Energy Planning Framework – Committee for the Hunter submission Jan 2024 1

Department of Planning and Environment

Thank you for the opportunity to provide feedback on the draft Energy Policy Framework.
The Committee for the Hunter (the Committee) acknowledge the leadership of the NSW
Government in reviewing the planning framework for clean energy infrastructure and support the
principles that have informed the draft guidelines.

INTRODUCTION
NSW emissions reductions, clean energy infrastructure and industry decarbonisation commitments
depend on investment and development in the Hunter.

The Hunter is home to the State’s largest electricity users and emitters, and accounts for 83 per cent
of NSW coal-fired electricity generation capacity.

The next decade will be especially critical for a timely transition from fossil fuel power generation, to
meet emission reductions commitments, keep the lights on, and provide low cost and reliable
renewable energy for NSW residents, business and industry.

The Hunter has a proud industrial heritage, powering NSW communities and the economy for over
50 years.

As the State shifts to clean energy and Net Zero, our region is impacted more than most. With smart
planning and targeted investment, the Hunter economy and quality of life will thrive through this
change, sustaining our critical role as energy provider for NSW.

The Committee has set a vision for the Hunter to be a global leader in clean energy and technology.

In our submission, the Committee seek assurance the proposed planning framework helps
achieve this vision, improves clean energy project delivery, meets the design principles
outlined in the Guide, and does not embed further costs, delays and uncertainty.
Planning reforms also provide a strategic opportunity to incentivise clean energy
investment and development in NSW and the Hunter when coordinated with other
measures across departments.
These include investment attraction and concierge, public-shared infrastructure and workforce
development.

This is a key recommendation in the industry-led Hunter Hydrogen Infrastructure Masterplan, with a
streamlined planning framework identified as one of the most powerful levers available to assure
competitiveness.

As a contestable network of energy assets, NSW relies on private sector investment to achieve its
climate and clean energy objectives and commitments at the scale and speed required. With the
State’s remaining coal fired power plants scheduled to close within 16 years, NSW is running out of
time to get this right and be competitive with other states and nations facing the same challenges in
the global race for new energy infrastructure investment.

Energy Planning Framework – Committee for the Hunter submission Jan 2024 2
ABOUT THE HUNTER

FEEDBACK
General Comments
1. Introduce ‘national and international competitiveness as a destination for clean energy
infrastructure projects’ as a core design principle (pp4 of the policy Guide).
The draft framework would benefit from transparent comparison on a range of performance
criteria with other states/territories and nations NSW competes with, including time, cost,
complexity and certainty. This includes how amendments improve the performance of the
existing planning system and project approvals and align with international standards for
clean energy projects.

Energy Planning Framework – Committee for the Hunter submission Jan 2024 3
General Comments (cont.)
2. Strongly support the broader use of Critical State Significant Infrastructure (CSSI) pathways,
including but not confined to when a project includes a significant energy storage system.
In the longer term, CSSI pathways, complying development and strategic assessments under
the Environment Protection and Biodiversity Conservation Act could be used as incentives to
attract investment and drive projects into the Hunter-Central Coast Renewable Energy Zone.

3. More clarity on the scope and weighting of ‘dwelling entitlements’ for which the proposed
visual impact requirements compel assessment and a 2km setback for wind infrastructure,
more than the distance required in Queensland, Victoria and Western Australia.

Ensure that visual impact requirements for wind and solar are not more extreme or onerous
than other jurisdictions and align with international standards.

4. Secure sufficient resourcing for the Department of Planning approvals team to assess more
clean energy infrastructure proposals, quicker.
5. Include markers for offshore wind and hydrogen projects in reforms, signalling that these
projects are part of NSW’s clean energy infrastructure plan and system including the Hunter-
Central Coast Renewable Energy Zone, and are facilitated by the State.

Wind & Solar Energy

7. Regional cities: The guidelines require wind and solar developments near certain regional
cities to satisfy that any urban land conflicts and impacts on urban growth potential are not
significant.
In order for this to be effective in high growth regions like the Hunter and not unduly
quarantine land from clean energy development, the NSW Government and Department of
Planning must get better at providing longer-term and strategic direction on where
development and public infrastructure investment will go, when, and where it won’t,
including via the Lower Hunter City Plan and Hunter Regional Plan.

Transmission Guideline
8. It is understood there has been significant coordination and feedback between the
Department of Planning and EnergyCo on planning frameworks for transmission
infrastructure. We will be looking to the final guidelines that they facilitate delivery of the
Hunter Transmission Project and future major transmission infrastructure required to deliver
the Hunter-Central Coast Renewable Energy Zone and Hunter Hydrogen Hub.

Energy Planning Framework – Committee for the Hunter submission Jan 2024 4
Benefit Sharing & Private Agreement Guidelines
9. The principles of a Benefit Sharing scheme that invests in the communities directly impacted
by clean energy development are supported, including adjustment for council rates. The
Hunter has experience with similar schemes for communities impacted by coal mining
activities and power plants, delivering positive outcomes for people, councils and
developers/asset owners.
We note the proposed Benefit Sharing scheme is additional to any project-specific Private
Agreements and costs.
Care will need to be taken in the design and implementation of any Benefit Sharing scheme
that this does not inadvertently disadvantage a nascent class of projects prioritised by the
NSW Government as critical for the State’s development over the next decade and beyond.
This imperative and immediacy drives a stronger role for the NSW Government in securing
greater local acceptance and support for the State’s energy transition in the Hunter,
including through public awareness campaigns and community funding programs. We note
the related commitment by EnergyCo to leverage access fees for community and
employment purposes.
Currently the region is experienced significant delays in accessing funding from the NSW-led
benefit sharing scheme for coal communities in transition – the Royalties for Rejuvenation
Fund. Enabling legislation passed in May 2022. There are no public guidelines or visible
pathways to apply for or access funding for the $25 million p.a. fund.
It is recommended the implementation of a Benefit Sharing scheme carefully consider:
• the timing and potential staging of rollout as to not deter clean energy development
in the critical 10-15 years of investment to replace the State’s retiring coal fired
power plants and achieve the legislated 70 percent emissions reduction target for
2035. This includes options for the scheme to be voluntary or subsidised for an initial
period.
• direct government investment in the scheme given the shared needs, benefits and
long-term public interest of clean energy infrastructure development.

Energy Planning Framework – Committee for the Hunter submission Jan 2024 5