Port Waratah Coal Services - Terminal 4

Please find attached submission, could you please send email confirmation of receipt to admin@dea,org.au

4 May 2012

NSW Department of Planning

Submission Against the Port Waratah Coal Services Terminal 4
Climate Action Newcastle (CAN) is a committed group of local residents from all backgrounds working together to address the single biggest issue facing humanity: climate change. We are a community based non-party-political group of volunteers who dedicate our time to advocating renewable energy solutions for the Hunter and beyond, as well as opposing policy and developments that lock in dangerous climate change, such as new coal mining and exporting projects. CAN has more than 60 active members as well as more than 600 supporters who receive regular email updates about ongoing campaigns and projects.
There are many environmental, social and also economic reasons why the proposed PWCS Terminal 4 (T4) project should not go ahead; and also many areas where the Environmental Assessment (EA) has been inadequate or fails to address key issues about the development and its far-reaching impacts. These are addressed under separate subheadings below.
Rapid Increase of Coal Mining in NSW
T4 has a proposed export capacity of 120 mega tonnes per annum; this is approximately double the current export capacity from the existing three loaders and will facilitate the development of at least 15 new 'super-pit' mines in NSW, principally in agricultural and forest lands of the Hunter Valley and Liverpool Plains, whose communities are already feeling the negative health and environmental impacts of excess levels of open-cut coal mining. The extent of irreparable destruction wrought by open-cut coal mining is already becoming too much for human and ecological communities in the Upper Hunter; another 120 million tonnes worth of new mining activity is almost inconceivable and any government that could countenance this is grossly irresponsible and thinking only of very short-term and short-lived economic gains at the expense of future generations and other species.
The devastating environmental impacts of open-cut mining has been well documented in recent years; and despite the mining industries' claims of 'best practice' remediation and rehabilitation of mine sites, the depth of extraction, total removal of living flora and fauna years of stockpiling soils means that no site can ever be the same again. Coal mining uses vast quantities of water for coal processing, dust suppression and equipment wash-down, sourced from local river systems such as the Hunter River in the Hunter Valley. Furthermore, open-cut mining substantially disrupts and contaminates regional groundwater systems, which are relied upon for ecosystem health as well as indirect and direct agricultural supply.
Acceleration of Global Climate Change
The demand for 120 mega tonnes of coal to be exported annually from T4 at peak capacity would fuel at least 15 more large power stations around the world, emitting 288 million additional tonnes of carbon pollution each year, which will double the carbon pollution impact of coal exported from NSW. For PWCS to claim that these 'Scope 3' emissions from burning the exported coal "is beyond the control of PWCS" demonstrates a major failing of NSW and Australian legislation. The bottom line is that coal dug up from NSW lands is being exported to be burnt in power stations and metallurgical industries overseas; the more that we export, the more that will be burnt and significantly contribute to accelerating global climate change. Conversely, if we do not expand our coal export capacity, the annual tonnage of carbon dioxide resulting from the burning of NSW coal will peak and decline as export customers move to cleaner alternatives. The inevitable and tired argument that 'if we don't export it, someone else will' is immature and fails to recognise the real and meaningful efforts of these countries to move towards renewable electricity sources. The desperation of the coal industry to increase coal exports for the short time that coal will still be profitable demonstrates a profoundly short-sighted , extreme greed which completely disregards the principles of sustainable development and risks the tenure of future generations.
The CSIRO released the 'State of the Climate 2012' report recently and it paints a very sobering picture of human-induced climate change, which is accelerating due to the burning of fossil fuels such as coal. In looking at future temperature increases, the report found that:
" Australian average temperatures are projected to rise by 0.6 to 1.5 °C by 2030 when compared with the climate of 1980 to 1999. The warming is projected to be in the range of 1.0 to 5.0 °C by 2070 if global greenhouse gas emissions are within the range of projected future emission scenarios considered by the Intergovernmental Panel on Climate Change."
The IPCC has clearly stated that global temperature increases need to be kept to less than 2°C to prevent runaway climate change with the escalating impacts of positive feedback loops such as loss of reflective sea ice and melting of permafrost. Exporting colossal amounts of coal as is proposed for T4 perpetuates the old-world business-as-usual paradigm which will lock in dangerous, potentially catastrophic climate change. No amount of money is worth the serious risks posed by a rapidly changing climate, and the governments of today who seek to line their own pockets over and above the livelihoods or even the lives of future generations deserve the highest censure.
Ecological Impacts at the Site
The site contains a significant area of National Parks lands which is habitat for a 23 threatened fauna species, including many migratory bird species as well as the Green and Golden Bell Frog (Litorea aurea). The freshwater pond on the site, which is to be destroyed, is one of the last of the freshwater refuges for shorebirds in the Hunter Region. The EA appears to give much higher significance to the Litorea aurea population and habitat than the many threatened bird species which use the site; and concludes without any proffered evidence that the project will not impact on the neighbouring Ramsar site. Given the scale and scope of the project - the dredging, dumping and clearing during construction and the dust, chemical, noise and light pollution during operation, the claim that neighbouring wetlands will not be adversely impacted is utterly ludicrous and the Department of Planning should require PWCS to undertake more detailed studies at the very least. The idea that 'biobanking' sites elsewhere will compensate for the loss and degradation of these unique freshwater and estuarine wetland habitats is ludicrous - migratory species cannot be told to divert their migrations to areas that are not suitable to support them.
Ecotoxicological Impacts at the Site
The site is largely comprised of former industrial lands which were also used as a chemical and heavy metal dumping ground for Port industries for many decades. The site is heavily contaminated with a range of toxic contaminants, including a range of metals, BTEX, PAHs, cyanide, anions and physico-chemistry at selected sites. These levels often exceed respective guidelines (e.g. NSW EPA Health based criteria for industrial/commercial landuse; the ANZECC Water Quality Guidelines for slightly to moderately disturbed sites). Most of these contaminants are bound up in the soil and in the sediment in the Hunter River that is to be dredged for the project.
The EA acknowledges that the construction of T4 will 'squeeze' the soil and potentially mobilise contaminants into groundwater systems and thence off-site, into other lands and the harbour environment. The groundwater sampling indicates high concentrations of selected contaminants in the two aquifers on the site; some of which still exceed ANZECC water quality guidelines. Testing carried out for the EA showed that surface waters commonly exceeded water quality guideline levels for existing ponds on the T4 site and for wetlands, ponds and the Hunter River offsite. This indicates that the Kooragang Island/Lower Hunter River area is heavily contaminated from decades of industrial use. The T4 site currently has a part in adding to this and future surface water runoff is acknowledged to have similar concentrations. The cumulative impacts of these discharges on the Kooragang wetlands and lower Hunter River system needs to be considered.
We, along with many other community groups in the Hunter, do not believe that the management strategies proposed to deal with the risk of contaminant leaching are adequate to address the problem. The proponent's approach seems to be to build the loader, then observe the effects and mitigate where possible. This is too risky a strategy given the human populations and sensitive ecological communities that live in very close proximity to the site.
Health Impacts from the Site and Train Movements
We have touched on the health impacts of increased open-cut coal mining on the rural communities of NSW affected by mining; and note that the NSW still has not commissioned a study into the health of effects of mining and burning coal near these communities.
T4 will have direct health impacts on the people of Newcastle and those who live near the coal rail corridors, as well as the people who are forced to breathe in the dust and emissions from mining and transporting coal in the Hunter valley and beyond.
The Environmental Assessment of T4 downplays impacts on air quality stating: "The T4 project is not expected to result in any criterion exceedences on any additional days of the year"1. It defies belief that extra, uncovered coal stockpiles will not increase the amount of coal dust effecting Newcastle suburbs.
The EA only considers the impact of increased coal train movements on residencies within 20m of the rail line. However, the impacts of coal dust are likely to extend far beyond this area. The current guidelines are out-dated and fail to account for the findings of recent health studies which demonstrate that total suspended particles (coal dust) are of greater detriment to human health than when the T4 guidelines were put in place.
We note that Medicine and Public Health academics from the University of Newcastle have prepared a detailed submission about the health impacts from T4, in which they state: "As public health professionals, we regard the Port Waratah Coal Services Terminal 4 development as a significant threat to public health." The facts detailed in that submission are reason enough in themselves to prohibit the development of an additional coal loading facility in the port of Newcastle, regardless of all the other negative impacts touched upon in our submission (and others).
Economic Viability
The proponents claim that T4 will be needed to accommodate the NSW coal export industry; whereas in reality the existing three coal loaders are running below capacity and demand for coal will decline dramatically in coming years as the countries that buy our coal, such as South Korea and Japan increase their renewable energy supplies and draw down their reliance on fossil fuels. In recent days South Korea has passed an Emissions Trading Scheme which will expedite this process.
Thermal coal prices are "expected to fall by 25 per cent on average to 2020" SMH April 28 and coal mining companies are desperate to mine and sell as much coal as they possibly can in as short a period of time as possible. It is irresponsible governance to allow this to happen, given the fact that barely any full time jobs will be created by T4 and the deleterious social, health and environmental impacts of the project will far outweigh the increased royalties to the NSW government. We note that PWCS is owned by Xstrata and Rio Tinto; multinational corporations with largely foreign ownership and shareholders. On the whole, the people of the Hunter will not significantly benefit from this development.
Employment Claims
Professor Bill Mitchell of the Centre for Full Employment and Equity at the University of Newcastle has analysed the employment claims in the EA, and concludes that "The Company has to use its estimated impacts in a highly selective fashion to justify its advertised claim that it will generate over 2000 jobs," once operational; and that following construction, "the employment impact drops dramatically and becomes relatively modest on a steady-state basis." The information supplied in Appendix R Economic Assessment does not make clear what permanent ongoing jobs will eventuate from T4 post-construction, and we find the advertised claims of more than 2,000 jobs following construction to be misleading and dishonest.
Conclusions
This submission briefly touches on some of the key reasons why T4 - or any other coal loader - should not be permitted to be built in the port of Newcastle. There are very serious and cumulative environmental, public health, food and water security impacts from the mining of the coal that will supply the 120 mega tonne capacity loader. Like many other community groups in the Hunter Valley and beyond, we strongly feel that coal mining should be phased out and replaced with renewable energy sources such as concentrating solar thermal plants, wind farms, and distributed photo voltaic systems to name but a few. Building T4 will lock in a dramatic expansion of coal mining in NSW with compounded impacts for communities, farmland, aquifers and river systems and what is left of our natural bushland and biodiversity.
There are also serious local environmental and public health impacts in the construction and ongoing operation of T4. As mentioned in this submission, the site comprises and lies adjacent to critical habitat for threatened fauna species. The site is heavily contaminated from previous industrial uses and dredging and construction will disturb these contaminants and will almost certainly mobilise a proportion of them into the soil, air, groundwater and surface waters including the Hunter River estuary. Furthermore, placement of heavy infrastructure will, by the EA's own admission, squeeze the contaminated soil beneath it resulting in leaching of contaminants to groundwater. Dust from the additional coal stockpiles and trains, as well as emissions from diesel trains and plant, will have detrimental impacts on health of nearby residents, of which there are more than 30,000 immediately surrounding the port of Newcastle.
For the above reasons alone no new coal exporting infrastructure should be built in Newcastle (or anywhere in NSW for that matter); however, it is also clear that this project will only be economically viable for a short period of time relative to the cost negative impacts of its construction and operation. The proponents claims of substantial economic benefits and a significant number of ongoing jobs are dubious; and we are convinced there is more PR spin than truth in such claims.
We trust that the Department of Planning will seriously listen to the grave concerns held by a great many individuals and community groups in Newcastle, the Hunter Valley and indeed throughout NSW. Coal is a 19th and 20th century fuel; the big mining companies know this which is why they are trying to rip out and sell as much as they can, as quickly as they can. It is grossly irresponsible for any government to allow them to do so.

Dear Rebecca,

The Hunter Community Environment Centre objects to the proposed Port Waratah Coal Services Terminal 4 proposal for Newcastle (MP10_0215) and urges that this project not be approved due to the level of irreparable harm that will result for the environment and human health. This level of harm should be considered unacceptable.

As detailed in our submission it is evident that the Environmental Assessment for the PWCS Terminal 4 has failed to comply with a number of the Director General's requirements and Supplementary Director General's requirements. There are also substantive problems with key aspects of the proposal and its assessment.

Please find our 23 page submission on the proposal `HCEC_Terminal_4_submission.pdf' attached as well as `Appendix_A_Hydroecology.pdf' and `Appendix_B_Ecotoxicology.pdf'.

Yours sincerely

Ben Latta, Secretary, email: [email protected]
Simon Fane, email: [email protected]

Hunter Community Environment Centre
Ph. (02) 49625316
167 Parry St, Hamilton East, 2303

The submission is response to the EA advertised - in the Newcastle Herald
I write in response to the project Application Number 10-0215 for the T4 Project
I, Jane Kattenhorn of 33 John St Tighes Hill recommend not to proceed with the T4 Project described in the EA - as the risk to human health and the environment are unacceptable. There are major risks to public health for the Newcastle Community including death and long term irreversible damage to Aquifers in the Hunter River.

Please read attached submission.

Climate Action Tomaree, a working group of EcoNetwork Port Stephens, a conservation and natural heritage network, wishes to object to the proposed development by Port Waratah Coal Services of a fourth coal loading facility (T4) on Kooragang Island in the Hunter River. We submit that the application should be refused on multiple grounds, as set out in the attachment.

I object to the loss of migratory shorebird habitat from Swan Pond and Deep Pond through the proposed development of the Port Waratah Coal Services T4 Coal Loader. My detailed submission is attached. A hard copy will be mailed separately.

SUBMISSION IN OPPOSITION TO THE PROPOSED T4 PROJECT
I am a lifelong Newcastle resident who is actively involved in local environment groups (such as Hunter Community Environment Centre, Climate Action Newcastle and the Wilderness Society Newcastle); and I am the Environmental Representative on the recently established Newcastle Consultative Committee for the Environment (NCCCE). I, like thousands of Newcastle and Hunter residents, am strongly opposed to a fourth coal loader being built in Newcastle. There are many very good reasons why T4 should not be built; these are summarised under the following subheadings.
Climate Change
T4 will have a peak capacity of 120 megatonnes per year; this is approximately double the current peak export capacity in the port of Newcastle, and will double NSW's contribution to global climate change when the coal is burnt in overseas power stations. More than 288 million tonnes of carbon dioxide will be emitted from the coal exported from T4 at peak capacity; this is a significant contribution to global climate change.
The EA has adopted the 'business as usual' trajectory with minimal or no global mitigation, resulting in six degrees of warming by 2050, to make the contribution of T4 to seem lesser; this is grossly irresponsible and does not take into consideration the mitigation that is already happening in Australia and overseas, including in the countries that we currently export coal to. I note that the Republic of Korea has recently established an emissions trading scheme, which will help expedite its transition to renewable energy as it moves away from coal.
The severity and consequences of accelerating climate change is very well documented by the CSIRO, the Bureau of Meteorology, the International Panel for Climate Change and countless science academies and centres of learning worldwide. Many of these organisations are in concurrence that it is happening faster than previously predicted and the impacts will be far more serious than most people realise - potentially threatening the capacity of the planet to sustain human civilisation in its current form. To further contribute to climate change by approving - nay, actively encouraging - a development such as T4 - is grossly irresponsible act of governance and will be met with censure and dismay by everyone who thinks about the sustainability and future of our society.
Health Impacts of the Coal Loader, Stockpiles and Trains
Dust emissions from coal trains, coal stockpiles and coal loading operations have serious health impacts, particularly the fine particles (PM2.5 and finer). The EA only considers coal dust generated within 20 m each side of the rail corridor - this disregards the dispersal of fine particulates far beyond 20m. I have many friends who live in Tighes Hill, Maryville, Carrington and Mayfield East and they almost constantly have fine coal dust on their houses, in their backyards and by inference in their children's lungs. The amount of dust generated by the existing three coal loaders is already too much; and there are already far too many coal trains travelling through port-side suburbs. To double coal train movements, and to double the amount of dust emissions that would occur at peak T4 capacity is totally unthinkable and the proposal should be rejected on these grounds alone, let alone all the other key reasons briefly outlined in this submission.
Environmental Health Impacts of the Development
The dredging and dumping of contaminant-laden sediment from the sites of the two swing basins is potentially an environmental disaster and will certainly have negative impacts on the endangered fauna species that are found on the development site and in the Ramsar listed wetlands adjacent to it. The fauna impact assessment in the EA has no grounds to dismiss the likely impacts as being 'not significant' - it is obvious that the report's authors have come to such a conclusion because, as consultants to PWCS, they do not wish to bite the hand that feeds them. Biodiversity offsetting is totally inappropriate for this site because it is habitat for migratory birds that land there year after year - they can't be told to go elsewhere for their foraging, roosting and nesting habitats.
The site has been a dumping ground for a cocktail of highly toxic contaminants for many decades. These contaminants are in the soil and groundwater and will almost certainly be release during dredging, earthworks and construction; and furthermore the colossal weight of the infrastructure will effectively 'squeeze' the soil and sediments beneath it, exacerbating the leaching of contaminants into the groundwater and subsequently into the Hunter River estuary. This is a ludicrously risky thing to do and port-side communities will not stand for it. It is now the 21st century, and citizens of a wealthy, first-world country such as ours demand first class environmental management which does not include contamination of groundwater or off-shore dumping of contaminated dredge spoil. I will continue to raise this issue in my role on the NCCCE.
Coal will not be economically viable in the very near future
Finally, there is no need for this piece of infrastructure, as the existing three coal loaders are currently operating 40% below capacity, and global demand for coal will shortly peak and begin to decline. It is obvious that the multinational giants Xstrata and Rio Tinto, who own PWCS, are trying to rush this development through so they can rip as much coal out of the ground while it is still profitable. They have seen the writing on the wall and know that coal will be dead within a few decades; the NSW government knows this too but wants to rake in what coal royalties it can. I urge the decision-makers in government and industry to think of the future of their children and grandchildren, and to put their future livelihoods above short-term greed.
Expansion of Mining in NSW
120 million tonnes of coal is the equivalent of 15 new mega pit coal mines in NSW, the majority or all of which will be located in the Hunter Valley and the Liverpool Plains. These communities are already feeling the negative health and environmental impacts of excess levels of open-cut coal mining. The extent of irreparable destruction wrought by open-cut coal mining is already becoming too much for human and ecological communities in the Upper Hunter; another 120 million tonnes worth of new mining activity is almost inconceivable and any government that could countenance this is grossly irresponsible and thinking only of very short-term and short-lived economic gains at the expense of future generations and other species.
The devastating environmental impacts of open-cut mining has been well documented in recent years; and despite the mining industries' claims of 'best practice' remediation and rehabilitation of mine sites, the depth of extraction, total removal of living flora and fauna years of stockpiling soils means that no site can ever be the same again. Coal mining uses vast quantities of water for coal processing, dust suppression and equipment wash-down, sourced from local river systems such as the Hunter River in the Hunter Valley. Furthermore, open-cut mining substantially disrupts and contaminates regional groundwater systems, which are relied upon for ecosystem health as well as indirect and direct agricultural supply.
Enough is enough - the community of NSW has spoken and we demand that our elected government really listens to us on this issue and does not give T4 the green light.
Yours sincerely,
Zoe Rogers

See attached letter containing comments on the EA and proposal regarding the proposed relocation of the high pressure natural gas pipeline.

Please see attached file for my objections

Please find my submission attached.

Please find submission attached.

Please see attached file

Attached, please find my submission in response to the public exhibition of Port Waratah Coal Service's proposal to develop new coal loading facilities on Kooragang Island, Newcastle (application number 10_0215).

See attached letter of objection

Please refer to the attached letter.

As Per Attachment

As Per Attachment