Port Waratah Coal Services - Terminal 4

"If we (Australians and other humans)want to avoid dangerous global temperature rise of 2 degrees or more we cannot burn 4/5 of the earth's reserves of fossil fuels.

Why would we then increase coal exports by building a 4th coal loader???? Unless we are suicidal it makes no sense. It is stupid, stupid stupid.

Please use your incredible engineering abilities to help develop Australia's RENEWABLE energy industry. We have so much potential to do so. Think solar thermal in place of coal mines for example.

Please please please. I am not suicidal plus I have children and I want them to have a livable world."

Residents like myself and my family who are in close proximity of coal stockpiling and loading facilities in and around the port of newcastle are tired of putting up with the noise, the emissions, and most importantly the dust from operations - not to mention the negative impact on the natural ecosystems. This includes the rail systems used to transport the material. Putting more infrastructure such as T4 into the same area will only make things worse. The opposite should be taking place - infrastructure should be moved. Facilities should be relocated an adequate distance from residential areas, and strict controls should be placed on dust and noise to protect residents (who are also taxpayers and voters) and limit the adverse impact on the enjoyment of their lives.

Why aren't coal wagons covered?
Why aren't stockpiles covered?
Why isn't coal infrastructure located at an appropriate distance from residential areas?

Coal loading infrastructure is adequate. It is crazy to add more huge infrastructure. Please stop with then facilitating the increase of coal mining and exports, the carbon dioxide liberated here and overseas creates unnecessarily increase in global warming. Our children will be unable to enjoy the world as we know it now.

I strongly oppose the proposal from Port Waratah Coal Services to build a fourth coal loader (T4) in Newcastle. I have no expertise in any field of science but I have kept myself informed on the issue while keeping myself objectively receptive to both sides of the argument. I have considered the economic, social and environmental dimensions and have I have come to the conclusion that the negative global and local impacts overwhelmingly outweighs the benefits.

I am personally aware of many arguments across all dimensions but there are a particular few arguments that I would like to elicit for my objection to the T4 proposal.

My arguments are firstly on a global level and secondly on a local level. On a global level, the proposal is at odds with the patently obvious imperative to down scale our fossil fuel dependency. The proposal essentially means an additional 70Mt, the capacity of the loader, will add 174.2 Mt of carbon dioxide to the atmosphere This is equal to 30% of Australia's total annual GHG emissions. In a time where we have widespread agreement that we need urgent action on climate change we should be de-investing in the fossil fuels and investing in appropriate technologies to create a diversified energy economy. This will mean that we will have to keep exporting coal for some time but definitely not increase the our output.

At the local level there are many communities that suffer their own particular negative impacts. Some of impacts are from dust pollution, noise pollution, and loss of amenity in mining communities. The impacts that I am directly affected by are inordinate noise pollution from trains and the coal loader. Even if I am not going to be affected by any more noise from another loader (though i fear I will) I wouldn't want other people in other suburbs to be subject to the amount of noise pollution that my neighbourhood endures.

The other negative impact for me is particle pollution from rail transport. With respect to this I ask why the Preferred Project Report continues to ignore the need to measure PM10 levels, the dangerous particles? I object the proposal of the PPR because it doesn't even address in any way the mitigation of the current pollution levels from train operation let alone the pollution levels from more trains.

I conclude that I object to the PPR proposal on the grounds that the weight of evidence of the negative impacts far outweighs the benefits that are argued for it.

"I object to this project and believe that the community health, environmental and socioeconomic impacts will 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.
Yours sincerely,

Glenn Winters"

Thank you for the opportunity to respond to this development proposal.
I object to the proposal.
Mining threatens our soils, our water, our land, our air and the future of agriculture in the Hunter Valley.
Increasing the coal capacity of the port will result in more coal mines being developed in the Upper Hunter Valley where I live.
The importance of Agriculture
Australia may be a large continent but the area of land and soils suitable for growing food is small in comparison. Our population is growing and the demand for food worldwide is growing. The population of the world is predicted to increase by 2 billion people between now and 2050. It is critical that we preserve our farming land for producing food. An extra two billion people will need significant resources to feed.
The Hunter Valley can become a food bowl to produce food to feed the growing population of the world. However, the expansion of coal threatens this.
Mining sterilises good faming land and replaces it with at best poor quality rehabilitated land that is no longer commercially viable for farming.
The Hunter Valley is blessed with rich farming soils. Where else is there a better area to grow food? The Upper Hunter is two hours to markets in Newcastle, four hours to markets in Sydney. Newcastle is well served by transport, road, air, rail and shipping.
So much is being written about Australia's next boom- Agriculture. We have the capacity in Australia to feed not only ourselves but a sizeable amount of South East Asia.
Mining is a once only use of land. No mined land has yet been shown to have been returned to its previous quality. Rehabilitated land is lacking in essential elements usually found in soil. For example, cattle grazed on rehabilitated land are stunted due to the lack of Copper in the soil.
Up until now, mined areas have been kept away from our rich soils and rivers. But the mining industry now threatens that richly productive farming land. Mining companies must not be allowed to mine our food producing land.
Coal mines now own close to fifty per cent of land subject to municipal rates in the Muswellbrook Shire. Coal mines are finding it difficult to find land in the Muswellbrook Shire for ecological offsets, as there is so little suitable land left. The ecological offsets chose end up being a poor match for the ecologies that are wiped out by mining operations.


Despite reducing capacity from 120Mt to 70Mt, Port Waratah Coal Services' (PWCS) Response to submissions and Preferred Project Report (RS/PPR) does not adequately address the issues raised by submissions to the Environmental Assessment (EA). The T4 project will have significant and unacceptable impacts. I therefore object to the fourth Newcastle coal terminal (T4) being approved and built. These unacceptable impacts include the following:
1. Global warming: 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. 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.
2. The Hunter wetlands: 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. The response to submissions does not address the conflict and possible illegality of using lands owned and managed under the National Parks and Wildlife Act for industrial development. We are aware that negotiations were underway to give or sell this land to the Port Corporation. No update on this process is provided. The Hunter estuary is an internationally recognised wetland protected by the Ramsar Convention[2]. The estuary is already heavily impacted by industry. The offset strategy proposed by PWCS cannot compensate for T4's proposed impacts.
3. Endangered species: 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.
a. Deep Pond: The 23 hectare freshwater drought refuge 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.
b. Swan 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.
c. Offsets: 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.
d. Green and Golden Bell Frog: The T4 project area covers a significant proportion of the extant (existing) Green and Golden Bell Frog habitat in the Hunter estuary and it is highly likely that the majority of the population in the project area will be adversely impacted due to removal of key habitat for this species. There is no certainty that the proposed management measures for Green and Golden Bell Frog within the T4 site or habitat creation at the proposed Tomago offset area will be effective in protecting the species in the region. Establishment of a research program is an adjunct to conservation and does little to conserve biodiversity in situ while habitat is being lost from direct impacts. Either the proposed mitigation measures should be implemented and demonstrated to be successful in preserving a viable population of this species in the Hunter estuary prior to any impacts on extant habitat areas or the precautionary principle should apply and key habitat areas be protected from any impacts.
e. Ramsar wetland values: Little has changed between the Environmental Assessment and the PPR in terms of the proposed degradation of Ramsar wetland values through the removal of existing estuarine habitat. Significant habitat is known to be present within the T4 project area and this cannot be adequately compensated by the proposed mitigation measures and offset strategies.
3. Ground and surface water: There is substantial uncertainty around the impacts of proposed ground and surface water management during construction and operation due to contamination issues or inherent differences in water quality between/within the site & surrounding habitats. The precautionary principle should apply to management of these aspects if certainty cannot be provided.
4. 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 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.
a. Number of PM10 exceedences: 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.
b. Particle pollution from rail transport: The RT/PPR does not address air quality issues 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.
c. Air pollution close to rail corridor: 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.
d. Diesel exhaust emissions from ships and coal trains. 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.
5. Socio economic impacts: T4 will generate some economic advantage but will also have significant impacts on existing Newcastle and Hunter businesses and communities. These impacts are not adequately offset by the proposed economic benefits of T4.
a. 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. During 2012, only 141Mt of coal was exported meaning 60Mt or 42 per cent of capacity was uninstalled.
b. 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.
c. Alternative industries: Exxon Mobil [3]suggests global coal demand will peak in 2025 and decline thereafter. BP[4] suggests that coal's recent rapid gain in share will start to reverse soon, with a trend decline evident by 2020. 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.[5] They suggest that Australia's total thermal coal exports in 2017 will only amount to 194Mt; 92 per cent of currently approved capacity. New industries will be required to replace coal in the near future. These industries will require export facilities that may include the T4 site.
d. Dutch disease and the economic risk of relying on coal exports: 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."[6]
e. Privatisation of Newcastle Port: The heavy reliance of the Port on coal exports may give rise to unique diversification risks. [7] It is acknowledged that the value of Newcastle Port Corporation will increase substantially after approval of T4. But approving a major development so as to artificially inflate the value of an asset cannot be justified when it fetters future discretion on available limited port land and the opportunities this land may present to those alternative proposals.


Yours Sincerely
John George Kaye
20 November 2013

________________________________________
[1] IEA, World Energy Outlook 2011.
[2] Hunter Estuary Wetlands (21/02/84). New South Wales, 2,969 ha
[3] Exon Mobil (2013) The Outlook for Energy: A view to 2040
[4] BP (2013) Energy Outlook 2030
[5] T. Edis (31/7/13) Coal's crippling outlook, Climate Spectator
[6] US Energy Information Administration (2013) International Energy Outlook
[7] Dr Martyn Taylor, Nigel Deed, 2013. Privatisation of Port Newcastle, Australia

"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:

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.
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).
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.
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.

Last week, Port Waratah Coal Services (PWCS) chief executive Hennie du Plooy said in the Newcastle Herald that the proposed Terminal 4 project (T4) would "inject $770million a year into the regional economy during construction and another $418million a year" when operating.

I don't believe this is correct.

PWCS's claim is 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.

It is the same sort of modelling that got Coal & Allied's Warkworth project into trouble when it tried to claim that project would "create" 45,000 jobs. The chief judge of the Land and Environment decided this type of model was "deficient".

The original economic assessment of the T4 project suggests its annual operating costs will only be between $45million and $50million a year. Since that assessment was made, the size of the project has "almost halved" according to PWCS, so the amount of money it will "inject" into the economy has presumably declined considerably.

The original assessment of the project said that it would not employ any extra staff - the existing PWCS staff would be sufficient to run the new facilities. The economic assessment of the revised, smaller project now says it will require an additional 80 people. It is only through the use of the ``biased'', ``abused'' and ``deficient'' modelling that PWCS is able to claim that many jobs will be created.

The project will increase the Hunter Region's capacity to export coal but with the subdued outlook for thermal coal exports, it is unlikely such an increase will deliver the benefits that PWCS is claiming. Most of the profits from any increase in export volumes would flow to the overseas owners of the major coal companies.

Even if the claim of hundreds of millions a year were true, what does this mean in relation to the size of the Hunter economy? A recent report by Deloitte Access Economics estimates the Hunter Region will produce more than $40billion worth of goods and services by 2015. PWCS's overblown estimates would represent a change of around 1per cent. The real impacts will be much lower.

What strings are attached to the T4 project? What does the Hunter need to do to secure this less than 1per cent ``injection"?

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 coalmines. 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.
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None of these costs are considered in the economic assessment commissioned by PWCS. If we take these costs into account and take a realistic look at the benefits, PWCS's claims about the T4 project are too good to be true.

Rod Campbell is an economist at The Australia Institute.
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.
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.
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.
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.
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."

To the Dept of Planning and Infrastructure,
Dear Sir/Madam,

I am writing to object to the proposed T4 project. My main objection is that we have reached the time that coal must be left in the ground and no further exports take place.

It is clear that the burning of fossil fuels increases global warming. We cannot afford to continue mining and exporting coal which is threatening the existence of life as we know it.

The fact that coal reserves remain is irrelevant. We cannot risk any more increases in global warming and climate change.

Thus, another coal port is not needed and must be stopped.

I strongly object to the T4 project which has not only become unnecessary but would severely diminish our quality of life, and destroy a wetland crucial to the survival of THREATENED and ENDANGERED BIRD SPECIES.

It would be wanton destruction of PUBLIC CONSERVATION LAND, which many people have put a great deal of time and energy into restoring.

Submissions made highlighting the detrimental impact the project would have on community health, and the disastrous effect it would have on the environment, have been ignored in the economic assessment commissioned by PWCS.

There is simply no justification for the project to go ahead.

I ask that the Planning and Assessment Commission reject the proposed T4 coal terminal proposed by Port Waratah Coal Services.

Given that drastic cuts to carbon dioxide emissions will be necessary in the coming decades it goes against reason to consider expanding coal exports at this time. Whether PWCS recognise it or not, it is clear that coal exports cannot continue to expand if we are to avert economically and environmentally disastrous climate change.

Science tells us that greenhouse emissions need to be reduced by 80% in the coming decades. This means that for T4 to be financially viable over the long term, at least 4 coal terminals of equivalent size will need to close. I ask the following questions:
1. How can PWCS be sure that their coal terminal will be one of those that succeeds? i.e. what clear competitive advantage will this coal terminal have over others to ensure its long term success?
2. Should T4 be commissioned and collapse in the coming years, what guarantee of remediation of the site is in place?
3. Are there remediation guarantees in place for PWCS's other two coal terminals should they need to close to ensure T4 can remain in service?
4. How can we be sure that continuing to expand coal terminal capacity will not lead to an oversupply of coal and put at risk the viability of the entire Australian coal industry?

Given that PWCS have acknowledged that there is no immediate need for T4, the considerable risks to its long term viability, and the substantial environmental impact that will occur during construction and any period of operation, I ask that the proposal be rejected.

In addition to the above concerns, as a Tighes Hill resident I can attest to the air and noise pollution issues we already experience at current coal export levels. Dust builds up on the walls and windows of the north face of my house at a truly alarming rate. The level of industrial noise from the Carrington coal terminal is often so excessive that we cannot tolerate opening our northern windows even on hot summer nights.

Any increase in coal exports can only increase the already unacceptable levels of dust and noise pollution along the coal corridor. Rather than considering expanding coal exports I call for a comprehensive study to be undertaken, and action taken to reduce the existing impacts.

Please consider the immediate and long term risks of this proposal and reject T4.

Yours sincerely, Ras Berghout

"Abbott, when do you grow up and drop your out dated views on climate change.
If you were to read (if you can) critically the articles you so believe in. You would come to notice that coal is better left in the ground and not burned."

"I object to this project and believe that the community health, environmental and socioeconomic impacts will 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.

Yours sincerely,

Jo-Ann Back"

"I object to this project and believe that the community health, environmental and socioeconomic impacts will 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.

Yours faithfully,

Noel Winters"

"Thankyou for the opportunity to comment on the above proposal.

Firstly Australia must take steps to stop Global warming - Recent weather events must show you that what scientists have been predicting for years is true. We need to drastically cut the carbon emissions now - not keep planning for more output.

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 Green House Gas emissions.

The proposed site is a total misuse of public conservation lands. Swan Pond is public land, owned and managed by the National Parks Service. Volunteers have worked for years to restore this wetland. I object to the government taking public land especially when it is for such an unsustainable project.

The full economics of such a project need to be considered. PWCS's claimed economic benefits to the region are based on a type of economic modeling 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. A lot more coal dust will ensure future health risks to Newcastle residents - a significant cost on society in the future. 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.

There are many other aspects but enough is enough - time to pull back and access the human destruction of our planet.

Regards Ros Woodward
Wooloweyah NSW 2464"

"I object to this project and believe that the community health, environmental and socioeconomic impacts will 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.

Yours sincerely,

Ms V. Back"

"There is no need for another Coal Mine at all, particularly in this area.

The pollution caused by these mines is not acceptable in this day and age, and we need to be concentrating on Renewable Energy..

The Mining Cos have the expertise and finance to develop more renewable energy sources and so why don't they commence doing something good for the world and this country.
Jobs, profits, less pollution to clean up, and less production costs all add to Companies making as much money as they would like.




STOP COAL MINING NOW."

"I object to this project and believe that the community health, environmental and socioeconomic impacts will 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.

Yours sincerely,

Ms Annalise Field"

"I object to this project and believe that the community health, environmental and socioeconomic impacts will 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.

Yours sincerely,

Mr S. Fortey"

"I totally object to this project and believe that the community health, environmental and socioeconomic impacts will 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.

Yours faithfully,

Mr Brendan Back"

"I totally object to this project and believe that the community health, environmental and socioeconomic impacts will far outweigh any short-term benefits it is claimed the project 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.

Yours sincerely,

Ms Jessie Winters"