Port Waratah Coal Services - Terminal 4

Hello,

My name is Tim and I live in Lewis Street Maryville.

Currently I live under 1km from one of the oldest and outdated coal loading terminal in Newcastle.

And exactly 4.5km from the proposed T4 coal Terminal.

As it currently stands, the North East side of my house gets covered in a substantial amount of coal dust every month. Each month I have at my own expense to clean my house and many other objects of the dust, it covers everything including the deck, the deck furniture, the windows, my car and our clothes.

I feel by building the T4 terminal and the ongoing decision not to use coal covers on coal train wagons, coal companies have shown total contempt for the people of inner city Newcastle.

I live just 4.5km from the actual proposed Terminal and I live a lot closer to the rail line. There are 30 000 people living just 500m from the rail line which will increase its traffic not just a little, 7000 trips from 80 wagon trains.

I work in the train industry and while living in Maryville it has become painfully obvious that the coal wagons are not being maintained properly. (Faulty brakes and suspension)

The result is a huge amount of noise pollution, the surrounding suburbs have been loosing sleep due to shonky trains for half a century now and now we are going to increase the load of trains?

Does this terminal really need to be built?

The T4 terminal is not needed.

Regards
Tim. Nash

I object to this project and believe that it sells short the residents, environment and fauna of the region.
Successive governments have promised to refashion the Hunter as an information based economy, moving away from the blue collar model and making a viable future for the residents. This proposal is a step in the opposite direction. Coal sales are destined for a steep decline and the residents would be further linked to the losing strategy.
One only has to take a trip up the Hunter valley to understand how the coal industry has compromised all else around it including the wine industry and tourism in particular. However the coal industry also threatens the health not only of those working around it but also those on its path or proximity. Air quality is severely compromised and land is left a devastated wilderness.
PWC's claimed economic benefits appear flawed with even ABS calling the modelling biased.
Swan Pond is managed and owned by NSW Parks Service and this development would constitute a misuse of public land and a threat to the wildlife therein.
Coal itself is a major contributor to greenhouse gas emissions. To allow such a project is to condemn not only our grandchildren but also our children to a vastly compromised and affected world. Not only that but we are responsible for the welfare of our oceans (the area hardest hit) and the fauna on land and in the sea, all of which we will fail if we o.k. such projects. These are issues whose urgency surprises even the experts. It is no use to say we will deal with the matter later. Already we breathe very different air to that inhaled in the 19th century. Enough is enough.

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.

Regards, Jon Singleton

I write in opposition to the proposal for a fourth coal terminal in Newcastle for the following reasons:

Air quality- The Hunter Valley and Newcastle communities already suffer impacts from coal dust. The increase in coal mines, stockpiles and transport associated with this development will substantially add to PM10 emissions in the region. Port Waratah Coal Services's air quality modelling is flawed on this front. It uses 2010 as a base year. No justification is given for why 2010 provides a realistic baseline figure, when averages over a longer period of time would provide stronger baseline data. Furthermore, the Preferred Project Report does not address air quality issues from rail transport returning to the Upper Hunter Valley and Port Waratah Coal Services focuses on air quality impacts within 20 metres, despite earlier submissions from NSW Heath noting the need for consideration beyond 20 metres (almost 30,000 people live within 500 metres of the rail corridor).

Climate change- The further expansion of coal exports is in contradiction with both the acute need to reduce global emissions, and Australia's own emissions reduction targets. Burning an additional 70 megatons of coal each year will add about 175 megatons of carbon dioxide to the atmosphere, in addition to associated construction, mining, and transport emissions.

Other environmental impacts: The development will destroy significant wetland, and public conservation lands, taking habitat from waterbirds and shorebirds, including nationally and internationally listed threatened species. Furthermore, the associated mining will mean the conversion of bush and agricultural land into coal mines.

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.

The environmental impact from this project is unacceptable. The Hunter Estuary in home to 112 species of waterbirds and nationally and internationally listed threatened species, including the species listed as endangered under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). 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.

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. To develop the T4 on this land is a misuse of public conservation land

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. 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.

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.

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.

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.

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.

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 T4 must not be allowed to proceed.

There are currently three coal loaders already running at 60% of capacity.

No more crap fouling our community's air thanks.

End coal mining. Invest in renewable energy sources

As a mother of a young child I would like to object to the proposed project regarding the "T4". I understand that there would be a vast increase of (uncovered - and I have witnessed these myself) coal trains/trucks moving through the Hunter Valley and Newcastle to service the T4 and as a result there would be a huge increase of health harming particles in the air. I would like to read your official response to the following: "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."
My other concerns surround the adverse effect on the environment with direct negative effect on the Hunter Estuary containing national and internationally listed threatened species.
I think it is important that these issues which are at the forefront of Newcastle and Hunter Valley parents' minds should be considered and addressed. Naturally it is to everyone's benefit if our beautiful region prospers but not if this is at the cost of people and indeed our children's health, and the natural beauty of our surrounding environment.

Thanking you.

Dear Ms Sommer,

I oppose the fourth coal terminal in Newcastle.

As a university educator teaching into courses on environmental ethics and sustainability I am constantly reminded of my responsibilities to students. One is to offer current material. In the area of sustainability this involves focusing on the relationship that we (humans) have with the environment that sustains us, the historical legacies of these relations, and implications of these in terms of contemporary land practices. Another responsibility is to provoke a questioning mind; one that encourages critical thought.

That we live in the world's biggest coal export city makes coal, and the idea of coal expansion, a pressing and relevant case study for students.

My experience in teaching these courses has been that students are the first to question the economic grounds for expansion. They are the ones who challenge existing coal operations in light of social and environmental impacts. They are the ones who raise concerns in terms of social justice and health implications.

The next generation of environmental managers, scientists and advisors are acutely aware of the (un)sustainability and serious limitations of contemporary land practices such as coal extraction.

That the big decisions being made now on coal expansion are by those schooled in another time--when the effects of the production, distribution and consumption was less known or understood--is highly problematic.

The case for other base-load alternatives is mounting and certainly a central part of forging a sustainable society. Students are thirsty for hopeful visions of sustainable energy alternatives and creative ways of thinking and living that are not beholden to another time.

I relay these brief reflections to alert the Department of Planning and Infrastructure that the next generation of critically minded environmental managers and scientists deserve to be handed a different legacy to the one on offer should T4 go ahead.

Surely we want future environmental graduate students to be spending their time creating and innovating sustainable futures rather than being employed to spend a lifetime on mitigation measures and having to produce weak environmental assessments.

I oppose the fourth coal terminal in Newcastle.

Dr Paul Hodge
Discipline of Geography and Environmental Studies
University of Newcastle

I object to the proposal.

I submit that this proposal is morally indefensible, has the potential to be enviromentally catastrophic, and that the claimed econonomic benefits appear to be very dubious.

The Hunter Estuary:

The Hunter Estuary is of enormous international significance for bird populations, both local and migratory. This was recognised in 1984 by the listing of the Kooragang Nature Reserve under the RAMSAR convention in 1984 and more recently the establisment of the Hunter Wetlands National Park. It 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). I believe that no development that poses the slightest threat to the estuary should be permitted.

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. Also the bird life on Swan Pond is one of the key attractions of Ash Island, appealing to both eco-tourists and family picnicers, and has great educational value. Countless volunteer hours and substantial grants have been spent on the rehabilitation of Ash Island. The off set proposed will be of no use to the migratory birds which return annually to breed. If the ponds are allowed to be destroyed they will be gone for ever.

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.

Biodiversity.

Australia does not have an unblemished record in this field, but that is no reason to allow the situation to deteriorate further. Wetlands around the world are being lost at an alarming rate, including those that are essential staging posts for the international migratory species. These are systems and patterns that have taken thousands of years to become established and there can be no justification for a supposedly advanced nation to deliberately and systematically further the destruction.

David Horkan.
28, Cunningham Street,
Birmingham Gardens,
NSW 2287.

I don't believe Newcastle, Australia or indeed, the planet needs yet more and bigger dirty coal infrastructure. The money would be better spent on clean energy. I say no to T4!

I object to this project on all of the grounds outlined below but believe that the global warming impact of this project alone should be sufficient to stop this project going ahead.

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) 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.

4) 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 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. None of these costs are considered in the economic assessment commissioned by PWCS.

To whom it concerns

Mining and coal terminals have no future as part of the future of Newcastle and a new coal terminal risks becoming a stranded asset in the very near future as the legitimacy of coal rapidly diminishes in the face of undeniable science on climate change.

Newcastle's future is in innovation, education, regional infrastructure and as a hub of knowledge, ideas and science and taking it down this new path and making these changes should not be procrastinated about any longer due to the self-interest and short term profits of the coal industry.

A new coal terminal takes Australia in the opposite direction to where its future lies. It will export climate change to the world at the expense of our community, but also future generations. We will suffer the cost for this, while the short term profits go to people who couldn't give a stuff.

It's our future at stake here, the community is saying don't do it, turn towards the sun, the future.

I strongly object to T4 and the corporate influence of mining companies on govt decision making.

Isabel McIntosh
Sydney

To Whom It May Concern

I request the P&AC reject this proposal on a number of grounds.

The three terminals that already exist in Newcastle operate at 60% capacity - there is therefore no need for the additional facility.

There is a significant health risk already by the coal train movements through Newcastle suburbs.

There is no benefit to the people of Newcastle by this development - on the contrary, there are increased negative impacts which include (but are not limited to) noise, pollution, traffic and negative health issues.

In a related matter it is proposed that T4 is built on the edge of the Hunter Wetlands and will negatively impact on the threatened and endangered species that live in that area as well as the migratory birds that utilise the estuary.

Finally, the terminal will contribute to an increased carbon emission - something the world simply does not need.

I hope you can agree that T$ is an unnecessary, greedy and selfishly thoughtless proposal and have the courage of conviction to deny it.

thank you for your consideration

kind regards

I object to the establishment of a fourth coal terminal at Kooragang and believe that the community health, environmental and socioeconomic impacts of this project will far outweighed any short-term benefits it is claimed to 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 greenhouse 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 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 Environmental Assessment document 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 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. None of these costs are considered in the economic assessment commissioned by PWCS.

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

Despite reducing the expansion sought from 120Mt to 70Mt, Port Waratah Coal Services' (PWCS) Response to submissions and Preferred Project Report (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 (without public consultation) 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 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 birds 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 its 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 current 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 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 RS/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 RS/PPR. During 2010 only one daily PM10 exceedence occurred, and on 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 RS/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 RS/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 RS/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 RS/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.






[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 believe that in this time, with climate change constituting a clear and present danger to the world and the clearly proven role of carbon pollution in its dynamics, that it is counter-productive indeed to construct significant coal export infrastructure that would encourage the proliferation of this industry.
Indeed as the Port Waratah Coal Service has stated there is no requirement for this facility, it is clearly not only bad business practice, but the wanton demands of a dangerous minority that has made this an issue.
I demand that the construction of this infrastructure be abandoned and indeed the entire coal industry be dismantled to ensure the future survival of the planet.

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.

The coal companies admit that a fourth coal loader is not necessary. The Hunter estuary is a valuable wildlife refuge and fish nursery. The impact of coal loading infrastructure and dredging will be devastating to this environment; certainly environmental impact studies need to be done before any approval is given.

David Marley

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

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.





[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