative impacts for roads, road users and road safety across many parts of NSW, as well as exacerbate the existing health and pollution burden borne by Upper Hunter residents. If this proposal were given the go-ahead, it will indicate that the NSW government and its agencies are not serious in trying to address our current climate change and biodiversity crises. The IPC will be doing Planet Earth, the people and biodiversity of NSW, as well as the NSW Government and its agencies, a huge service by conclusively REJECTING this ill-advised and destructive proposal. Yours sincerely, Dr Brett Stevenson Ph.D., B.Sc. (Hons 1).

5191

18/08/2025

Object

Email

To the NSW Independent Planning Commission, I am an ecologist with more than ten years' experience, currently conducting research at the University of New South Wales to improve the management of biodiversity through Australia's renewable energy transition. I am writing to oppose the proposal to restart Redbank Power Station near Singleton, NSW and burn up to 700,000 dry tonnes per year of biomass as fuel to generate electricity. I oppose this proposal for the following key reasons: 1. Burning biomass is a potentially carbon intensive form of energy generation (Field et al., 2008), releasing carbon from the biomass burnt into the atmosphere which will not be taken up by regrowing vegetation for many years, if at all. While an improvement on fossil fuel emissions there are now much better options for renewable energy generation, and current investment in energy infrastructure should be focussed on technologies with minimal carbon footprints such as wind power, solar power and batteries. 2. In addition to the carbon footprint of this project, the biodiversity footprint of the proposed Redbank Power Station is significant, relying as it does on burning native vegetation from land clearing. These offsite impacts could be considerable, contributing to the loss and degradation of native species and ecosystems across New South Wales. For these key reasons I oppose the proposed Redbank Power Station restart. Sincerely, Ruby Stephens -- Dr Ruby E. Stephens (she/her) Centre for Ecosystem Science University of New South Wales References Field, C. B., Campbell, J. E., & Lobell, D. B. (2008). Biomass energy: The scale of the potential resource. Trends in Ecology & Evolution, 23(2), 65–72. https://doi.org/10.1016/j.tree.2007.12.001

5196

New South Wales 2611

18/08/2025

Object

Email

I oppose the Redbank Power Station Proposal for the following reasons: 1. Unacceptable environmental and biodiversity impacts: i) the clearing and burning of vast areas of native vegetation as required under this proposal cannot be considered ecologically sustainable; ii) the project will inevitably result in increased land clearing, potentially in the order of many thousands of hectares. 2. The proposal’s carbon accounting under-represents emissions from land clearing and the burning of vegetation. Emissions from the burning of biomass are much higher than from solar and wind generation. 3. Negative impact on local air quality of the intensive transport and burning of biomass. Patricia Saunders

5201

New South Wales 2423

18/08/2025

Object

Email

Dear Commissioners, Re: Redbank Power Station proposal SSD-56284960 Again, I am writing to make a submission to strongly oppose the proposal to restart Redbank Power Station (RPS) (SSD-56284960). I submit my objection and oppose this development in the strongest possible terms. We are in a climate and biodiversity emergency and a development like this will only exacerbate these problems. This proposal to reopening RPS to burn wood, and so called forest waste has already been rejected twice. When will the proponents acknowledge they have no social or environmental licenses to proceed with this. At what point will decission makers acknowledge, and consider in the decision making process the horrendous extreme events Australia has experienced, the 2019/20 fires, the historic floods of Sydney, Mid and North Coast of NSW, the Brisbane floods etc.. At this very moment we have got massive wildfires throughout southern Europe with record high temperatures, and moreover, disastrous flash flooding in the Himalayas, Pakistan, India and Beijing. In light of the alarming and escalating impacts from climate change, and the extinction of our wildlife, this proposal could be regarded as negligent at this time and place. And for decission makers to knowingly approve such a climate change accelering, pollutting, and biodiversity destroying industry will be seen as culpable negligence. 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. We know without urgent action, our Koala populations could be extinct by 2050. This proposal will only exacerbate that extinction process for Koalas and other endangered & critically endangered species. Many of these species are hanging on in the areas that are proposed to be used to supply this dra The proposed supply of 850,000 tonnes of biomass required each year, will require a major increase in the rate of land clearing, especially in the Hunter valley and on the tablelands. This proposal will creat a market for large volumes of biomass that will provide an economic incentive to clear land that would otherwise not have been cleared. Most land clearing is unapproved & unregulated and if there is an application for an approval to clear land, there is no requirement for surveys to identify habitat of threatened species. It is undeniable that burning wood to fuel this converted coal burning power station will produce more CO2 and other pollutants than coal to produce an equivalent amount of electricity. This proposed polluting power station will release over 1.3 million tonnes of CO2 each year, while increasing emissions from debris and soils at the clearing sites, and from processing and transporting woodchips. There will be unacceptable negative impacts of sourcing 850,000 tonnes of woodchip on our already overexploited and stressed native forests in terms of habitat loss and disruption to the water cycle. This project appears to have an awful lot of green washing, using permissible green waste to generate green power is a myth and has been disproved. While often touted as a renewable or carbon-neutral energy source, wood burning releases pollutants into the air, including particulate matter, carbon monoxide, and other harmful gases. These pollutants contribute to air quality issues, respiratory problems, and climate change. Burning wood releases stored carbon and, while this carbon is part of the carbon cycle, burning so much at once can be expected to have negative social and environmental impacts beyond the RPS generating site. Landclearing and associated habitat fragmentation are the single greatest threat to biodiversity in NSW. Landclearing and logging are not in the public interest – they do not have a social licence, and do not require public consultation through a Development Application process like other developments on private land. In this day and age with extreme weather events becoming normal, native forests are worth more standing for biodiversity protection, carbon capture & storage and water catchment integrity. Moreover, the added negative effects of bushfire, air quality and disruptions to neighbouring communities from the hugely increased truck movement required to transport this material must be given serious consideration, particularly in light of the high levels of air pollution in the Hunter Valley. A recent NSW Parliamentary Inquiry recommended that native forest biomaterial not be classed as renewable energy or eligible for renewable energy credits as it is not a renewable or sustainable source of energy. This proposal is a strong echo of the disastrous, now abandoned, woodchip export activity from Newcastle by Sawmillers Exports Pty Ltd. They too proposed to source their product from forest logging waste, sawmill waste and silvicultural thinning. This was proven time and time again not to be the case. Instead the company was shown to be using young healthy trees which should have been left as part of a healthy regenerating forest to be utilised for future sawlogs. This must not be allowed to happen again. It is time to abandon the wilful blindness to the profound disastrous effects of native forest destruction. Even though not mentioned, I completely oppose any use of burning any form of plastic as an energy source. We should be at a point where we have evolved to circular economy, instead of the destructive, consumptive linear and recycling economy, that exists using raw resources with a single use. For the sake of our future and that of future generations of all species, I urge you to exercise your due diligence & duty of care and reject this unacceptable proposal. Your Sincerely Linda Gill 18.08.2025

5206

Braidwood Greens

18/08/2025

Object

Email

Submission from Braidwood Greens re: opposition to Redbank Power Station (SSD-56284960) Dear Commissioners I am making this submission on behalf of Braidwood Greens which was founded in 1993 and is a local group of the Greens NSW and Australian Greens. Within our local group coverage there are several national parks and state forest areas so we know only too well the damage that has already been done to these by bushfires and logging. In addition, there are many privately owned areas of native vegetation that have been cleared or are threatened with clearing by people who want to extend their agricultural areas or believe that vegetation poses a threat from bushfire or who want to sub-divide areas of bush into housing blocks. At a time when the effects of climate change are being experienced on a daily basis and trees and other plants are known to be our best hope of decreasing these effects, we simply cannot afford to let an activity like burning vegetation to create electricity proceed. Consequently we are strongly in 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. Why is this needed? Renewable energy can be sourced from the sun, wind, water and ground heat. It is neither necessary nor advisable to burn vegetation to create it. We already lose the vast majority of our native forests to wood-chipping. Approving this will only exacerbate an already unacceptable situation, and threaten remaining areas of vegetation when we need to everything possible to protect them. This 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, destroying native vegetation, not burning 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: • 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 • To meet Redbank’s demands, clearing rates would need to increase five to seven times current levels • In 2021 alone, more than one third of all woody vegetation clearing in NSW was unexplained, meaning it was either unauthorised or unrecorded Braidwood Greens are 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. This is unacceptable 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: • Burning 850,000 tones of vegetation will release over 1.3 million tonnes of carbon dioxide annually • Additional emissions will occur from the clearing process, soil disturbance, transport, and processing • The vegetation being cleared will not regrow. These are permanent land use changes, and the lost carbon will stay in the atmosphere for decades 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. This is all unacceptable. 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. • Most of the vegetation clearing will occur on private land, outside any formal planning or development application process. This is unacceptable. • No surveys are required to identify threatened species or ecological values before clearing occurs. This is unacceptable. • The satellite processing facilities proposed for dying and chipping native vegetation have not been identified, assessed or approved. This is unacceptable. 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. It is highly likely that 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. We urge the Commission to reject this proposal. • Burning of native vegetation is not clean energy • Logging residues must not be approved in the future as feedstock • Environmental impacts must include clearing locations, not just the power station site • Emissions must be properly accounted for and assessed under current climate goals. 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. Thank you for the opportunity to make a submission. Yours faithfully, Catherine Moore convenor/secretary Braidwood Greens August 17, 2025

5211

New South Wales 2094

18/08/2025

Object

Email

Dear Commissioners, Please find attached a short submission expressing my opposition to the proposal by Verdant Earth Technologies to restart of the Redbank Power Station by burning of native vegetation for fuel. Thank you for your consideration of the matters raised. Judy Lambert

Judy Lambert submission_Redacted.pdf (PDF, 188.49 KB)

5216

New South Wales

18/08/2025

Object

Email

To whom it may concern, I am making a submission in opposition to the proposed re-opening of the Redbank Power Station (SSD-56284960) For the following reasons 1. the project will be reliant on the permanent destruction and fragmentation of native vegetation - core habitat for many threatened species. (New figures show that rates of clearing have skyrocketed to 66,498 hectares in 2023, a 40% increase from the year before). 2. these areas should be regenerated rather than further destroyed. At every stage of regeneration, woodland forests provide immense value to native plants, wildlife and birds, but this proposal gives no consideration to their ecological value - including the importance of restoring connectivity for wildlife across large distances. Ensuring food and nesting resources for birds that range widely across our landscapes is critically important for their survival. 3. Claims that this project is carbon neutral are contradicted by the latest science. Burning wood emits more carbon dioxide than coal (Mackey et. al, 2025) and in some cases emissions are reportedly double (Booth, 2014). 4. It is scandalous that a landscape scale assessment of the biodiversity impacts of tree clearing that will supply the Redbank Power Station was not required by the NSW Government. There has also been no requirement to assess or reveal the CO₂ emissions from the projects associated biomass burning and clearing. Clearly the NSW planning framework is not fit for the purpose of preventing biodiversity loss and reversing our trajectory on climate change. 5. the recommendations of the Independent Review of the Biodiversity Conservation Act 2016 - NSW’s environmental protection legislation - which found that the ‘Clearing of native vegetation’ was one of the key drivers of ‘destruction, alteration and fragmentation of habitat across the state’ and a primary risk to biodiversity. In response, the NSW Government made a commitment to ‘end excess land clearing’ which has not been delivered. Thank you, Susan Ambler

5221

18/08/2025

Object

Email

Dear Sir/Madam I wish to submit that I am extremely opposed to the proposal to resurrect a power station in the Hunter Valley area and use timber as it's fuel. ..After a huge expense to get this proposal into effect, how long is New South Wales's timber going to last? ..The money spent on that would be much better put towards really solving our State's power supply in the long term, not as a band-aid short term solution. .. Scientific evidence has been produced to show that the carbon footprint would even exceed that of coal powered stations . ..The removal of biomass in the form of clearing timber & forest areas, native or otherwise, would create higher temperatures and prove detrimental to native flora and fauna that is already on the endangered lists for that area. Yours faithfully Heather McPhee

5226

New South Wales 2131

18/08/2025

Object

Email

To the Independent Planning Commission, My position is in OPPOSITION to the proposed re-opening of the Redbank Power Station (SSD-56284960) due to the following reasons: 1. Carbon emissions: The project being deemed carbon neutral relies on the premise that the biomass “waste” material would have been otherwise burned. There is insufficient evidence this is the case. Further, the amount of biomass fuel the power plant requires will result in an increase in logging of invasive native species. This WILL result in an overall increase in emissions. Details in the report of how the carbon sequestration will occur are insufficient. The cost to the environment (both locally and globally) are too great to allow this project to continue until this is addressed. 2. Soil and habitat degradation: When the project matures, it will burn plantations of fast growing native trees every 3-5 years. The analysis of how this land will cope with the rapid growing and removal of the trees and subsequent loss of soil quality and animal habitat is insufficient. 3. Vegetation loss: It is highly likely the project will result in an acceleration of vegetation loss in NSW. By providing financial incentives to land owners to clear “waste” vegetation, there is a strong chance that the amount of land cleared will be higher than it otherwise would have been. This will further decrease the opportunity for carbon sequestration. A lack of clarity regarding where the fuel stocks will be sourced is a major concern as is in the future there may be additional land clearing required to keep the power plant operational. Finally the use of the term “invasive native species” is misleading as these are often native flora which are growing as a result of misused land. Further clearing of these trees will result in the loss of animal habitat and less opportunity for the land to recover and return to its original state in the future. Thank you for considering this submission. Simon Le Breton

5231

Australian Forests and Climate Alliance (AFCA)

18/08/2025

Object

Email

Please find attached AFCA's 2025 written submission regarding Redbank Power Station, noting that our 2024 submission might be consulted as required. With this submission we attach 4 appendices numbered 2,3,4, and 5. There is no Appendix 1. Note please that Appendix 2 is a zipped file containing several scientist letters. regards, Frances Pike *Appendix have been combined for publishing*

AFCA SUBMISSION RE REDBANK RESTART 2025_Redacted.pdf (PDF, 1.45 MB)

AFCA Appendix 2 combined.pdf (PDF, 1.33 MB)

AFCA Appendix 3, 4 & 5 Combined.pdf (PDF, 2.1 MB)

5236

18/08/2025

Object

Email

I am writing in opposition to this proposal. My objections are as follows. Environmental and biodiversity impacts The proposal to burn up to 700,000 tonnes of dry biomass annually, primarily from land clearing and potentially from native forests, will threaten biodiversity. The proposal is not carbon neutral and will ultimately undermine the NSW government’s climate and conservation goals. The Australia Institute has advised that the environmental impact statement (EIS) for this proposal has vastly underestimated the greenhouse gas emissions and other potential environmental impacts that the project could have. The proposal will have unacceptable environmental and biodiversity impacts. The Fuel Supply and Characterisation Study - Restart of Redbank Power Station - claims that: '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 is not ecologically sustainable. The proposal relies heavily on the clearing of 'Invasive Native Species' (INS) that is poorly regulated and overseen. ‘Invasive native species’ is a term that has been used to allow farmers to clear native vegetation on their properties with little oversight, for the purpose of increasing agricultural productivity. Land clearing and ‘INS' will provide 71% of the fuel burned in the first year and 64% in the second year. Based on information provided by the proponent, Verdant Earth Technologies, at least 20,000 hectares of ‘INS' will need to be cleared to provide the required fuel levels during the project's 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. The demand creates the risk that 'INS' is managed in an ecologically unsustainable way. By providing a market for dead native vegetation, it will drive increases in land clearing. The EIS fails to assess off-site impacts. It considers only impacts on the 18 ha of land that the power station sits on, ignoring the potential biodiversity impacts on the thousands of hectares of land clearing required off-site. The proposal aims to establish biomass fuel crops to sustain the project long term. Verdant Earth Technologies’ proposal states: ‘in order to meet the total required biomass demand, a total planted area of 72,000 hectares would be required’. The proposal seeks to convert grasslands to crops and the project plan specifies it will target marginal 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. Emissions from land clearing are under-represented 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. Verdant Earth Technologies claims 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 breaks down slowly over a long period. The emissions from biomass burning are compared to high emitting coal plants rather than wind and solar; the Verdant Earth significantly overestimates 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. Such an increase in heavy traffic is completely unacceptable. 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 to be used in this project under future governments. The banning of any native vegetation to be used 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 to produce electricity. Labor has stated its recognisition that burning timber and cleared vegetation for electricity is not carbon neutral and is neither clean nor renewable energy. Better alternatives There are much better alternatives to this proposal that will enable NSW to reach its renewable energy goals. The NSW government needs to focus on high value, cleaner energy solutions like solar and wind power. Yours faithfully Paul Wallace

5241

New South Wales 2448

18/08/2025

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Submission to Independent Planning Commission NSW Redbank Power Station BIOMASS Proposal 18 August 2025 To Planning Panel, Please accept my submission for the consideration of the Redbank Power Station Biomass Proposal. Governments have an important role to play to govern for all of NSW residents at a time of Climate Change, while considering inter-generational legacies. More than ever governments need to govern for the common good and not just for business. I oppose the Redbank Biomass Power Station proposal for several reasons: 1. It creates air pollution. If not captured it will contribute to smog and exceed the emissions of some fossil fuels. It can release hazardous pollutants like PM2.5 and volatile organic compounds. Communities may experience respiratory problems, sleep disturbances and other health issues. The health and safety concerns of the communities that live around this power station should be considered, not just the Health and Safety of workers. Many communities in the United States especially in the south (Carolina) are documented as having negative impacts on their health and lifestyle. 2. Supporters of biomass for fuel often highlight the carbon cycle of plants as if this in itself is the justification for biomass for fuel. The reality is a bit more complex. Burning biomass by combustion releases carbon dioxide negating any benefit of the trees carbon storage. During the time that is labelled as “payback period” is a furphy. How are they measuring the carbon offset? The regrowth of trees can take decades-even centuries to grow. Cutting forests for fuel releases carbon instantly. To be carbon neutral we need to know time frames being studied, what type of biomass is being used, the combustion technology, which fossil fuel it is replacing, and what forest management techniques are employed where the biomass is being harvested. According to the UK Office of national Statistics and UK government “Department of Energy and Climate change, Life cycle and impacts of biomass electricity 2020, “A major source of biomass burnt (In UK) were wood pellets. In 2018, 82% of the wood pellets were imported from Canada and USA. 7.8 million tons.” It continues to state that UK government research has shown that greenhouse gas emissions per unit of electricity generated by biomass can be lower or higher than those of fossil fuels like coal and gas depending on factors such as type of biomass burnt.” Where is the benefit? 3. If NSW starts relying on bio fuels for its energy mix, it will inevitably place increasing pressure on our forests and the fauna and flora that live there. Large scale Bio fuel stations will require increasing large volumes of biomass. This will lead to forest degradation, loss of carbon storage capacity and be a significant contributor to negative aspects of climate change. As stated earlier, converting biomass to energy requires in itself a lot of energy and in some cases higher than the energy it produces. Increase demand will far outweigh a sustainable supply. 4. Biomass is less energy efficient than other energy sources such as wind and solar. Bio fuels are Natural Resource intensive. For all the above reasons I oppose the Redbank Station proposal. I reject “Biomass” being described as a “waste product “when in fact it’s role in a forest is crucial. In the natural world, tree limbs, leaves, and plant parts from forests would naturally recycle nutrients back into the soil as they decay. Removing them will hasten erosion and diminish soil fertility. Heavy machinery impacts the soil leading to increased runoff which may affect water quality if water resources are close. Removing vegetation from the ground also impacts wildlife habitats. Source (Renee Cho, 2016 Colombia School Climate, Earth, & Society, State of the Planet.) I trust the NSW Independent panel will carefully weigh up the pro and cons of this energy proposal. Biomass fuel is only “Green” if the supply chain is sustainable. I urge that you consider future generations in this decision, and the devastating floods and fires that will continue to negatively impact NSW residents and environment. Thank you for this opportunity. Lotus Cavagnino

5246

New South Wales 2536

18/08/2025

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Dear IPC, I wish to make the following submission opposing the Redbank Power Station Biomass proposal. The burning of native vegetation, produced mainly from land clearing, is not carbon neutral. This will result in more destruction of forest and associated shrublands on private property, increasing the threat of extinction for native species of birds, animals, reptiles and plants. The proposed fuel is referred to as “invasive native species”, ignoring the fact that native shrubs and trees are the essential backbone of a functioning habitat. What government or expert scientific authority is going to examine and identify these so-called “invasive species”, before they are cleared and burned? How many endangered plants and animals will be destroyed in this unmonitored process? How much stored carbon in these trees and shrubs will be burned and released into the atmosphere? This is promoting land clearing and destruction of the environment for company profit, all the while cynically promoting the untruth that this is “green” power generation. There is no plan for the power station operators to replant the 20,000 ha of trees and shrubs removed and burned in the first year alone, or to undertake long-term environmental rehabilitation. The promise to move to burning crops grown specifically to be burned by the power station, does not result in the storage of carbon. The opposite is true, as burning these crops will result in a huge release of CO2. As has been demonstrated scientifically, the burning of this type of biomass fuel produces more carbon released into the atmosphere than the burning of coal itself. The Environmental Impact Statement of the project does nothing to address the wider damage that will be caused by the land clearing that this project proposes. Furthermore, the proposed carbon capture and storage “solutions” cited have so far been a colossal failure in practice in Western Australia. These “solutions” have delivered only a tiny part of the promised results in carbon capture at the Gorgon project, which has been a conspicuous failure of the technology in spite of much greenwashing. The vague statements of the Redbank project that carbon will be captured from burning biomass ignore the fact that the technology does not exist to do this with anything like acceptable efficiency. This proposal to burn biomass for power generation is a highly polluting method that will result in an increase in atmospheric CO2 pollution, destruction of very large areas of native forests and shrubland, and an increase in the extinction crisis that New South Wales is currently experiencing. This proposed use of biomass for power generation is unsustainable, polluting and environmentally disastrous. The proposal should be rejected and replaced with renewable power generation from wind and solar. Yours sincerely, Dr Marjorie Apthorpe,

5251

New South Wales 2330

18/08/2025

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I object to the proposal to Restart Redbank Power Station in the Hunter Valley, near Warkworth, for many reasons, including those listed below. The Assessment Report of the Redbank Refiring Proposal SSD-56284960 lists ‘Key reasons for objection from the community include greenhouse gas emissions, offsite biodiversity impacts to source biomass for fuel and air quality and human health impacts from the operation of the power station. ‘ BUT, despite many documents later and apparently a significant amount of talking before the Public Meeting on Monday August 11, 2025 that I attended, it seemed to me that there was no reason for any of the objections to be withdrawn. My experience of the meeting was that the proponent has grossly failed to address or respond to the concerns raised by the public. The best that I could gather from the speaker for Verdant , Mark Jackson, at both the beginning and end of the meeting was that the project could be construed to be compliant with the current legal structure. It certainly was not highlighted however that it is contrary to Government Policy. Electricity generated by burning wood waste is not renewable energy like solar and windpower. It was however acknowledged that there would be a negative impact on air quality but since the locality is already suffering the greatest number of exceedances of the Valley, a little bit more does not matter. This is certainly not in the public interest. I contend that, despite the Dept Planning, Housing and Infrastructure recommending approval with conditions, the Independent Planning Commission only has an adequate basis for valid assessment of the proposed Redbank Biomass Burning Steam Power Station with respect to the public interest. The only information that was provided supporting an approval by the IPC being in the public interest was the grossly inflated unsubstantiated job creation statement by Dan Rapacholi and by businessmen proposing it would encourage investment. Whereas there were many presentations of well researched authoritative information exposing the inherently flawed carbon accounting methodology debunking the story of any possibility of burning 850,000 tonnes of wood and not producing greenhouse gas emissions that contribute to global heating. In fact the Redbank Proposal would produce 1.3 million tonnes carbon dioxide per year. The global carbon budget to keep annual temperature rise below 1.5 degrees as now calculated [globalcarbonbudget.org] means we must radically cut emissions now and increase sequestration. Every tonne of carbon that we do not put in to the atmosphere is worth saving. It is not in the public interest to contribute to our uncertain future of dangerous climate change. It seems that the primary purpose of this application is to increase the abstract stockmarket value of an alleged renewable energy asset if it can obtain an approval. The actual operation of the scheme remains halfbaked with most details not developed. At the Public Meeting it seemed to me that the proponent actually recognises this fact as almost the entire operation is riven with uncertainty from fuelsource, fuelsource supply, transport capacity, fuel source storage to minimise moisture uptake, security of water supply, impact of greenhouse gas emissions and air quality, including appropriate monitoring,. The only certain thing about this proposal appears to be the misrepresentation of the impact of the burning of biomass on biodiversity. The failure of European land management to respect, understand and work with these old ecosystems of terra australis has led to our current biodiversity crisis. This proposal continues this failure to understand or perhaps it is that the proponent just does not care. I heard several presentations on the impact of a proposed threefold increase in annual clearing on the biodiversity of the Central West from expert witnesses. These presentations and others evidenced the appalling omission in assessment of the impact of the proposal. The proponent apparently relies upon Local Land Services to oversee the process, as this is the law but the self assessment process is not designed for broad scale clearing required by this proposal. LLS is a land management agency to support agriculture, actively encourages clearing of “Invasive Native Scrub” and does not carry any sense of the crisis of biodiversity loss through habitat clearing, let alone promote the restoration of ecosystem services that the “invasive native scrub” is contributing to by, for example, holding soil together and slowing water loss from evaporation by shading. Verdant has a moral, at the very least, and also perhaps now, a legal duty of care to consider the impact of the proposal on the environment in the locality where the fuel would be sourced. It did seem, in fact, by the end of the Meeting that Verdant or at least Mark Jackson had come to some acceptance of this perspective as he said, something like, the community seems to be forgetting that the idea of using “woody waste” would only be for the first few years with the implication that this diminishes the significance of the impact. In fact it rather more highlighted the failure of the unrealistic understanding or perhaps even consideration of the ‘on the ground’ impact of this project. Verdant has also been negligent, unrealistic or perhaps just cavalier with respect to water supply for the Refiring of Redbank proposal, or perhaps there has been an administrative error or perhaps it is my mistake but I did not find any conditions of consent regarding water licencing. I noted in the DPHI Assessment Report: 36. The project would require the purchase of a water access licence (WAL) under the Water Management Act 2000 (WM Act) to extract up to 3,300 ML/year of raw water from the Hunter River. And : A11 DCCEEW Water Group • Requested additional information regarding water take and water transfers. • Verdant provided the additional information to the satisfaction of DCCEEW Water Group. • DCCEEW Water Group provided recommended conditions of consent regarding water licencing. But there is only 4 responses to a search for “water” in the Conditions of Consent document and they do not refer to licencing. Moreover, as I tried to explain to the Commissioners when I stepped in to speak, it is not a simple matter to get water from the Hunter River. I speak from the experience of being a community representative on the Hunter River Water Management Committee that developed the Hunter Regulated River Water Sharing Plan. The proposal has not taken in to account the Hunter River Water Sharing Plan and the fact that the water may not be available. The speaker for the proponent advised, at the Public Meeting, that the Water Licence previously held by Redbank was ‘relinquished’ in 2018 when it was sold. This water licence is not a licence to extract a certain amount of water, it is only a licence or right to access water, to have a share of the water in accord with the Hunter River Water Sharing Plan. During times of drought and limited water storage in Glenbawn and Glennies Crek Dam right to access the Hunter River water is restricted according to the status of water licence held. General Security licences, generally held by farmers with prime agricultural land, are restricted before high security licences. The water needed to operate Redbank, a steam power station is not guaranteed, even if they can buy the high security licenced water allocations that they need. It cannot be guaranteed, particularly in our uncertain future of climate change. The proponent promoted the proposal of this burning biomass project using purpose grown crops for fuel as NOT being in competition with prime agricultural land for food production, BUT, in times of drought High Security Water licence Holders and specifically power stations get access to water before the farmers. Not only would there be competition for water in times of drought between power generation and food production if Redbank went ahead, but this is presuming that Redbank is even able to actually buy enough water allocation shares … perhaps all the current holders of high security licence holders will decide to not sell, not even for love nor money – no matter what is offered. The uncertainty of the capacity of Redbank to secure the necessary water for operation is yet another factor that has apparently been overlooked by the proponent. For ongoing operation, the proposal needed to take the Hunter River Water Sharing plan in to account. The Redbank Refiring Power Station proposal is not dispatchable energy production [unless the use of diesel could be considered as available ! (it certainly is not precluded in the conditions of approval)]. Not only is 24/7 energy production from steam powered turbines not easily turned off and on, but it also needs a lot of water and a secure supply. It is antiquated technology. The overall extraordinary lack of certainty in almost all aspects of the project could not inspire confidence in investors for the project going ahead. This proposal also evidences a complete failure to appreciate that there are irreparable consequences for continuing to emit carbon as if there is no tomorrow. I submit that the IPC has a sound basis for rejecting this proposal. Yours sincerely, Marg Mclean

5256

Northern Beaches Envirolink

18/08/2025

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