Port Waratah Coal Services - Terminal 4

NSW Government - Planning and Infrastructure

I am writing to express my support for the T4 Project. I have reviewed both the Environmental Impact Statement and Response to Submissions and believe that the study is an accurate representation of the project and one that has considered potential environmental, social and economic impacts.

With tightening economic conditions, I find it reassuring that PWCS are willing to invest in local communities and provide employment opportunities and long term job security.

I believe that the project offers a balanced approach to the environment with significant financial contributions to both local and state economies and I welcome the approval of this project.

I have worked within the resource sector within Australia and predominantly the Hunter Valley for almost 20 years. In that time I have personally experienced a rapid evolution to make the Hunter Coal Chain a sustainable and globally competitive supply chain.

The continued need for thermal coal within the industrial and domestic needs of expanding countries is undeniable. To not consider the future world energy consumption, including growth in thermal coal on a scale, that we have not experienced as a society over the next 30-50 years could be considered naive.

I fully support the implementation of high standard infrastructure and employment of best practice environmental stewardship to ensure the least amount of industrial and carbon footprint possible, I maintain that this can be done inconjunction with industry expansion and this has been demonstrated not only within the coal sector to date. I too have younf family and consider the future and believe this balance is an imperative.

The benefits for building and initiating T4 when global demand requires is an absolute neccesity for the economic good of the Hunter, NSW and the national GDP. Whilst exportation of services and other goods is important to a balanced Austrlian economy moving forward, it is absurd to think that this can be done without expansion to existing natural resource exportation.

PWCS have demonstrated benchmark setting environmental and safety standards over the life of operation, and have not only maintained, but fostered an improved the social licence with the community for coal loading and exportation in the Port of Newcastle. I have and will continue to support PWCS in their bid to establish the next critical step in developmnet of Coal Chain capacity in prepartion for this region to sieze upon the opportunity and demonstratably do so, in world class fashion.

I undoubtley support the construction of the T4 facility by PWCS and unashamedly acknowldge that I am and aim to continue to be directly employed within this industry, arguably the lifeblood of the Hunter.

I strongly object to the proposal for another coal loader in Newcastle.

The increase in open cut mines in the Hunter Valley particularly near me at Bulga is distressing. The continuous noise, dust and blasting is not what the residents of the Hunter Valley should be experiencing. The construction of an additional coal loader will place pressure on the Government and the coal industry to increase coal production by additional mines or the extension of existing mines. This approach will continue the very evident destruction of the Hunter Valley and continue the major detrimental impacts on our health and the childrens' health.

This additional coal loader must not be approved. The Government has a duty of care to the residents of the Hunter Valley and elsewhere and at present this duty of care is not evident.

Leslie Krey

For the development of the area

Lock the Lake opposes the proposed fourth terminal on social, environmental and economic grounds.

Further investment in the coal industry in the face of overwhelming evidence of the health impacts from coal dust and mining is poor policy. We should be looking to move away from sourcing energy from fossil fuels. Energy from renewable sources is the future and where our region should be positioning itself to best take advantage of a clean energy future.

The wealth of potential jobs is a prime reason for moving away from mining and the limited jobs the industry provides.

The environmental destruction needed to build this facility is unacceptable.

The impact on people's health must be a prime consideration. Newcastle and Hunter residents are exposed to high levels of coal dust already. Putting more dust in the air is unacceptable.

The mining industry is not the community's friend and provides little benefit. The alternative is for further investment and support in the renewable energy sector. The potential benefits from renewables are many and include more employment, less pollution and significantly less community and environmental impact. To prioritise fossil fuel projects over renewables is objectionable.

The scientific community agrees that burning coal is warming the planet. It is beyond time to act on climate change. For this reason alone T4 should be blocked.

It is time to listen to the environment and listen to the community rather than bow to the vested interests of big corporations who receive massive government subsidies but still send up to 80% of their profits off shore. At this moment in history, private companies should not be allowed such a massive investment in an outmoded industry, an investment requiring decades of operating at full capacity.

We need to look to the future and transition to renewable energy and move away from a technology thought a good idea 200 years ago.

I am a long term resident (>22 years) of the Newcastle region. I was born in this region, I own a home in the suburb of Shortland and I have been educated at the University of Newcastle. I believe very strongly that the Newcastle community needs to embrace development to grow the city and to ensure long term prosperity for its residents.

Over many years PWCS has been operating coal terminals at Carrington and on Kooragang Island. During this time PWCS has developed itself as a valuable corporate citizen through charity donations and local community participation. In addition to this, PWCS has also provided support to local apprentices and university students who wish to gain valuable industry experience. Allowing the T4 project to proceed will allow this record to continue into the future.

I strongly support the proposed T4 project for a number of key reasons:
* The project will provide thousands of jobs during construction and hundreds of additional permanent jobs during operation. This will support many local families and also bring many new families to the region. This will be a good development for the overall community.
* The types of jobs that this project will provide are highly skilled professional jobs. This includes tradespeople, engineers, supervisors, machinery operators and technicians.
* The construction and operation of the T4 site will also provide many opportunities for local businesses to contract to, bid for and participate in the economic activity which will be generated. This will increase the positive impact on the Newcastle community and economy.
* The project will improve the current condition of the Kooragang Island site by capping the contamination which was dumped many decades ago. This will allow Newcastle residents to have confidence in their long term health and wellbeing
* The project is well designed, using world's best design and operational practices for coal handling terminals with considerable measures put in place to ensure noise, water and dust impacts are kept to a minimum and well within the criteria set by government.

I believe that overall, the negative aspects of the T4 project which are commonly touted associated with this project are largely exaggerated. As someone who lives close to Kooragang Island and the Hunter Valley coal chain I am not impacted on by freight movements or by construction or operational noises. I have not experienced any evidence of coal dust or other issues which are often blamed on the coal industry despite living quite close to the operations.

Overall, I hope that you consider the proposal on its merits and consider the many benefits of the project. I also hope that the impacts associated with this project are read in the context of quantitative evidence as opposed to qualitative opinion and the relevant government standards which have been set.

Thank you.

Name withheld.
Islington, NSW

Thank you for the opportunity to respond to this unwanted development proposal on the Port of Newcastle.

I made a previous submission to the proposal numbered C375 and do not feel that my objections were adequately answered, or that the Terminal 4 proposal is any more acceptable in its current version. I still do not wish to see this development proceed and ask that it be rejected and better use be made of this land - most importantly leaving the remnant habitats in tact.

And before I begin to address some of my specific objections to T4, I would like you inform the assessor that: as a community member and someone who is concerned about the stability of the earth's climate, and the health of my local environments; I am extremely tired of my time, and energy being taken up responding to and campaigning against proposals such as this being put forth by the outdated coal industry. There is a barrage of planning changes and inappropriate development proposals that require response from concerned citizens such as myself, and it is an immense drain on my productivity and that of civil society. The people of Newcastle and the Hunter have made their voices loud and clear: T4 is outdated, not wanted and enough is enough for coal. Please bury this proposal.

I will use the numerical references applied to my submission in the T4 Project: Response to submissions and preferred project report Sept 2013. Appendix A Summary. Submission C375.

Classified as "GHG/climate change" summarised as:
C375.10 Contradicts other national efforts to mitigate climate change.
I do not accept the premise that the off-shore emissions being generated from the T4 site are not considered as part of this proposal. Global warming is now happening faster than forecasted by scientists with already devastating effects being seen in communities and ecologies around the world. On this basis I deem the T4 proposal irresponsible, inappropriate and dangerous to the stability of Earth's climate.
The greenhouse pollution from coal proposed to be exported through T4 would be more than 300 million tonnes per year - more than every power station and vehicle in Australia combined, or put another way - this equals this equals 30% of Australia's total annual GHG emissions and of its own, very much higher than many countries on Earth.
The International Energy Agency predicts that to limit global warming to under 2 degrees Celsius, global coal demand must peak in 2016,[1] at least a year before PWCS indicates T4 will begin operation.
The burning of an additional 70Mt of coal a year will add about 174Mt of carbon dioxide to the atmosphere. Although not part of Australia's formal commitments under the UN climate change convention (UNFCCC),


Classified as "Justification" summarised as:
C375.1 Stand to be left with stranded assets as the world moves away from coal. S14.2
C375.4 Trigger to build, ie capacity shortfall. Is not substantiated in the EA. S14.2

Different references can be cherry picked on global economic and energy trends, but the facts remain that climate change is real, burning coal is the single biggest contribution to global warming, and that any responsible Government and society is right now, moving away from installing new coal fired energy generation at this critical point in history. Meanwhile renewable energy generation is growing exponentially and the Port of Newcastle could instead see new appropriate developments. I would not like to see this site sterilised for the inappropriate use that is T4.

Goldman Sachs suggests that coal will never recover from its current downturn, expecting average annual growth of one per cent b 2013-17, compared to seven per cent in 2007-12. (Coal's crippling outlook, Climate Spectator. T.Edis) They suggest that Australia's total thermal coal exports in 2017 will only amount to 194Mt; 92 per cent of currently already-approved capacity. Exxon Mobil (The Outlook for Energy: A view to 2014) suggests global coal demand will peak in 2025 and decline thereafter. BP (Energy Outlook 2030) suggests that coal's recent rapid gain in share will start to reverse soon, with a trend decline evident by 2020.

Coal is by far the Port of Newcastle's largest trade commodity, representing around 95% of the total port throughput in mass tonnes and $20 billion in 2010-11, half of which is to Japan. The US Energy Information Agency (EIA) suggests that "Although the nuclear power plant shutdowns after the Fukushima disaster necessitate an increase in coal use in the near term, a shift toward renewable energy and natural gas for electricity generation weaken electric power sector demand for coal in the long run. Japan is currently the world's second-largest steel producer, but its steel production declines after 2020 as its population and domestic demand both decline." (US Energy Information Admin 2013 International Energy Outlook)



Classified as "Consultation/planning and policy" summarised as:
C375.2 Aspirations of Newcastle people for future direction of the port have not been assessed. There is no port, regional or economic futures plan.
There has been no change in this situation since the last version of the T4 proposal, with no planning or community consultation on the future of the Port of Newcastle in its entirety. In fact there has been a worsening of the situation and further disenfranchisement of the community with the sudden announcement that the Port of Newcastle is now up for sale, for a fraction of its long-term value.

It is not good enough to isolate this development for assessment within the margin of its footprint and out of context of the transformation of the port into one that is undiversified and heavily reliant on coal exports.
It is widely perceived by the Newcastle community that the approval of T4 serves only to artificially inflate the value of Newcastle Port Corporation and it's assets. This does not meet the broader public benefit test and is unacceptable.
Classified as "Coal industry" summarised as:
C375.6 Cumulative impact of coal industry in Hunter. Industry needs to be phased out and a sustainable renewable energy economy established. Asks what the long-term vision planning goal is.
As with climate change impacts and the cumulative impacts on the Port of Newcastle of the coal industry, I do not accept that this proposal is assessed in isolation. The many mines that would be established for throughput for this proposal and the quantity of land and water wasted in their operation has impacts way beyond the operations of T4 and are simply not addressed in the T4 proposal in the context of cumulative impacts.
There has been no change to the cumulative impact of the coal industry in the Hunter, already too much has been given over to coal, and further open cut coal mines will be resisted at every turn because this industry has gone too far. I recongnise that NSW and Federal planning laws are currently being stacked in the favour of coal mining operations, however that does not make this right.
This proposal does not fit in with my vision for the Hunter and Newcastle and is not sustainable in any way. Climate change is a reality and new industries need to be renewable.
Classified as "Air Quality" summarised as:
C375.7 Existing nuisance and health impacts of coal dust deposition on property from rail and coal loading facilities, particularly ultra-fine particles. Do not believe EA statement that T4 will not significantly affect surrounding air quality environment.
C375.8 Calls for more data on existing noise and dust emissions.
Newcastle and the Hunter Valley communities are impacted by dust from the mining, transport and stockpiling of coal. An additional 70Mt of coal exported will mean roughly 7,000 additional trips of 80 wagon trains between the Hunter mines and the port and back again, the capacity to export coal from an additional 8 to 10 mega mines and four new 1.5km coal stockpiles will substantially add to PM10 emissions in Newcastle and the Hunter Valley.
The RT/PPR air quality modelling continues to use 2010 as a base year. The submission to the T4 EA by NSW Health suggested that the EA should have included "a justification for assuming the PM10 levels in 2010 would be a realistic baseline for modelling future particulate levels or alternatively use, as a baseline, average levels over a longer period of time". This recommendation is ignored in the RT/PPR. During 2010 only one daily PM10 exceedence occurred and only one day did PM10 levels exceed 45ug/m3. In 2012, PM10 levels exceeded 45ug/m3 nine times (one of these was over 50ug/m3). Since 2005, when PM10 monitoring began in Newcastle, there have been 20 exceedences and 17 days above 45ug/m3. This is an average of 2.5 exceedences a year and 2.125 days over 45ug/m3; more than twice the number as in 2010. If an average baseline was used rather than 2010, the additional particle pollution associated with construction and operation of T4 could result in levels exceeding the national standard an average of 4.6 days a year.
The RT/PPR does not address air quality issues regarding particle pollution from rail transport returning to the Upper Hunter Valley. It has been shown clearly by CTAG that significant particle pollution is emitted by empty coal wagons returning to mines.
The RT/PPR continues to focus on air quality impacts within 20m of the rail corridor. Only about 100 homes fall within this area between Muswellbrook and Newcastle. There are over 30,000 people living within 500m of the rail corridor and 23,000 students attend 16 schools. The submission to the EA by NSW Health noted that the contribution of coal dust from coal trains beyond 20m from the rail corridor needs to be carefully considered. This recommendation is ignored in the RT/PPR.
The additional 7,000 return train movements and more than 700 return ship movements necessary to deliver 70Mt of coal to and from T4 will significantly increase diesel emissions in Newcastle and the Hunter. Diesel emissions are listed as a known carcinogen by the International Agency for Research on Cancer. The submission to the EA by NSW Health noted the failure of the EA to address diesel exhaust emissions and recommended a comprehensive health assessment. The RT/PPR ignores this recommendation.
Classified as "Ecology" summarised as:
C375.12 Habitat on the T4 site is critical and not able to be compensated for, as evidenced by the inadequate offsets proposed.
T4 will destroy 28ha of habitat known to support a population of the Nationally threatened Australasian bittern. The PPR proposes a highly experimental proposal to build and create habitat for both the migratory shorebirds and Australasian bittern. Though creation of new habitat has been seen to work for Green and golden bell frogs, it is not known if this will succeed for the birds. It is crucial that no clearing or construction begins before this offset site is established, and shown to be used by the species concerned. SEWPaC (The Commonwealth environment department) state in their submission to the EA that avoidance and mitigation are the primary strategies for managing potential impacts of a proposed action and while offsets can help to achieve long term conservation outcomes, they are not intended to make proposals with unacceptable impacts acceptable.
The proposal to acquire habitat areas at Brundee (near Nowra) and Ellalong Lagoon (near Cessnock) does nothing to offset impacts on species occurring in the Hunter estuary and only serves to further degrade their status on a broader scale. The proposed Ellalong Lagoon offset area as proposed in the EA, is 40km from the project area & is recognised as providing different habitat attributes to those occurring in the project area. The proposed Brundee offset area is located approx. 250km from the project area so cannot contribute to the conservation of biodiversity values present in the Hunter estuary or offset impacts on them. The proposed Tomago offset area currently provides suitable wetland habitat attributes so it's acceptance as an offset area as a result of the T4 project will further contribute to the net loss of wetlands in the Hunter estuary, which is already recognised as significant. Any proposed species habitat restoration in offset areas, such as Green and Golden Bell Frog habitat creation in the proposed Tomago offset area, should be demonstrated to be effective before any impacts on existing habitat areas should be considered.
The reservation of suitable habitat for respective species elsewhere does nothing to protect these species or ecological communities in the Hunter region where they are significant in a local and regional ecological context and only contributes further to overall loss across the distribution range or extinction risk. The same principles apply to migratory shorebirds, Australasian Bittern, threatened aquatic bird species, endangered ecological communities, other species and the loss of habitat generally as a result of the T4 project.
The Hunter Estuary supports 112 species of waterbirds and nationally and internationally listed threatened species, including the Australasian bittern (Botaurus poiciloptilus), listed as endangered under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act), green and golden bell frog (Litoria aurea), listed as vulnerable under the EPBC Act and known to breed in the Ramsar site, and the estuary stingray (Dasyatis fluviorum), listed as vulnerable on the IUCN Red List. Important habitats that will be impacted by T4 include Deep pond, Railway pond, Bittern pond and Swan pond.
The 23 hectare freshwater drought refuge Deep Pond supports at least 11 species of migratory recorded and above the threshold of 0.1 per cent of the Australian flyway population for three migratory shorebird species, with 600 sharp-tailed sandpiper, 450 curlew sandpiper, and 270 marsh sandpiper recorded. T4 will destroy 80 per cent of Deep Pond.
2.3 hectares of Swan Pond will be destroyed by T4. Swan Pond also exceeds the threshold of 0.1 per cent of the Australian flyway population for three migratory shorebird species, including records of 1,482 sharp-tailed sandpiper 152 marsh sandpiper and 78 common greenshank. Swan Pond is public land, owned and managed by the National Parks Service under Part 11 of the NSW National Parks and Wildlife Act. It is part of a highly successful long-term restoration project, the Kooragang Wetland Rehabilitation Project (KWRP) and has been the site of significant hours of volunteer labour by the local bird watching club

For the above and so many more reasons that I haven't time to outline, I object to the Terminal 4 proposal. It is not a modern approach to the development of our port or local economy and I would like to see better assessment requirements from the Department of Planning and better proposals such as renewable energy facilities from the public and corporate sectors.

Yours sincerely,
Name Withheld.
Islington NSW

Migratory shorebirds will be adversely affected by the proposed development of PWCS' Coal Terminal 4 where proposed rail lines will occupy shorebird habitat in Swan Pond on Ash Island. Migratory shorebirds and their habitats are supposedly protected under international agreements between the Australian government and the governments of China, Republic of Korea and Japan - yet the populations of these birds continue to decline due to the inexorable removal of their habitat. We point our fingers at the removal of habitat in the vital staging area of the Yellow Sea but we must protect habitat here too - after all the birds spend seven months of every year in Australia and depend on good foraging habitat to lay down adequate fat stores to complete the first long leg of their northward migrations. It is high time that Australia demonstrated protection of migratory shorebird habitat rather than continuing to approve developments that erode and remove existing habitat.

I object to this proposal.

I object to this proposal.

I object to this proposal for the health of my family and for its impacts on the stability of the climate.

I am grateful for the opportunity to respond to this very dangerous development proposal.

The T4 project will have significant and unacceptable impacts. I object to the fourth Newcastle coal terminal (T4) being approved and built. These unacceptable impacts include the following:

Climate Change:
The burning of an additional 70Mt of coal a year will add 174.2Mt of carbon dioxide to the atmosphere, equal to 30% of Australia's total annual GHG emissions.

Air pollution:
Newcastle and the Hunter Valley communities are impacted by dust from the mining, transport and stockpiling of coal. An additional 70Mt of coal exported will mean about an additional 7000 trips of 80 wagon trains between the Hunter mines and the port and back again per year, the capacity to export coal from an additional 8 to 10 mega mines and four new 1.5km coal stockpiles will substantially add to PM10 emissions in Newcastle and the Hunter Valley.

Particle pollution from trains:
The PPR does not address air quality issues from rail transport returning to the Upper Hunter Valley. PWCS continues to focus on air quality impacts within 20m of the rail corridor, but there are almost 30,000 people living within 500m of the rail corridor and 23,000 students attend 16 schools in that vicinity. The submission to the EA by NSW Health noted that the contribution of coal dust from coal trains beyond 20m from the rail corridor needs to be carefully considered, but this recommendation is ignored.

Air quality modelling flaws:
PWCS's air quality modelling continues to use 2010 as a base year. NSW Health has suggested that PWCS should have included "a justification for assuming the PM10 levels in 2010 would be a realistic baseline for modelling future particulate levels or alternatively use, as a baseline, average levels over a longer period of time". This recommendation is ignored in the PPR.

Employment:
The 120 Mt facility proposed in the EA identified no additional employment would result from its operation. The revised T4 project of 70Mt million of the RT/PPR is identified as employing 80 additional people. How is this possible?

Impacts on the The Hunter Estuary:

This Estuary supports 112 species of waterbirds and nationally and internationally listed threatened species, including the Australasian bittern (Botaurus poiciloptilus), listed as endangered under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).

Deep and Swan Ponds:

The Project will wipe out 80% of Deep Pond, which supports at least 11 species of migratory recorded and above the threshold of 0.1 per cent of the Australian flyway population for three migratory shorebird species, and will develop part of Swan Pond which supports three species in numbers that exceed the threshold of 0.1 per cent of the Australian flyway population.

Misuse of public conservation lands:

Swan Pond is public land, owned and managed by the National Parks Service under Part 11 of the NSW National Parks and Wildlife Act. It is part of a highly successful long-term restoration project, the Kooragang Wetland Rehabilitation Project (KWRP) and has been the site of significant hours of volunteer labour by the local bird watching club.

Justification for the project: There is no justification for the project. PWCS does not commit to building T4 and only suggests an indicative build date of 2015 with operation maybe in 2017. During a major downturn in global coal demand, Newcastle's approved coal export port capacity of 211Mt seems optimistic. Last year only 141Mt of coal was exported meaning 60Mt or 42 per cent of capacity was uninstalled.

Thank you for this opportunity to comment
Nicola Bowskill

I support PWCS' proposal. Newcastle and the Hunter Region will suffer if this development does go ahead as required to meet the demand of the mining industry.

I have grown up in the surrounding Newcastle area and currently live in the Newcastle area raising a young family with my wife. We were both fortunate to attend The University of Newcastle. Working in the coal mining industry and holding qualifications in finance and economics I understand well the contributions and opportunity both PWCS and its T4 Project bring to the region and State.
PWCS' T4 Project has been modified and has been designed well to be accommodated on disused contaminated industrial land west of the existing PWCS Kooragang Terminal. The coal mining industry relies upon PWCS to provide capacity and growth to meet their demand from overseas customers. The contribution that the industry makes to the region and State is enormous. PWCS is a large employer that not only offers security and employment for its employees and families but also training and opportunity for young people via Traineeships and Apprenticeships etc.
PWCS is planning to utilise and rehabilitate a contaminated industrial site whilst at the same time offering environmental offsets which I believe are more than sufficient.
For these reasons, my family and children I appreciate the contribution and opportunity PWCS and its T4 Project offer not just directly but indirectly via jobs, training, growth etc. I strongly support PWCS' T4 Project.

I refer to NSW Planning & Infrastructure's letter of 9 September 2013 with the Preferred Project Report for the proposed works at Power Waratah Coal Services Terminal 4.

NSW Resources & Energy do not wish to make a submission on this proposal.

Following planning approval, applications for a variation to pipeline licence area and a variation to easements will be required. This application shall be lodged by the pipeline licensee with NSW Resources and Energy.

I object to this project and believe that the community health, environmental
and socioeconomic impacts will have far outweigh any short term benefits it
is claimed it will deliver. These include:
1.Global warming: The burning of an additional 70Mt of coal a year will add
174.2Mt of carbon dioxide to the atmosphere. This is equal to 30% of
Australia's total annual GHG emissions. The International Energy Agency
predicts that to limit global warming to under 2 degrees Celsius, global coal
demand must peak in 2016, at least a year before PWCS indicates T4's will
begin operation.
2.The Hunter Estuary supports 112 species of waterbirds and nationally and
internationally listed threatened species, including the Australasian bittern
(Botaurus poiciloptilus), listed as endangered under the Environment
Protection and Biodiversity Conservation Act 1999 (EPBC Act).
3.Deep and Swan Ponds: The Project will wipe out 80% of Deep Pond, which
supports at least 11 species of migratory recorded and above the threshold of
0.1 per cent of the Australian flyway population for three migratory
shorebird species, and will develop part of Swan Pond which supports three
species in numbers that exceed the threshold of 0.1 per cent of the
Australian flyway population.
4.Misuse of public conservation lands: Swan Pond is public land, owned and
managed by the National Parks Service under Part 11 of the NSW National Parks
and Wildlife Act. It is part of a highly successful long-term restoration
project, the Kooragang Wetland Rehabilitation Project (KWRP) and has been the
site of significant hours of volunteer labour by the local bird watching
club.
5.Air quality: Newcastle and the Hunter Valley communities are impacted by
dust from the mining, transport and stockpiling of coal. An additional 70Mt
of coal exported will mean about an additional 7000 trips of 80 wagon trains
between the Hunter mines and the port and back again per year, the capacity
to export coal from an additional 8 to 10 mega mines and four new 1.5km coal
stockpiles will substantially add to PM10 emissions in Newcastle and the
Hunter Valley.
6.Air quality modelling flaws: PWCS's air quality modelling continues to
use 2010 as a base year. NSW Health has suggested that PWCS should have
included "a justification for assuming the PM10 levels in 2010 would be a
realistic baseline for modelling future particulate levels or alternatively
use, as a baseline, average levels over a longer period of time". This
recommendation is ignored in the PPR.
7.Particle pollution from rail transport: The PPR does not address air
quality issues from rail transport returning to the Upper Hunter Valley. PWCS
continues to focus on air quality impacts within 20m of the rail corridor,
but there are almost 30,000 people living within 500m of the rail corridor
and 23,000 students attend 16 schools in that vicinity. The submission to the
EA by NSW Health noted that the contribution of coal dust from coal trains
beyond 20m from the rail corridor needs to be carefully considered, but this
recommendation is ignored.
8.Justification for the project: There is no justification for the project.
PWCS does not commit to building T4 and only suggests an indicative build
date of 2015 with operation maybe in 2017. During a major downturn in global
coal demand, Newcastle's approved coal export port capacity of 211Mt seems
optimistic. Last year only 141Mt of coal was exported meaning 60Mt or 42 per
cent of capacity was uninstalled.
9.Employment: The 120 Mt facility proposed in the EA identified no
additional employment would result from its operation. The revised T4 project
of 70Mt million of the RT/PPR is identified as employing 80 additional
people. How is this possible? This dubious additional employment is not
explained.
10.Economics: PWCS's claimed economic benefits to the region are based on a
type of economic modelling the Australian Bureau of Statistics calls
"biased" and the Productivity Commission says is regularly "abused",
usually to overstate the economic importance of specific projects. The
original economic assessment of the T4 project suggests its annual operating
costs will only be between $45-50 million a year. Since that assessment was
made, the size of the project has "almost halved", so the amount of money
it will "inject" into the economy has presumably declined considerably.
For the terminal to achieve its economic potential, a lot more coal has to be
dug up and exported. This means that a lot more bush and agricultural land
needs to be turned into coal mines. A lot more coal trains need to pass
through Newcastle's suburbs. At the site of the proposal, a significant
wetland would have to be destroyed. And, of course, the extra coal being
burned would contribute to climate change. None of these costs are considered
in the economic assessment commissioned by PWCS. (Read Rod Campbell's
economic analysis here.)

I object to the T4 proposal. for the following reasons

1.70 million tons of green house gases will be released if the project goes
ahead

2. Significant habitat which sustains significant wild life will be
destroyed or compromised.. eg Swan Pond and Deep Pond and the Kooragang
Wetland.

3.Public land should not be turned over to the proponent as is proposed.

4. As train and tonnage increase and stockpiles build, so will PM10
emissions.
The comments of the Health Dept that there is a need to consider
monitoring outside the 20 metre distance from the rail line has been ignored.


5. Hunter Valley communities already suffer disruption to their communities,
poor air quality, alienation of productive lands and forests, concerns about
quality and quantity of water. The advent of 8 to 10 mines can only
exacerbate already unacceptable outcomes.

If this proposal is given the green light by PAC, then the commissioners must
bear the responsibility for being party to a process which has demonstrable
negative outcomes for many,many citizens of the Hunter Valley, Newcastle and
the world community.

It is not a banal comment to say that our children and their children will
bear the consequences of our decisions in this matter

I have a number of concerns, as a long term resident of Newcastle, and I
therefore believe that T4 shouldn't go ahead.

Firstly,

T4 is proposed to be built on the edge of the Hunter Estuary National Park,
18.5ha of which was removed from the Park to facilitate this project. The
project will also develop lands held by OEH under Part 11 of the National
Parks and Wildlife Act which is supposed to be managed for conservation. This
area includes Swan Pond.

This area is meant to be reserved for conservation of flora and fauna. The
Hunter estuary is an internationally recognised wetland protected by the
Ramsar Convention[2]. The estuary is already heavily impacted by industry. I
have been pleased that despite the industrial development alongside, many
species of bird, frog, mussel etc have flourished including a number of
endangered species found only in one or two other places.

How is it then possible to take lands owned and managed the National Parks
and Wildlife Act for industrial development? This seems highly unethical and
dubious to me. As a local rate payer and tax payer I find this particularly
offensive and suspect.

I have studied The offset strategy proposed by PWCS absolutely cannot
compensate for T4's proposed impacts.

Secondly,

I am particularly concerned about the worsening climate change disaster we
are causing. My children and grandchildren's lives are at stake.

The burning of an additional 70Mt of coal a year will add about 174Mt of
carbon dioxide to the atmosphere. Although not part of Australia's formal
commitments under the UN climate change convention (UNFCCC), this equals 30%
of Australia's total annual GHG emissions.

Realistically all our government agencies need to moving our culture and
economy away from fossil fuels to avoid the worst of this catastrophic
warming.

The International Energy Agency predicts that to limit global warming to
under 2 degrees Celsius, global coal demand must peak in 2016,[1] at least a
year before PWCS indicates T4 will begin operation. It is therefore highly
inappropriate to allow this type of unnecessary development to go ahead.

Thirdly,

The air and water pollution from coal mining and transport to feed the T4 is
unacceptable. It extracts a very heavy toll on the people who live near the
mines and the transport corridors.

Lastly,

There is absolutely no justification for the project.

It provides very few jobs, and these will be in an area shown to have an
unexplained cancer cluster. Not a job I would want!

Coal prices will continue to stagnate as
1. world concern about climate change grows and more climate change "events"
happen.
2. renewable energy sources continue to prove themselves a cheaper, more
reliable power source, with no risk, no pollution, and don't require foreign
exchange to import. New wind power is cheaper than coal now and in many
countries is cheaper than established coal power. Solar arrays that heat
water or salt can provide cheap 24/7 baseload power now.
3. divestment campaigns make more impact and concerns of the financial sector
about investing in potentially stranded assests.

Meanwhile coal exports at Newcastle are far less than existing capacity.

This focus on coal is very risky. The coal mines in the upper Hunter Valley
have been disastrous for a number of industries and this has resulted in a
loss of jobs in long term sustainable industries such as agriculture,
tourism, timber getting, vititculture and the horse industry. The loss of
these jobs, and damage to these industries is ignored when mining is
discussed. These impacts are not adequately offset by the few proposed
economic benefits of T4.

We risk Dutch disease due to the heavy reliance of the Port on coal exports.
We should be protecting the economic viability of the region by reading the
trends carefully, diversifying our industry and not giving in to the interest
of a few companies, wanting to inflate the value of the Newcastle Port
Corporation and therefore, Coal and Allied and Rio Tinto at a massive cost to
our environment.

To the Planning & Assessment Commission.

Re the Port Waratah Coal Services Terminal 4


I object to this project and believe the environmental, health, economic and political costs on the Newcastle and Hunter and NSW communities far outweigh any potential gains.

Please consider this short submission in which I outline my concerns:
Coal exports contribute to global warming:
The project will enable a significant increase the export of coal from the Port of Newcastle. The mining, transport and combustion of this coal will contribute to global warming with consequent impacts on environments and communities globally. Coal exported from T4 will be an export that comes
back to bite us, as can be clearly seen from the recent bushfires.

A transition towards a sustainable and `moral economy' is needed: In their book, Right Relationship, Brown and Garver (2009), discusses the urgent need for achieving an economy that is recognised to be a subsidiary of the overall ecosystem of the planet. They address key questions regarding the
purpose, function, appropriate size, fairness, and governance of a world economic system and propose new ideas to place our economy in correct relationship with the Earth's ecosystem. Expansion of industries that contribute to climate change clearly does not fit within a 'moral economy'.
Currently the nature of the Hunter's economy shifts environmental, social and economic risks from the relatively wealthy and safe communities of the Hunter and Australia onto the most vulnerable communities in the world, e.g. in low lying coastal areas.

Rather than further investment in coal and climate change, governments, industry and communities should be assisting a just transition of the Hunter economy off fossil fuels, which are clearly not compatible with a sustainable economy to an economy that enhances environmental and social well-being
locally and globally.

Government should facilitate a shift in investment from fossil fuels to other more sustainable industries: While it might be argued that private finance should be allowed to go wherever a profit can be made or suffer the consequences if they make a loss, many Australian local governments, small investors and families have investments in the fossil fuel industry, either directly or through superannuation funds. Given the uncertainty of coal markets, and the firesale of many coal mines now underway across Australia, including the
Hunter, allowing the T4 project to go ahead puts investor funds at risk.

The NSW Government has a responsibility to protect investors, and should not approve T4, as it is a potentially risky investment. Governments should instead provide incentives to direct investment away from risky and outdated
industries, such as T4, towards the industries of the future that would help the Hunter and NSW develop an economy that is not based on harmful commodities and which secure the economic future for the region.

Wasteful investment in a potentially stranded asset: The T4 is wasteful investment that is very likely to become a tranded asset. There is a decline in the economic viability of coalmines and this is likely to become more pronounced over the next decade as a steady decline in coal demand from overseas markets for Hunter thermal coal is likely.

A stranded asset is wasteful investment for private companies and financiers, but it is also a more general issue for the general public if, as is likely, significant public funds are spent on infrastructure to support T4. These
will be wasted funds that could be better used for other purposes such as health, education, environmental repair, or investment in clean energy, among
other things.

T4 will exacerbate the displacement of rural communities by mining: The expansion of coal exports from T4 will increase the social impacts of mining coal on rural life and on many communities in the Hunter and nearby regions that have been well documented. These include farming land being
lost as it has been acquired for mining purposes leading to the closure of many farms and resulting loss of farming families to the region, loss of knowledge and general decline in historic farming sectors of the regional economy.

Indeed, there are entire villages such as Warkworth and Ravensworth that have now disappeared because of the encroachment of mines. Other villages such as Camberwell, and many farms including the Hunter's historic horse- breeding and wine-growing industries are under threat. This threatens to add to the loss of social networks and the anxiety and stress for affected communities, business operators and families.

The expansion of coal mining facilitated by a T4 would exacerbate the financial stress felt by many farmers who, for example, now find it difficult to compete for labour with the higher wages paid to workers in the mining sector.

Health and air quality is threatened: I live directly downwind from the current coal terminals, and am already exposed to air pollution from these terminals. The T4 will increase the
volume of coal being transported, stockpiled and loaded and will increase air pollution exposure to me and my family in Newcastle, and to other people in Newcastle and the surrounding regions.

The impact of coal particles on public health is not fully known, and requires further investigation. It is likely that there is no safe level of exposure. Government has a responsibility to protect public health and reduce risk. A precautionary approach suggests that polluting industries
should be scaled back rather than expanded.

Harmful ecological impacts: Increased coal mining to feed the T4 will have ecological health impacts on mind landscapes, rivers, wetlands and biodiversity generally. Many of the areas affected directly and indirectly by the T4 project, including wetlands in the Hunter estuary, are vulnerable ecosystems, which provide a critical refuge for endangered species. Industrial development of these sites is likely to imperil the ecological viability of these ecosystems and diminish the biodiversity of the Hunter, while undermining Australia's responsibility as a global environmental citizen.

The mining industry claims a good record in environmental management but it is blatantly obvious to any person who can actually see the impacts on mining on landscapes and rivers that it is not, and cannot, successfully rehabilitate land that has been mined, and degraded.

Responsible planning should reduce these impacts rather than facilitate new developments with relatively short lifespans, of a few decades at best, but which will inevitably lead to long term and potentially irreversible environmental impacts.

There appears to be no credible process for measuring, and limiting, the cumulative impacts of mining, and no further development should be allowed to occur until it is clear that the cumulative impacts of mining are declining, and processes are in place to ensure that this occurs.

Spurious economics fails to properly account for costs and benefits: The claimed economic benefits of mining seem to be vastly over-stated by the industry, with employment figures in both mining and the T4 project grossly inflated through use of spurious input-output and multiplier modelling, and a
failure to apply contemporary and credible environmental economics approaches that acknowledge and measure social and environmental costs which traditionally are ignored in project assessments.

The economic benefits claimed are short-term only and accrue to a relatively small number of people over a relatively short timeframe. The economic modeling does not adequately include externalized economic costs, such as environmental and social impacts of mining and air quality
degradation on public health, loss of opportunity of using land designated for new mines to feed the T4 or use of Port of Newcastle land for alternative purposes.

If the economic impacts of climate change caused by the CO2 emissions attributable to the combustion of coal from T4 are considered, for example using data from the Stern Review on the Economics of Climate Change (2006), then the project would clearly be uneconomic in short and long-term timeframes.

Sustainability and equity in jeopardy: A proper accounting of the cumulative ecological, social and economic impacts
of mining and linked coal exports, including health and climate change impacts locally or globally, would clearly highlight the lack of sustainability of the T4 project.

The sustainability of mining-affected regions of the Hunter and surrounding region is jeopardised by current environmental protection and pubic health management processes.

The scale of mining and export from the region jeopardises local and global sustainability particularly when climate change impacts are considered.

Any credible assessment of the impact of T4 must consider global costs and benefits, as well as local as well as local costs and benefits. It must also consider long-term costs and benefits as well as short-term impacts. It must
also consider which people and sectors of society benefit and who pays the costs.

It is highly likely that a credible assessment would acknowledge that short term economic benefits will accrue to a relatively few people and corporations while major long-term costs will fall on many more people in the local region as well as people living in other places on the planet.

Ultimately, the issue is one of environmental justice - will the most vulnerable communities and future generations pay the costs while the most privileged enjoy the benefits? I hope the PAC has the wisdom to ensure that this is not the case.

For the reason above I object to the T4 project and believe the PAC should not approve it.

This submission is to make known my strong opposition to the proposal to build a fourth coal terminal in Newcastle. There are so many reasons why this is not a good idea that they will not all be detailed here but it is important to explain a little about my primary reason for opposing this proposal.

The main reason we do not need another coal terminal is that it is detrimental to the climate of the planet to continue to use energy sources that contribute to global warming. Despite the fact that the federal government has done their best to try to stigmatise any comments about the connection between the recent devastating fires in New South Wales and climate change, we do know that these fires are unprecedented and reliable expert sources are saying that we are likely to see more of these as climate change continues. Not only these, but other horrific, extreme, climate events have been occurring and are expected to increase in frequency as global warming continues. These events result in a huge cost in human grief and in monetary terms. Any claims for economic benefits from further coal export need to be weighed against these broader costs.

It is the height of stupidity to ignore climate change and there are no longer any grounds for claiming ignorance of the seriousness of the situation that humanity faces if we do not come to terms with this problem. Actions on the part of those in leadership roles that ignore this serious situation can
reasonably be seen to be to be ethically bankrupt and should, before too long, be seen as criminal.]

The burning of an additional 70Mt of coal a year will add 174.2Mt of carbon dioxide to the atmosphere; almost one third of Australia's total annual green house gas emissions. The International Energy Agency predicts that to limit
global warming to under 2 degrees Celsius, global coal demand must peak in 2016, at least a year before Port Waratah Coal Services indicates the new terminal will begin operation. It would be unconscionable to approve this
project given these facts alone.

There are important local ecological reasons not to go ahead with this project including the health of the Hunter River estuary and the wildlife there as well as misuse of public conservation lands.

Health issues are important locally and all along the coal chain with considerable social and economic cost resulting from illness caused by poor air quality resulting from coal movement.

A refusal of this proposal would be a gain for the health of the people, sustainable businesses and ecosystems of the region; would strike a blow in favour of the health of the global climatic systems and would make more
overall sense economically than an approval.