Port Waratah Coal Services - Terminal 4

To whom it may concern
As a xxx I have a lot of experience working in our Australian Environment. To widen my knowledge I have finished my xxx and all this gained understanding makes it clear: We need to act now and protect our environment! There is no need for more coal ports. There are enough other energy resources out there. And yes, it might give some short term money profit. However, the longterm costs are much more!
We have to stop working towards short term money profit and look at the big picture!

Kind regards

I object to this project being approved. There is no doubt that public long term costs (health, environment, socioeconomic) will far exceed the promised short term benefits.

I have a particular interest in coastal wildlife and the Great Barrier Reef World Heritage Area (GBRWHA) which is in Queensland. Ocean warming and ocean acidification from climate change are already permanently damaging GBRWHA corals. Australian coal is a huge contributor to climate change and these now scientifically measurable impacts on the GBRWHA. It would be madness for Australia to encourage further ocean warming by mining and shipping more coal only to increase atmospheric CO2 levels; particularly when the profitability is evidently so marginal that both nature and humans local to the Hunter/Newcastle area are to be treated so badly by this project.

I am a former resident (farmer) of NSW Hawkesbury region and familiar with the Hunter Valley. Also (later) of Gladstone Qld, a coal port. Now in the Port of Townsville. So I have some genuine first-hand knowledge of the context.


My objections relate to:
Global warming: adding 174.2Mt of carbon dioxide to the atmosphere. See above.

Wildlife: 112 species of waterbirds in the Hunter Estuary. Nationally and internationally listed threatened species.

Habitat: Deep and Swan Ponds, an unspeakable loss to migratory birds who depend on a vanishing daisy chain of such wetland areas.

State conservation lands: loss/damage to Swan Pond and the Kooragang Wetland Rehabilitation Project (KWRP).

AIR QUALITY: Misleading Air quality modelling: wrong and unscientific to use one selected year as a baseline; NSW Health's critique ignored; do you think the public are fools? Particulates: there is no reason coal dust cannot be contained. Sugar stockpiling and loading (Townsville) is totally covered - why not coal??? ONLY $$profit is the difference. No respect for the victims of your profit-taking. Particulate pollution from rail transport to the Upper Hunter Valley not addressed. NSW Health EA recommendation ignored. As an asthmatic I am familiar with the causes and triggers of asthma, the diminution of people's lives and the public health cost. Will you pay for these?

Economic benefits: of dubious reliability: SHAME. To achieve its claimed economic potential needs increased coal mining and further loss of natural and agricultural land, cartage, coal trains, and contribution to climate change; none accounted for PWCS economic assessment. Little or no benefit from new employment - disparity in PWCS assertions.

NO realistic justification for this project: So what's it really all about?

I strongly oppose a fourth coal loader for Newcastle! The effects of climate change are showing themselves to be very real, very costly and very distressing. As a grandfather I worry about the impact on future generations. Coal exporters only worry about profits and selling as much as possible before it becomes politically unfavorable. They need to be reined in or future generations will curse us for our greed!
On a local level, residents in nearby suburbs are already suffering unacceptable levels of coal dust pollution and health statistics for Newcastle residents are worrying!
Please place public well -being before short term profits!

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.
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.

Yours sincerely,

Geri Roggiero

please, no more coal mining or export. we do too much already.

I disaprove of the proposed fourth coal terminal and would like my opposition noted

I am appalled at the selfishness and greed of all companies and persons wanting to push forward this T4 project. The fact that there is so little regard for the health of the people who live close to the ports and the coal corridor is obvious, but given that for the most part they are of lower socioeconomic status it doesn't surprise that they continue to try to thrust this project right under their nose, literally! Just the smell of the coal trains some nights in Hamilton is overwhelming already with existing terminals! The amount of heavy metals and toxins we are breathing is definitively UNHEALTHY and there are several schools along the coal corridor! The fact that on the dollar Newcastle gets so little monetary benefit for such exposure again speaks to the fact that they are dealing with what they know to be a predominantly lower socioeconomic group being exposed and being ignorant. But this is not to say that I am interested in their money, I am not! I am a xxx and a homeowner in xxx and what I am interested in bringing to light is their unmitigated GREED. They haven't even agreed to spend one cent of all that profit to simply cover the damned coal trains, that's how much they care about the people exposed! Res ispi loquitor... The deed speaks for itself! The fact that WE THE PEOPLE have had to implement studies to measure our exposure is simply ludicrous and again speaks to Res ispi loquitor. Not only do they have no concern about our health, but they are having us run around re-inventing the wheel (doing studies that have already been done in various places in the world and show what's coming out of uncovered empty and full coal trains in transit) before the damn government is going to even step in and protect us. Well of course this speaks to the fact that while Australians like to think of themselves as better than Americans... looking after the underdog and all that crap, when push comes to shove and politicians are pushing money around under the table dealing with this issue believe me you, they are every bit as corrupt and underhanded as any American politician out there! But at least American culture admits to being doggedly capitalistic. The socialist bent of this country to look after the little guy apparently doesn't apply when the countries biggest export is concerned, politicians are the worst of us in any language and every country and big business and capitalism are alive and well here in America, I mean 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:
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 c
ontribute to climate change. None of these costs are considered in the economic assessment commissioned by PWCS.

The Lake Macquarie Climate Action (LMCA) group objects to the T4 project on the grounds of climate change related rising sea levels.

This project will make a significant contribution to climate change and should not go ahead.

It will result in the burning of 70 Mt of coal a year which will add some 170 Mt of carbon dioxide to the atmosphere.

Climate change is a major concern for the Local Government area of Lake Macquarie in regard to climate change linked sea level rises.

The 2009 Australian Government report Climate Change Risks to Australia's Coast lists the Local Government area of Lake Macquarie amongst those at the greatest level of risk from sea level rises and storm surges linked to climate change. (1)

Further this report states that "between 5,100 and 6,800 buildings in the LGA of
Lake Macquarie may be affected by sea-level rise and storm tide inundation by 2100" (2)


The effects of climate change are predicted to have a huge socio-economic impact on the LGA of Lake Macquarie and for this reason we are strongly objecting to the T4 project.

Now is not the time to expand the coal industry and increase global carbon emissions. Now is the time to reject this project and work towards creating a more sustainable future.

Thank you for considering our submission.

David Whitson
Vice- President
Lake Macquarie Climate Action.
21 November 2013

References:

1.Climate Change Risks to Australia's Coast.
(Australian Government: Department of Climate Change) 2009, p 80.

http://www.climatechange.gov.au/sites/climatechange/files/documents/03_2013/cc-risks-full-report.pdf Accessed 21-11-2013.

2.Climate Change Risks to Australia's Coast. p 80.

I object to this project and believe that the community health, environmental and socioeconomic impacts will have far outweighed 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.
* 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 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.

What use another port facility when the world ceases to exist?

What need for another coal terminal when the world ceases to exist?

Newcastle is now the largest coal port in the world. Australia is the world's second biggest exporter of black coal and the fourth largest producer overall, and this industry plans to simply expand as much, and as quickly, as possible. Even though it is 80% foreign owned and employs only 46,000 people, it is lauded as Australia's economic salvation.
But, and this is studiously ignored by the leaders of government and industry, coal is a double-edged sword.
The science is in and the evidence overwhelmingly indicates that our world is warming too quickly and uncontrollably. Without agressive cuts to emissions of greenhouse gases the world is on track for more than two degrees - and possibly more than four degrees - warming by 2100. This would lead to the death of 6 billion people, leaving only 1 billion people, and horrific consequenses for future generations in every way imaginable.
Yet world governments are reluctant to do what is necessary - end conventional fossil feul use and halt the widespread clearing of forests, cut pollution and shift to clean, renewable energy, like wind and solar. As Ross Garnaut stated in his 2008 Climate Change Review: "The most costly and damaging policy for Australia would be to implement a policy that was designed to appear meaningful, but was largely meamingless in application." But this is exactly what our governments and our coal industry have delivered.
"The CEO's of fossil feul energy companies know what they are doing and are aware of long term consequences of continued business as usual. In my opinion, these CEO's should be tried for high crimes against humanity and nature." The words of James Hansen to the US Congress in 2008.
Just yesterday, on Thursday the 21st of November, 2013, Mary Robinson said at the Warsaw Climate Conference: "....progress is too slow. We need visionary leaders. We need brave, enlightened, transformative leadership."

I object to the T4 proposal at Newcastle Port.
I have worked at the `coal face' of the Upper Hunter community for nearly 20 years. I've raised my children in Gloucester and value our rural communities.
I think I know the values that unite communities, and those that divide. The coal industry, because of its' economic power and political influence is under attack from those who gain little or nothing from their existence (the majority of Hunter Valley residents).
Where once the coal industry was compatible with existing economies and rural communities (because it wasn't `big' as it is now), over the past decade we have seen rapid expansion in order to cash in on Asian demand. That short term boom time has now reached the inevitable bust and as people draw breath, they can see the permanent damage caused by mining. There are many communities in the Hunter opposed to furthering the mining industry.
The T4 Project is for a fourth coal terminal - that is simply not wanted or required. PWCS have stated so. To expand the coal industry, so that T4 can be built, at the cost of losing our remaining profitable and sustainable agricultural and tourism industries is too great a price for the community to pay. We need to stop these short-term cash grabs that strip and pollute our natural resources - because to do otherwise would leave this area sterile and dependent on the natural resources of other regions.
Coal is the dirtiest, most polluting of fossil fuels - we have to address new ways to supply our energy needs that do not quicken the pace of climate change. And the technology is there to achieve this if there was the political will to do it.
Clean air, clean and secure water supply, diversified economies offering a selection of employment opportunity should be protected above the short term profits that coal mining has afforded to government.
The T4 proposal just doesn't stack up. It should be seen as a stab at achieving a little more time for an industry that does not serve the public interest any more.
Yours faithfully,

I wish to object to the proposed T4 Project at Newcastle. Support should NOT be granted for the expansion of an industry that represents a greater health risk to this region - to our population and environment - than the asbestos or tobacco industries.
The expansion of the coal industry is in direct conflict with community welfare. The expansion of the coal industry that has occurred in recent times has remained unchallenged by successive governments. Recently the courts have upheld community petition to protect their local environments and economies (Warkworth).
We have seen many farming, viticulture, tourist operators and horse breeders as well as everyday community members publicly oppose coal expansion for good reason.
Long term, sustainable, economically viable and socially acceptable industries are put at risk by coal mining. I realise this situation has occurred as a result of the quick money return of the `mining boom', but short term gain should not dictate sound governance.
One only has to listen to the news reports to realize that coal mines are reducing their workforce to combat lower export prices and demand for coal.
It is predicted this situation will continue as the world economies work towards reducing their pollution levels (think China).
Coal burning is the largest contributor to those pollution levels and the world is working to reduce carbon emissions. We know in the foreseeable future alternative supply of clean energy will be available at a cost competitive price to fossil fuels. The coal industry has reached its' `used by' date - all that is needed is political guidance to expedite change from traditional energy sources.
To upgrade rail lines, road infrastructure, and support industries for coal mining is simply a waste of time and money. But this what the T4 Project will require.
The legacy of environmental damage left by mines will be with us for ever. If it were only the money of miners that was to be wasted, I wouldn't be so upset - but I know my taxes go towards subsidising fuel costs and rail transportation for coal.
We know that the high wages offered by coal companies have stripped alternative, competing industries of growth opportunity particularly in the Hunter region and in Newcastle.
We also know that at the present time nearly 2,000 coal related jobs have been lost this year alone in NSW. More than that number in Queensland. "New" jobs offered by the T4 proposal can only represent a transference of the workforce, no new jobs will be created in the industry. It is well documented that as the price of coal drops, so does the number of employees in the industry. Mining is by nature, boom or bust after all.
PWCS is a joint venture consortium of the large coal miners. I understand that their project will be built if coal markets can be created and they can expand their industry. It's important to note that because of the fall in coal exports over recent years, an increase in coal demand is more than unlikely to occur.
I realise the reader of this submission will not be in a position to answer my questions, but nevertheless, one has to ask why on earth are PWCS pursuing development approval? Is it the case that PWCS and their mining partners will reduce the cost of coal to their markets while they can, and as a consequence leave the Australian community with long term liabilities of -

Loss of real estate values (eg Gloucester)
Loss of tourist dollars (eg wine industry)
Loss of our multi-billion dollar horse breeding industry
Permanent impact on our water resources
Costs associated with health impacts to the population (dust, noise, environmental degradation),
Dislocation and destabilisation of workforce

Where does the idea of `corporate responsibility' come into play? Where does fair governance come into play?
The T4 proposal just doesn't impact on Newcastle Port and their surrounding suburbs - it affects the whole region and those communities and environments that surround coal mines. It is a bad proposal that should be rejected.
Yours sincerely,

Stop this greedy mad 'gold rush' just in the name of the dollar. We need to place a high priority on the future of our environment but also the future wealth of our children, grandchildren and beyond. Slow and steady wins the race.

This submission is written on behalf of the Parks and Playgrounds Movement Inc, PO Box 373, Hamilton, NSW 2303. We are a community organisation established in the early 1930's and now based in Newcastle.

The Parks and Playgrounds Movement Inc. object to this project.

We submit that the adverse environmental, community health, and socioeconomic consequences will far outweigh any of the benefits claimed by the proponents.

Justification for the project:

There appears to be no real justification for the project even from the proponents point of view. PWCS are making no commitment to building T4 even if they do receive approval. We understand that at the time of the initial proposal PWCS made much of their legal obligation to proceed under the triggering conditions in place but as they have refused to substantiate the claims this remains open to speculation. Even if the triggering conditions were reached at the time we can find no information regarding the current situation in light of the economic downturn and consequent reduction in projected demand.

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). We 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. We believe that permitting development of any sort, and particularly a massive coal terminal, on the site would be an abuse of process.

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.

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.

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. Also T4 will surely be the destination for the stated five million tonnes annually for the next 30 years for the Wallarah 2 mine in Wyong awaiting approval with NSW Planning. This will bring 50,000 coal rail trucks per year from the south through all the residential areas between the mine and port. 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.

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.

David Horkan.
Hon Sec.
Parks and Playground Movement Inc.

Our health and the health of our children and environment is more important than short term economic gain.

I am a resident of the Hunter Valley village of Bulga. The very existence of our village is currently threatened by an out-of-control expansion of the open cut coal mines and by coal seam gas exploration. I oppose the approval of the T4 Coal Terminal in Newcastle for the following four main reasons:



1. NSW Government keeps approving new coal mines and expansion of the existing mines regardless of the damage these cause to the environment and the social fabric of the Hunter Valley. Coal mines no longer bother to regenerate the mined-out areas and thus the environmental scars are forever growing. I used to work in the mines so I know what is going on.



2. Building of T4 Coal Terminal will further worsen the negative health effects of the dust and noise constantly generated by the coal mines. Current environmental regulations are not properly enforced and fail to control the problems. The residential area of the Valley and some Newcastle suburbs near the railway line are already choking in coal dust.



3. Coal industry hugely overstates their contributions to the Australian economy.While the coal mines management and some employees are well paid for helping to rape the country, the rest of the community benefits little because the majority of the coal mines is foreign-owned and the profits are exported. This assertion is easy to prove. We are currently at the crest of the mining boom and yet all levels of our governments are broke. We are told daily that there is no money for schools, hospitals, roads and other infrastructure and that severe government budget cuts are needed. Where is the evidence that doubling the size of the coal industry, controlled by transnationals under the current arrangements, will actually improve government budgets? We are selling our resources too cheap. Clever countries do not base their future on digging big holes!



4. Last but not least is the problem of the climate change. More than 80% of the Australian coal is currently exported. An additional coal terminal will certainly help to export more coal to be burned in countries like China or India. Each tonne of the exported coal will contribute about 3.3 tonnes of the carbon dioxide to the Earth atmosphere and will come back to haunt us in a form of droughts, bushfires, cyclones, storms and floods. Reputable climate science tells us that, due to its geography, Australia is particularly vulnerable extreme weather effects of the climate change. Yet, under the current system of the carbon accounting., we behave as if burning our coal overseas has nothing to do with us!

If nothing else mattered surely this alone would be enough to send out a serious warning signal-

"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)"

Please do your best to save these birds who deserve to live. They also will provide enjoyment for our children and their children.

Please accept this as my T4 Submission

Forty years ago as a teenager I worked for a professional fisherman setting nets in the mangrove creeks of Kooragang Island. That was a time that seems a lifetime away (and nearly is I guess). but it was a formative time for my love of the natural environment. More broadly those times, the early seventies, had us as a community questioning our impact on natural systems. Back then it was more about point load pollution ,chemical discharges and concentrated air pollution from industry While many of those issues have to an extent been better addessed T4 brings up many of the problems we were talking about then loss of habitat air pollution from coal handling and transport and the adverse health effects for workers and residents of a major increase in coal volumes. And of course the major environment issue of our time greenhouse pollution not considered even by the environment movement at the time now has to be front and centre of our actions for a better environment. None of these issues have been covered adequately in the T4 proposal to date and until they are T4 should be rejected.

Port Waratah Coal Services Terminal 4 (MP 10/14864)

Comment on the Response to Submissions Report


I refer to your letter dated 9 September 2013 to the Department of Primary Industries in respect to the above matter.


Comment by Fisheries NSW

Fisheries NSW has no further significant issues with the T4 development and impacts at the site. However, it does encourage a reconsideration of the design plans for the Tomago Offset Site. Detailed comments are provided in Attachment A.


For further information please contact Scott Carter, Senior Conservation Manager, (Port Stephens Office) on 4916 3931, or at [email protected].


Comment by NSW Office of Water

The NSW Office of Water advises:

(i) it has no objections to the development.

(ii) as noted in the Environmental Assessment, any activities likely to intercept groundwater may require a licence under Part 5 of the Water Act 1912 prior to the activity commencing. The proponent should liaise with the Office of Water to determine licensing requirements prior to the commencement of any such activities.

(iii) activities on waterfront land (as defined in the Water Management Act 2000) may be considered controlled activities. Any such activities should be conducted in accordance with the NSW Office of Water's Guidelines for Controlled Activities.


For further information please contact Rohan Macdonald, Water Regulation Officer (Newcastle office) on 4904 2642, or at: [email protected].


Attachment A


Port Waratah Coal Services Terminal 4 (MP 10/14864)

Comment on the Response to Submissions Report

Comments by Fisheries NSW _____________________________________________________________________________


Fisheries NSW is responsible for ensuring that fish stocks are conserved and that there is no net loss of key fish habitats upon which they depend. To achieve this, Fisheries NSW ensures that developments comply with the requirements of the Fisheries Management Act 1994 (namely the aquatic habitat protection and threatened species provisions in Parts 7 and 7A of the Act, respectively), and the associated Policy and Guidelines for Fish Habitat Conservation and Management (2013). In addition, Fisheries NSW is responsible for ensuring the sustainable management of commercial and recreational fishing in NSW.


The Response to Submissions and Preferred Project Report for the Port Waratah Coal Service Terminal 4 (T4) project has addressed some of the earlier concerns held by Fisheries NSW, such as the connectivity of Mosquito Creek to the north of the project area. As a result Fisheries NSW has no further concerns or objections to the Terminal development area on Kooragang Island.


Fisheries NSW has a justifiable interest in the rehabilitation of estuarine wetland areas, such as saltmarsh communities, as they are important to fisheries resources and aquatic ecosystems. While the primary objective of rehabilitating saltmarsh and mangrove communities the Tomago Offset Site is for avian fauna and micro-bats, fisheries outcomes will be concomitant with these activities. Fisheries NSW continues to have many concerns about the proposed project design and some design criteria for the Tomago Offset Site, as detailed below. It is however, encouraging to note that the proposed design has now been deemed preliminary only and will be subject to a detailed review prior to the finialisation of the design for this site.


Overall, while the Department is aware of the need to meet particular offset habitat requirements at the Tomago site, the current proposal is overly focused on intensive earth works to achieve those outcomes. The Department encourages a less invasive option to be considered, such as reinstating tidal flows over the existing landscape and allowing a natural regeneration of saltmarsh vegetation. This option is more consistent with best practices for reinstating estuarine wetlands and restoring fish access to these wetlands. While some earthworks may still be required, probably only a fraction of the scale, cost and disturbance of the proposed project would be needed.


Points of concern regarding the proposed project design for the Tomago Offset Site.


There is an established and proven method of saltmarsh rehabilitation that has been employed in the Hunter Wetlands National Park (HWNP) and other locations which has been over looked in favour of the intensive pond construction works proposed. These more natural hydrological methods have been very effective in increasing saltmarsh areas in the HWNP and provide habitat frequented by migratory shorebirds that are the primary target of the T4 Offset Site. Fisheries NSW encourages the consideration of more natural rehabilitation options through detailed hydrological modelling investigations.

Revision of the Tomago Offset Site Design Criteria to seek connectivity to the existing HWNP rehabilitation area, rather than isolation from it, is encouraged where it can be determined that no adverse impacts will occur to the HWNP area. This will provide better integration of the site with HWNP if and when it is transferred to National Parks and Wildlife Service (NPWS) ownership in the future and allow more direct connectivity and biological dispersal from previously rehabilitated areas within the HWNP to the Tomago Offset Site.

Modelling of other hydrological connectivity options may indicate that adequate habitat compensation would be achievable in a more natural, cheaper and less destructive manner that would allow the fauna and flora of the site to gradually revert back to the desired ecological community types. Timeframes for natural site ecosystem transformation are likely to be similar or better than that expected by the intensive pond construction design, as evidenced by monitoring of the HWNP area at Tomago versus the Port Botany constructed saltmarsh site at Penrhyn estuary (Port Botany Post Construction Monitoring Annual Report 2013. prepared for Sydney Ports Corporation, September 2013 EL1112046). Natural rehabilitation would also omit the very disruptive construction period, which was shown to impact on shorebird numbers at the Penrhyn estuary site for at least 5 years for many species.

Monitoring of the Penrhyn Estuary site also indicated the better saltmarsh rehabilitation results are obtained from retaining and improving existing areas of saltmarsh, rather than creating new areas artificially. Zelder & Callaway 1999 have also shown that adequate soil characteristics for saltmarsh do not develop in constructed estuarine wetlands for a number of years.

Swamp Oak Forest did occur on the site in 1946, prior to the levee being constructed (aerial photos, taken May 1946, available from the Kooragang Wetland Centre). The extent and density of the forest has no doubt varied over time due to changes in land use and the ability of the species to quickly colonise suitable habitat.

The Rice Paddy is not a natural depression, but rather a constructed, bunded site. Questions remain as to whether the `freshwater wetland' would occur in the Rice Paddy area to the current extent if it was not for the historical infrastructure there, ie a similar situation to that claimed by the proponent about the Swamp Oak forest that has grown behind the levee since its construction and apparently decreased its value as significant habitat. Other information indicates that the environmental conditions now existing within the Rice Paddy are quite saline, with numerous saltmarsh species found in the area.

Questions remain about the ability of the constructed site to operate independently of sea level rise until 2050 due to increasing volumes through the submerged culverts and overland flow between ponds that may by-pass fitted control structures. The constructed ponds proposal is limited in its provision of areas for landward migration of saltmarsh ecosystems, where-as the mosaic of wetland ecosystems likely to occur with natural rehabilitation is likely to be more accommodating of water level changes over the long term. The Geotechnical Assessment also recommends further investigations about the settlement rates and magnitudes which may affect design levels for levees, leading to prolonged maintenance requirements to maintain the constructed design.

It is difficult to comment on any proposed Mangrove propagule exclusion mechanisms at this stage due to the lack of proposed mechanism or how it is incorporated into the culvert design. Reno mattresses will provide very poor benthic habitat if required over a large area. The use of Gabions in any water flow control situations, such as around the culvert structure is not recommended.

There are some discrepancies between the main culvert invert depth, the depth of the central channel and recorded tides that indicate they will not be submerged during low tides. Chart 4.1 Recorded and Estimated Tidal Cycle suggests low tides regularly are below -0.6m AHD in the vicinity of the proposed culverts, whereas the culvert inverts are -0.2AHD and the lagoon base elevations between 0 and 0.2mAHD. This would indicate that the channel would drain completely on every tidal cycle. Velocities through main entrance of 1.2 -2m/s are acceptable for `fish friendly' flows through the box culverts as long as there is no waterfall effect beyond the culvert or the culverts are not dry. Velocity at the Swing gates in western Tomago HWNP is slower at 0.3m/s.

The plan to scrape the vast majority of the topsoil off the site and pile it on 11ha of `Vegetation Management Area' to a height of about 8m (initially) has a number of concerning issues.

(i) Will this elevated area affect the drainage of or into neighbouring properties, particularly the HWNP?

(ii) What is the fire and / or self combustion risk of such a large mass of vegetation and organic material, especially initially?

(iii) Where does rainfall water drain to from this fully bunded site?

(iv) What will be the impacts of runoff and seepage on the amount & quality of freshwater draining from the site?

(v) What is the impact of the weight of the "vegetation management area" placed onto the soil profile on soil heave?


Considering the above, the proposal to add organic matter to the upper layers of pond sediment to assist with the re-establishment of saltmarsh and benthic invertebrates seems overly complicated. Will this organic matter be sourced from onsite (with subsequent seed bank issues) or from offsite (ie seagrass wrack as used in other locations) requiring significant operational commitments?

It is likely that Casuarina regrowth in the Vegetation Management Area will occur due to the transported soil seed bank and the elevation of the subsequent mound, even after it has settled, therefore long term plans to grow pasture grasses in that location seem unlikely.

Depending on the depth excavated, the remaining soil is likely to retain a substantial seed bank and casuarinas are likely to be an on-going issue on the site where conditions are suitable for their growth, such as the proposed islands (affecting bird line-of-site in these critical places). Natural Casuarina dieback in low lying areas has & is occurring in naturally regenerating estuarine wetlands in the adjacent HWNP, with little risk of further recruitment in those areas.

There is a potentially large risk of ongoing Acid Sulfate Soil (ASS) problems from removed soil, especially if this fill is to be used to create bunds/levees. Remediation of this acidity will require very large quantities of lime. This cost would be significantly reduced with alternative rehabilitation options.

It is noted that none of the boreholes monitored as part of the Coffey Geotechnical Assessment are located in the areas of deepest excavation (the bottom of permanent ponds). Considering the issues regarding the tide levels, culvert and pond inverts and ASS risks discussed above, as well as construction methods, questions about the likelihood of exposing potential ASS and the quality and management of groundwater during construction remain under the current design proposal for the site. Designs that reduce excavation requirements at the site may decrease this risk.

Some of the Swamp Oak Forest (SOF) on the site is actually in good condition and the forest has poor connectivity mostly due to the industrial land surrounding it. With the exception of levee areas the claim that the site elevations have been broadly raised from historical levels thereby allowing the SOF to colonise the area is questionable, with many such drained areas actually decreasing in elevation due to prolonged drainage.


End Attachment A




Regards

Wayne


Wayne Jones | Land Use Planning Coordinating Officer
Department of Primary Industries
Level 48, MLC Centre, 19 Martin Place Sydney NSW 2000

T:02 9338 6708 | E: [email protected]