Consultation in Reverse: How EnergyCo Decided First and Asked Later

Consultation in Reverse: How EnergyCo Decided First and Asked Later

The Core Problem

The Community and Employment Benefit Program (CEBP) Policy Paper, published by EnergyCo in July 2024, is presented as evidence of the NSW Government's commitment to sharing the benefits of the energy transition with regional communities. It speaks of collaboration, consultation, community voice, and legacy outcomes.

But it arrives years too late — and in the wrong order.

The critical decisions that will shape the New England region for decades were made without any genuine community consultation. Now that those decisions are locked in and construction is bearing down on our communities, EnergyCo offers us a say on how to spend a fund whose size we don't know, governed by rules that don't yet exist, administered by the same body that made those decisions without us.

This is not consultation. This is choreography.

What Was Decided Without Us

The following foundational decisions — each with profound and irreversible consequences for our communities — were made before anyone in the New England region was meaningfully consulted:

1. The Declaration of the REZ Itself

The New England REZ was declared by the Minister under the EII Act without community consultation on whether our region should host an REZ of this scale, or at all. The declaration — covering an enormous geographic area across multiple Local Government Areas — was a top-down decision. No community vote. No local input. No impact assessment shared with residents before the decision was made.

2. The Scale — 8 GW

The New England REZ was designated for up to 8 GW of renewable energy generation — one of the largest in the country. This scale was determined by government and EnergyCo based on transmission modelling and energy market objectives. At no point were the communities expected to host this infrastructure asked whether 8 GW was appropriate, sustainable, or survivable for our region. ReD4NE has consistently advocated for a revised 2–3 GW model, but that conversation was never invited before the target was set.

3. The Location

The geographic boundaries of the REZ were drawn around our farms, our towns, our water catchments, and our roads. The decision about where to concentrate this infrastructure was made centrally. Landowners and residents discovered they were inside a REZ — not because they were consulted, but because developers started knocking on their doors.

4. The Access Scheme Framework

The access scheme — which determines how generators connect, what they pay, and under what conditions — was designed by EnergyCo. The community and employment component of access fees was embedded in legislation before any community had a say on whether the fee levels were adequate, how the money should be governed, or who should control it.

5. The Transmission Routes

Decisions about where high-voltage transmission lines would run — through farmland, across ridgelines, near homes — were progressed through planning processes driven by EnergyCo and network operators. Communities were presented with preferred routes and asked for feedback within tight timeframes, not invited to shape the options from the outset.

6. No Cumulative Impact Assessment Before Approval

Multiple large-scale projects — wind farms, solar farms, battery storage, pumped hydro — were individually assessed and approved without any cumulative assessment of their combined impact on our water, roads, workforce, housing, or social fabric. Each project was treated in isolation. The community was never shown the full picture before it was too late to change it.

What We're Now Being "Consulted" On

After all those decisions were made, the CEBP Policy Paper now invites us to have a say on:

• What our local priorities are (after the priorities of the energy market have already been imposed on us)
• What types of projects we'd like funded (from a fund whose size hasn't been disclosed)
• How we'd like to be consulted (after the most consequential decisions are already locked in)
• Who might deliver community benefits (under rules that EnergyCo will write, assess, and decide upon)

The paper is 25 pages of warm language about collaboration, legacy, and community voice. But it contains:

• No dollar amounts — we don't know how much is in the fund
• No access fee rates — we don't know what generators will pay per MW
• No host community definition — the most impacted communities have no guaranteed share
• No independent governance — EnergyCo administers, assesses, and decides
• No community voting rights — we advise, they decide
• No binding commitments — on water, roads, decommissioning, local employment, or procurement
• No grant guidelines — the rules for applying don't exist yet
• No clarity on forward funding — whether TAF money is a grant or a loan against our future benefits

In short, we are being consulted on the colour of the curtains after someone else designed the house, built it on our land, and kept the keys.

The Right Way Round

Genuine consultation would have looked like this:

Stage

What Should Have Happened

What Actually Happened

Before REZ declaration

Communities asked whether they support hosting an REZ and at what scale. That’s how the French do it.

Declared by the Minister without community input

Before scale was set

Independent assessment of what the region can sustainably support — water, roads, workforce, social infrastructure

8 GW target set based on energy market modelling, not community capacity

Before boundaries were drawn

Landowners and residents consulted on geographic scope and exclusion zones

Boundaries drawn centrally; residents discovered they were inside a REZ when developers arrived

Before access scheme designed

Communities consulted on fee levels, fund governance, independent administration, host community protections

Access scheme framework embedded in legislation; community and employment component designed by EnergyCo

Before projects approved

Cumulative impact assessment across all proposed projects — water demand, road capacity, workforce displacement, housing pressure

Projects assessed individually with no cumulative picture

Before transmission routes selected

Communities involved in route option development from the outset

Preferred routes presented for comment within tight timeframes

Then — and only then

Communities consulted on how benefits should be shared, governed, and distributed

This is where we are now — being asked about benefits after all the costs have been imposed

What This Policy Paper Really Is

The CEBP Policy Paper is not a plan. It is a promise to plan later — with EnergyCo holding the pen.

It gives the impression of community inclusion without delivering any of the structural safeguards that would make that inclusion meaningful. It is a framework for a framework, published after the decisions that actually matter have already been made.

Our communities are not opposed to renewable energy. We accept our fair share. Not saturation. Not extraction. Not at any cost.

But we will not accept a process that imposes the costs first and then asks us — politely, consultatively, collaboratively — how we'd like to arrange the consolation prizes.

If the NSW Government is serious about leaving communities "better off than before," it needs to start by acknowledging that the process was done in the wrong order — and give communities genuine power over the decisions that are still to come.

Responsible Energy Development for New England (ReD4NE) is an independent, not-for-profit, member-funded community organisation established in 2021.

We accept our fair share. Not saturation. Not extraction. Not at any cost.

Source document referenced: [Community and Employment Benefit Program for Renewable Energy Zones in NSW — EnergyCo, July 2024] (uploaded file: u0728062320_cebp-policy-paper.pdf)