Clarence Colliery (MOD 4) - Coal Supply to Mount Piper Power Station

Please find attached a submission from the Nature Conservation Council of NSW.

We encourage Centennial Coal, Energy Australia and the NSW Government to use the coal supply constraint at Mt Piper Power Station as an opportunity to diversify the region into tourism and clean sources of energy rather than increase heavy-vehicle traffic and air pollution for the people of Lithgow.

We are also very concerned about the impact of heavy diesel truck movements, mining and coal-fired power on air pollution and the health of residents in Lithgow and surrounding areas. Although the direct emissions from this proposal are relatively small, the proposal must be considered in the context of the cumulative emissions load in the region.

Therefore if it is approved we are seeking conditions to be attached to the consent which will reduce the air quality impact and ensure proper monitoring of air pollution in the Lithgow region. We recommend the addition of the following new conditions of consent if approval is granted:

1. Centennial must pay for the NSW Department of Planning and Environment to install, operate and maintain at least two permanent, National Association of Testing Authorities (NATA)-accredited, continuous air-quality monitoring stations in the Lithgow area. These should become part of the NSW Government's statewide air-quality monitoring network and monitor particles, sulfur dioxide, nitrogen oxides and ozone.
2. Trucks transporting coal from the premises must be covered immediately after loading to prevent wind blown emissions and spillage. The covering must be maintained until immediately before unloading the trucks.
3. The drop height when loading and unloading the trucks must be less than 1.5 metres.
4. The moisture content of the material transported must be at least 2%.
5. There must be a truck wheel wash before any truck used to haul coal leaves the mine or the destination to ensure that truck is clean and free of loose material.
6. All trucks used to haul coal from the site must be compliant with Euro VI standards for heavy vehicle emissions.

I totally support the Clarence Coal Project as it will provide much needed employment in the Lithgow Community.

SUBMISSION ON CLARENCE COAL (MOD 4)
Dear Sir/Madam,
Thank you for the opportunity to comment on Centennial Coal’s application to modify conditions of consent for the Clarence Colliery to increase the total allowable coal haulage off-site by road to the Mount Piper Power Station by 100,000 tonnes until 31 December 2020.
I am very concerned about the impact of heavy diesel truck movements, mining and coal-fired power on air pollution and the health of residents in Lithgow and surrounding areas. Although the direct emissions from this proposal are relatively small, the proposal will increase air pollution and must be considered in the context of the cumulative emissions load in the region.
Air pollution is a serious issue in Lithgow and is harming people’s health
In the Lithgow region there are several significant sources of fine particle pollution, including the Mt Piper power station and local mines, including Centennial’s Springvale and Clarence collieries. According to data from the National Pollutant Inventory, in 2017-18 there were 395,700 kg of fine particles emitted from these three sources alone, including 61,000 kg of ultra-fine particles less than 2.5um.
The NSW Environment Protection Authority has identified fine particle pollution as a priority due to the adverse impacts on health, particularly for the elderly, children and those with existing health conditions, such as heart or lung disease or asthma.
Air pollution is currently not adequately monitored in the Lithgow area
Unfortunately, it is not possible to accurately assess the impact all this accumulated air pollution is having on the health of residents in Lithgow and the surrounding region. This is because there is currently no National Association of Testing Authorities-accredited, continuous air-quality monitoring station in the Lithgow area as part of the NSW Government's statewide air-quality monitoring network. However, in comparable regions such as Muswellbrook and Singleton, near the Bayswater and Liddell coal-fired power stations, publicly available data shows these areas regularly breach national air-quality standards for fine particles.
Transportation of coal by road will add to the cumulative air pollution load
The proposed modification will result in an additional 30–56 daily movements of heavy diesel trucks through Lithgow. This is on top of the existing 50 truck movements per day associated with a similar modification granted in 2014 which has allowed 100,000 tonnes per year of coal haulage to the west. This will significantly add to the cumulative air pollution load through wheel-generated particulates on unsealed roads at either end of the journey and transferring and dumping coal into and out of trucks. The NSW EPA has also identified diesel exhaust emissions as a major source of fine particle pollution, as well as ozone-forming nitrogen-oxides and toxins.
Centennial should be required to ensure public air-pollution monitoring
Centennial Coal operates the Springvale and Clarence collieries, and supplies the coal for the Mt Piper power station, the largest emitter of fine-particle pollution in the region. Centennial has a responsibility to ensure health authorities and residents are better able to understand the cost to their health and wellbeing of air pollution and identify opportunities to mitigate the threat. This modification application is an opportunity to ensure Centennial Coal takes on this responsibility.
The monitoring stations should be publicly owned and operated as part of the NSW Government's statewide air-quality monitoring network. It is not good enough for the monitoring to be privately undertaken by the polluter. To ensure access, consistency and public confidence in the quality of the data being reported, Centennial Coal should be required to pay for the NSW Department of Planning and Environment to install, operate and maintain at least two permanent, NATA-accredited, continuous air-quality monitoring stations in the Lithgow area. These should monitor particles, sulphur dioxide, nitrogen oxides and ozone.
Best practice pollution reduction controls should be mandatory
The conditions of consent should require best-practice pollution reduction controls for the loading, transport and unloading of the coal, including:
1. Trucks transporting coal from the premises must be covered immediately after loading to prevent wind-blown emissions and spillage. The covering must be maintained until immediately before unloading the trucks.
2. The drop height when loading and unloading the trucks must be less than 1.5 metres.
3. The moisture content of the material transported must be at least 2%.
4. There must be a truck wheel wash before any truck used to haul coal leaves the mine or the destination to ensure that truck is clean and free of loose material.
5. All trucks used to haul coal from the site must be compliant with Euro VI standards for heavy vehicle emissions.

SUBMISSION ON CLARENCE COAL (MOD 4)

Dear Sir/Madam,

Thank you for the opportunity to comment on Centennial Coal’s application to modify conditions of consent for the Clarence Colliery to increase the total allowable coal haulage off-site by road to the Mount Piper Power Station by 100,000 tonnes until 31 December 2020.

I am very concerned about the impact of heavy diesel truck movements, mining and coal-fired power on air pollution and the health of residents in Lithgow and surrounding areas. Although the direct emissions from this proposal are relatively small, the proposal will increase air pollution and must be considered in the context of the cumulative emissions load in the region.

Air pollution is a serious issue in Lithgow and is harming people’s health

In the Lithgow region there are several significant sources of fine particle pollution, including the Mt Piper power station and local mines, including Centennial’s Springvale and Clarence collieries. According to data from the National Pollutant Inventory, in 2017-18 there were 395,700 kg of fine particles emitted from these three sources alone, including 61,000 kg of ultra-fine particles less than 2.5um.

The NSW Environment Protection Authority has identified fine particle pollution as a priority due to the adverse impacts on health, particularly for the elderly, children and those with existing health conditions, such as heart or lung disease or asthma.

Air pollution is currently not adequately monitored in the Lithgow area

Unfortunately, it is not possible to accurately assess the impact all this accumulated air pollution is having on the health of residents in Lithgow and the surrounding region. This is because there is currently no National Association of Testing Authorities-accredited, continuous air-quality monitoring station in the Lithgow area as part of the NSW Government's statewide air-quality monitoring network. However, in comparable regions such as Muswellbrook and Singleton, near the Bayswater and Liddell coal-fired power stations, publicly available data shows these areas regularly breach national air-quality standards for fine particles.

Transportation of coal by road will add to the cumulative air pollution load

The proposed modification will result in an additional 30–56 daily movements of heavy diesel trucks through Lithgow. This is on top of the existing 50 truck movements per day associated with a similar modification granted in 2014 which has allowed 100,000 tonnes per year of coal haulage to the west. This will significantly add to the cumulative air pollution load through wheel-generated particulates on unsealed roads at either end of the journey and transferring and dumping coal into and out of trucks. The NSW EPA has also identified diesel exhaust emissions as a major source of fine particle pollution, as well as ozone-forming nitrogen-oxides and toxins.

Centennial should be required to ensure public air-pollution monitoring

Centennial Coal operates the Springvale and Clarence collieries, and supplies the coal for the Mt Piper power station, the largest emitter of fine-particle pollution in the region. Centennial has a responsibility to ensure health authorities and residents are better able to understand the cost to their health and wellbeing of air pollution and identify opportunities to mitigate the threat. This modification application is an opportunity to ensure Centennial Coal takes on this responsibility.

The monitoring stations should be publicly owned and operated as part of the NSW Government's statewide air-quality monitoring network. It is not good enough for the monitoring to be privately undertaken by the polluter. To ensure access, consistency and public confidence in the quality of the data being reported, Centennial Coal should be required to pay for the NSW Department of Planning and Environment to install, operate and maintain at least two permanent, NATA-accredited, continuous air-quality monitoring stations in the Lithgow area. These should monitor particles, sulphur dioxide, nitrogen oxides and ozone.

Best practice pollution reduction controls should be mandatory

The conditions of consent should require best-practice pollution reduction controls for the loading, transport and unloading of the coal, including:
1.Trucks transporting coal from the premises must be covered immediately after loading to prevent wind-blown emissions and spillage. The covering must be maintained until immediately before unloading the trucks.
2.The drop height when loading and unloading the trucks must be less than 1.5 metres.
3.The moisture content of the material transported must be at least 2%.
4.There must be a truck wheel wash before any truck used to haul coal leaves the mine or the destination to ensure that truck is clean and free of loose material.
5.All trucks used to haul coal from the site must be compliant with Euro VI standards for heavy vehicle emissions.


--------------------------------------------------------------------------------

SUBMISSION ON CLARENCE COAL (MOD 4)
Dear Sir/Madam,
Thank you for the opportunity to comment on Centennial Coal’s application to modify conditions of consent for the Clarence Colliery to increase the total allowable coal haulage off-site by road to the Mount Piper Power Station by 100,000 tonnes until 31 December 2020.
I am very concerned about the impact of heavy diesel truck movements, mining and coal-fired power on air pollution and the health of residents in Lithgow and surrounding areas. Although the direct emissions from this proposal are relatively small, the proposal will increase air pollution and must be considered in the context of the cumulative emissions load in the region.
Air pollution is a serious issue in Lithgow and is harming people’s health.
In the Lithgow region there are several significant sources of fine particle pollution, including the Mt Piper power station and local mines, including Centennial’s Springvale and Clarence collieries. According to data from the National Pollutant Inventory, in 2017-18 there were 395,700 kg of fine particles emitted from these three sources alone, including 61,000 kg of ultra-fine particles less than 2.5um.
The NSW Environment Protection Authority has identified fine particle pollution as a priority due to the adverse impacts on health, particularly for the elderly, children and those with existing health conditions, such as heart or lung disease or asthma.
Air pollution is currently not adequately monitored in the Lithgow area.
Unfortunately, it is not possible to accurately assess the impact all this accumulated air pollution is having on the health of residents in Lithgow and the surrounding region. This is because there is currently no National Association of Testing Authorities-accredited, continuous air-quality monitoring station in the Lithgow area as part of the NSW Government's statewide air-quality monitoring network. However, in comparable regions such as Muswellbrook and Singleton, near the Bayswater and Liddell coal-fired power stations, publicly available data shows these areas regularly breach national air-quality standards for fine particles.
Transportation of coal by road will add to the cumulative air pollution load
The proposed modification will result in an additional 30–56 daily movements of heavy diesel trucks through Lithgow. This is on top of the existing 50 truck movements per day associated with a similar modification granted in 2014 which has allowed 100,000 tonnes per year of coal haulage to the west. This will significantly add to the cumulative air pollution load through wheel-generated particulates on unsealed roads at either end of the journey and transferring and dumping coal into and out of trucks. The NSW EPA has also identified diesel exhaust emissions as a major source of fine particle pollution, as well as ozone-forming nitrogen-oxides and toxins.
Centennial Coal should be required to ensure public air-pollution monitoring.
Centennial Coal operates the Springvale and Clarence collieries, and supplies the coal for the Mt Piper power station, the largest emitter of fine-particle pollution in the region. Centennial has a responsibility to ensure health authorities and residents are better able to understand the cost to their health and wellbeing of air pollution and identify opportunities to mitigate the threat. This modification application is an opportunity to ensure Centennial Coal takes on this responsibility.
The monitoring stations should be publicly owned and operated as part of the NSW Government's statewide air-quality monitoring network. It is not good enough for the monitoring to be privately undertaken by the polluter. To ensure access, consistency and public confidence in the quality of the data being reported, Centennial Coal should be required to pay for the NSW Department of Planning and Environment to install, operate and maintain at least two permanent, NATA-accredited, continuous air-quality monitoring stations in the Lithgow area. These should monitor particles, sulphur dioxide, nitrogen oxides and ozone.
Best practice pollution reduction controls should be mandatory.
The conditions of consent should require best-practice pollution reduction controls for the loading, transport and unloading of the coal, including:
1. Trucks transporting coal from the premises must be covered immediately after loading to prevent wind-blown emissions and spillage. The covering must be maintained until immediately before unloading the trucks.
2. The drop height when loading and unloading the trucks must be less than 1.5 metres.
3. The moisture content of the material transported must be at least 2%.
4. There must be a truck wheel wash before any truck used to haul coal leaves the mine or the destination to ensure that truck is clean and free of loose material.
5. All trucks used to haul coal from the site must be compliant with Euro VI standards for heavy vehicle emissions.

SUBMISSION ON CLARENCE COAL (MOD 4)

Dear Sir/Madam,

Thank you for the opportunity to comment on Centennial Coal’s application to modify conditions of consent for the Clarence Colliery to increase the total allowable coal haulage off-site by road to the Mount Piper Power Station by 100,000 tonnes until 31 December 2020.

I am very concerned about the impact of heavy diesel truck movements, mining and coal-fired power on air pollution and the health of residents in Lithgow and surrounding areas. Although the direct emissions from this proposal are relatively small, the proposal will increase air pollution and must be considered in the context of the cumulative emissions load in the region.

Air pollution is a serious issue in Lithgow and is harming people’s health

In the Lithgow region there are several significant sources of fine particle pollution, including the Mt Piper power station and local mines, including Centennial’s Springvale and Clarence collieries. According to data from the National Pollutant Inventory, in 2017-18 there were 395,700 kg of fine particles emitted from these three sources alone, including 61,000 kg of ultra-fine particles less than 2.5um.

The NSW Environment Protection Authority has identified fine particle pollution as a priority due to the adverse impacts on health, particularly for the elderly, children and those with existing health conditions, such as heart or lung disease or asthma.

Air pollution is currently not adequately monitored in the Lithgow area

Unfortunately, it is not possible to accurately assess the impact all this accumulated air pollution is having on the health of residents in Lithgow and the surrounding region. This is because there is currently no National Association of Testing Authorities-accredited, continuous air-quality monitoring station in the Lithgow area as part of the NSW Government's statewide air-quality monitoring network. However, in comparable regions such as Muswellbrook and Singleton, near the Bayswater and Liddell coal-fired power stations, publicly available data shows these areas regularly breach national air-quality standards for fine particles.

Transportation of coal by road will add to the cumulative air pollution load

The proposed modification will result in an additional 30–56 daily movements of heavy diesel trucks through Lithgow. This is on top of the existing 50 truck movements per day associated with a similar modification granted in 2014 which has allowed 100,000 tonnes per year of coal haulage to the west. This will significantly add to the cumulative air pollution load through wheel-generated particulates on unsealed roads at either end of the journey and transferring and dumping coal into and out of trucks. The NSW EPA has also identified diesel exhaust emissions as a major source of fine particle pollution, as well as ozone-forming nitrogen-oxides and toxins.

Centennial should be required to ensure public air-pollution monitoring

Centennial Coal operates the Springvale and Clarence collieries, and supplies the coal for the Mt Piper power station, the largest emitter of fine-particle pollution in the region. Centennial has a responsibility to ensure health authorities and residents are better able to understand the cost to their health and wellbeing of air pollution and identify opportunities to mitigate the threat. This modification application is an opportunity to ensure Centennial Coal takes on this responsibility.

The monitoring stations should be publicly owned and operated as part of the NSW Government's statewide air-quality monitoring network. It is not good enough for the monitoring to be privately undertaken by the polluter. To ensure access, consistency and public confidence in the quality of the data being reported, Centennial Coal should be required to pay for the NSW Department of Planning and Environment to install, operate and maintain at least two permanent, NATA-accredited, continuous air-quality monitoring stations in the Lithgow area. These should monitor particles, sulphur dioxide, nitrogen oxides and ozone.

Best practice pollution reduction controls should be mandatory

The conditions of consent should require best-practice pollution reduction controls for the loading, transport and unloading of the coal, including:

Trucks transporting coal from the premises must be covered immediately after loading to prevent wind-blown emissions and spillage. The covering must be maintained until immediately before unloading the trucks.
The drop height when loading and unloading the trucks must be less than 1.5 metres.
The moisture content of the material transported must be at least 2%.
There must be a truck wheel wash before any truck used to haul coal leaves the mine or the destination to ensure that truck is clean and free of loose material.
All trucks used to haul coal from the site must be compliant with Euro VI standards for heavy vehicle emissions.

SUBMISSION ON CLARENCE COAL (MOD 4)

Dear Sir/Madam,

Thank you for the opportunity to comment on Centennial Coal’s application to modify conditions of consent for the Clarence Colliery to increase the total allowable coal haulage off-site by road to the Mount Piper Power Station by 100,000 tonnes until 31 December 2020.

I am very concerned about the impact of heavy diesel truck movements, mining and coal-fired power on air pollution and the health of residents in Lithgow and surrounding areas. Although the direct emissions from this proposal are relatively small, the proposal will increase air pollution and must be considered in the context of the cumulative emissions load in the region.

Air pollution is a serious issue in Lithgow and is harming people’s health

In the Lithgow region there are several significant sources of fine particle pollution, including the Mt Piper power station and local mines, including Centennial’s Springvale and Clarence collieries. According to data from the National Pollutant Inventory, in 2017-18 there were 395,700 kg of fine particles emitted from these three sources alone, including 61,000 kg of ultra-fine particles less than 2.5um.

The NSW Environment Protection Authority has identified fine particle pollution as a priority due to the adverse impacts on health, particularly for the elderly, children and those with existing health conditions, such as heart or lung disease or asthma.

Air pollution is currently not adequately monitored in the Lithgow area

Unfortunately, it is not possible to accurately assess the impact all this accumulated air pollution is having on the health of residents in Lithgow and the surrounding region. This is because there is currently no National Association of Testing Authorities-accredited, continuous air-quality monitoring station in the Lithgow area as part of the NSW Government's statewide air-quality monitoring network. However, in comparable regions such as Muswellbrook and Singleton, near the Bayswater and Liddell coal-fired power stations, publicly available data shows these areas regularly breach national air-quality standards for fine particles.

Transportation of coal by road will add to the cumulative air pollution load

The proposed modification will result in an additional 30–56 daily movements of heavy diesel trucks through Lithgow. This is on top of the existing 50 truck movements per day associated with a similar modification granted in 2014 which has allowed 100,000 tonnes per year of coal haulage to the west. This will significantly add to the cumulative air pollution load through wheel-generated particulates on unsealed roads at either end of the journey and transferring and dumping coal into and out of trucks. The NSW EPA has also identified diesel exhaust emissions as a major source of fine particle pollution, as well as ozone-forming nitrogen-oxides and toxins.

Centennial should be required to ensure public air-pollution monitoring

Centennial Coal operates the Springvale and Clarence collieries, and supplies the coal for the Mt Piper power station, the largest emitter of fine-particle pollution in the region. Centennial has a responsibility to ensure health authorities and residents are better able to understand the cost to their health and wellbeing of air pollution and identify opportunities to mitigate the threat. This modification application is an opportunity to ensure Centennial Coal takes on this responsibility.

The monitoring stations should be publicly owned and operated as part of the NSW Government's statewide air-quality monitoring network. It is not good enough for the monitoring to be privately undertaken by the polluter. To ensure access, consistency and public confidence in the quality of the data being reported, Centennial Coal should be required to pay for the NSW Department of Planning and Environment to install, operate and maintain at least two permanent, NATA-accredited, continuous air-quality monitoring stations in the Lithgow area. These should monitor particles, sulphur dioxide, nitrogen oxides and ozone.

Best practice pollution reduction controls should be mandatory

The conditions of consent should require best-practice pollution reduction controls for the loading, transport and unloading of the coal, including:

Trucks transporting coal from the premises must be covered immediately after loading to prevent wind-blown emissions and spillage. The covering must be maintained until immediately before unloading the trucks.
The drop height when loading and unloading the trucks must be less than 1.5 metres.
The moisture content of the material transported must be at least 2%.
There must be a truck wheel wash before any truck used to haul coal leaves the mine or the destination to ensure that truck is clean and free of loose material.
All trucks used to haul coal from the site must be compliant with Euro VI standards for heavy vehicle emissions.

Council considers the Environmental Assessment adequately highlights the relevant issues, and has no objection to the project subject to Council’s original conditions remaining on the consent.
A supplementary submission from Council may be required upon a report being presented at the next Council meeting on 24 June 2019.

To whom it may concern,

I would like to take this opportunity to object to the proposal submitted by Centennial Coal to increase heavy truck movements through the Lithgow LGA.

My objection is based around the increasingly unsafe nature of using a bicycle in the Lithgow LGA.

As a person who uses my bicycle for transport I am finding it increasingly difficult to cycle due to the constant increase in truck movements in our area. The roads that are affected are major highways and town residential streets. I, and others, routinely cycle between Wallerawang and Lithgow, for work, shopping and health.

Whilst the increase in truck traffic is from my perspective anecdotal, it is very real and this noticeable increase of heavy traffic is a deterrent to encouraging people to use the bicycle for transport.

You would be aware that the Lithgow LGA has a higher rate of obesity than the state average. How do we get people out of their cars and engaging in physically active transport if Government’s and private companies continually encourage more and more trucks on the roads?

The route currently used by the trucks transporting from Clarence to MPPS travel past three Primary Schools. How does your Department and Centennial Coal plan to assist with ensuring ‘safe routes to school’?

Any increase in the number of heavy trucks travelling through Lithgow is in my view extremely short sighted and can/will only make the environment of the town worse. Lithgow Council has over the years attempted to improve the town and bring investment. Having more and more heavy trucks is not in line with improving the town’s environment.

I am disappointed to read in the document on page 29 “ due to the negligible traffic impact associated with the proposed modification, no additional traffic management or mitigation measures for the local and regional road network have been proposed.” The social impact risk is deemed moderate.

My question to your department is “ how are you going to ensure that the increase in truck movements will not negatively impact travelling by bicycle along these routes “?

I hope that you will consider the needs of vulnerable road users when reviewing this development application.

Refer to attachment

I’m am writing to object to Clarence Colliery Modification DA 504-00 MOD 4.
I object for the following reasons; 1.The roads are narrow and not suited to additional heavy truck movements.
2. I travel this road and I feel there is an increased risk of accidents.
3. Increased movement of heavy trucks through residential areas.
4. Increased risk to the environment.
5. The steep descent again adding to the risk of an accident.
6. Increased coal production at the mine will place additional pressure on the
Environment.

Overall I believe this application should be rejected as it posses an increased risk to road users, residents and the environment.

SUBMISSION ON CLARENCE COAL (MOD 4)

Dear Sir/Madam,

Thank you for the opportunity to comment on Centennial Coal’s application to modify conditions of consent for the Clarence Colliery to increase the total allowable coal haulage off-site by road to the Mount Piper Power Station by 100,000 tonnes until 31 December 2020.

I am very concerned about the impact of heavy diesel truck movements, mining and coal-fired power on air pollution and the health of residents in Lithgow and surrounding areas. Although the direct emissions from this proposal are relatively small, the proposal will increase air pollution and must be considered in the context of the cumulative emissions load in the region.

Air pollution is a serious issue in Lithgow and is harming people’s health

In the Lithgow region there are several significant sources of fine particle pollution, including the Mt Piper power station and local mines, including Centennial’s Springvale and Clarence collieries. According to data from the National Pollutant Inventory, in 2017-18 there were 395,700 kg of fine particles emitted from these three sources alone, including 61,000 kg of ultra-fine particles less than 2.5um.

The NSW Environment Protection Authority has identified fine particle pollution as a priority due to the adverse impacts on health, particularly for the elderly, children and those with existing health conditions, such as heart or lung disease or asthma.

Air pollution is currently not adequately monitored in the Lithgow area

Unfortunately, it is not possible to accurately assess the impact all this accumulated air pollution is having on the health of residents in Lithgow and the surrounding region. This is because there is currently no National Association of Testing Authorities-accredited, continuous air-quality monitoring station in the Lithgow area as part of the NSW Government's statewide air-quality monitoring network. However, in comparable regions such as Muswellbrook and Singleton, near the Bayswater and Liddell coal-fired power stations, publicly available data shows these areas regularly breach national air-quality standards for fine particles.

Transportation of coal by road will add to the cumulative air pollution load

The proposed modification will result in an additional 30–56 daily movements of heavy diesel trucks through Lithgow. This is on top of the existing 50 truck movements per day associated with a similar modification granted in 2014 which has allowed 100,000 tonnes per year of coal haulage to the west. This will significantly add to the cumulative air pollution load through wheel-generated particulates on unsealed roads at either end of the journey and transferring and dumping coal into and out of trucks. The NSW EPA has also identified diesel exhaust emissions as a major source of fine particle pollution, as well as ozone-forming nitrogen-oxides and toxins.

Centennial should be required to ensure public air-pollution monitoring

Centennial Coal operates the Springvale and Clarence collieries, and supplies the coal for the Mt Piper power station, the largest emitter of fine-particle pollution in the region. Centennial has a responsibility to ensure health authorities and residents are better able to understand the cost to their health and wellbeing of air pollution and identify opportunities to mitigate the threat. This modification application is an opportunity to ensure Centennial Coal takes on this responsibility.

The monitoring stations should be publicly owned and operated as part of the NSW Government's statewide air-quality monitoring network. It is not good enough for the monitoring to be privately undertaken by the polluter. To ensure access, consistency and public confidence in the quality of the data being reported, Centennial Coal should be required to pay for the NSW Department of Planning and Environment to install, operate and maintain at least two permanent, NATA-accredited, continuous air-quality monitoring stations in the Lithgow area. These should monitor particles, sulphur dioxide, nitrogen oxides and ozone.

Best practice pollution reduction controls should be mandatory

The conditions of consent should require best-practice pollution reduction controls for the loading, transport and unloading of the coal, including:

Trucks transporting coal from the premises must be covered immediately after loading to prevent wind-blown emissions and spillage. The covering must be maintained until immediately before unloading the trucks.
The drop height when loading and unloading the trucks must be less than 1.5 metres.
The moisture content of the material transported must be at least 2%.
There must be a truck wheel wash before any truck used to haul coal leaves the mine or the destination to ensure that truck is clean and free of loose material.
All trucks used to haul coal from the site must be compliant with Euro VI standards for heavy vehicle emissions.

Traffic along the Great Western Highway through to Sydney is already strained. It is time to look to a different future and stop putting resources into antiquated systems. The future is now.

I would rather see this development funding going towards alternative energy, and cleaner air, not expanding an a dying industry that creates more problems than solutions.