Port Waratah Coal Services - Terminal 4

I have uploaded the objections from the Coal Terminal Action Group.

While I do not support the proposed terminal on the grounds that it will negatively affect the health of residents and schoool children in the vicinity of the rail lines and that it will adversely affect natural areas and wildlife my main objection relates to the fact that fossil fuels must stay in the ground if further climate change is to be avoided. The less coal dug up and burned the more hope we have of living in a habitable world!

"I have heard that the existing coal ports are not at full capacity and understand that coal prices are falling, which will further reduce demand for coal and use of the coal port facilities. The existing facilities are already putting lives at risk through respiratory and other problems and more coal trains to serve an expanded port will just make matters worse."

An attachment has been submitted

Refer the attached Whitehaven Coal Submission in support of the Port Waratah Coal Services Terminal 4

To whom it may concern:

Please find my submission regarding concerns on likely impacts to migratory shorebirds resulting from the proposed Terminal 4 Project, and my recommendations.

First the recommendations:

A. Consider saying no to this project.

B. Figure out what is driving greater losses of shorebirds within the Hunter Estuary than being seen at other Australian wetlands. Before that is understood it seems unlikely further impacts will be avoided. Hold off on further developments until this can be done, as there are no proven effective offsets that can be created for some of the Hunter estuary's migratory shorebirds.

C. If offsets go ahead; ensure any offsets are permanent, deal appropriately with uncertainty of success with an adaptive management framework, and costed contingencies to try something else if in ten years the offset is not working. The proposed offset does not appear likely to work well for shorebirds, does not appear to be permanent, and lacks any contingency plans if in a few years objectives to avoid impacts are not met. Further, the offset proposed only works for some of the areas shorebird species, and different designs may be far better for supporting important numbers of the few shorebird species that potentially would respond to this kind of offset.

D. Focus offsets at a relevant scale to maximise conservation outcomes. Rio Tinto was considering a few years ago getting involved in trying to secure some shorebird staging habitats in the Bohai Sea of China. I'm not sure where those plans are at, but species like Curlew Sandpiper and Red Knot will continue to decline at sites around Australia regardless of what steps are taken in Australia if those important staging habitats are not conserved. Eastern Curlew is likely being impacted throughout the flyway including here in Australia, but the Great Sandy Straight is Australia's most important habitat for them, and further steps to ensure their conservation would be beneficial. The ponds proposed here, are the kind of thing if done differently that could benefit Sharp-tailed Sandpiper and Red-necked Stint populations, however, again I'm not convinced with this design and am concerned that runoff into the downstream mudflats could actually impact shorebirds. Interestingly, these species are some of the migrants that habitat loss in Australia may be impacting disproportionately.

E. Remember that we have entered into international agreements, and I have spoken at meetings in Korea on how the Hunter Estuary is an example on how to limit impacts to these birds. My fear is that the Hunter may not remain that kind of example if this project goes ahead. Throughout the flyway we need to avoid impacting Eastern Curlew populations further, and this project would se a bad international example.

Now more on my concerns:

1. Migratory Shorebird Impacts will not be offset by proposed Tomago site.

2. The Migratory shorebirds in the Hunter Estuary are doing more poorly than most places in Australia.

3. Irresponsible to potentially exacerbate impacts to migratory shorebirds

4. The importance of foraging habitat, and the risks this project adds.

5. Earlier thoughts on the T4 project (before the response to submissions)



1. Migratory Shorebird Impacts will not be offset by proposed Tomago site.

I am concerned that the project could result in on-going impacts to migratory shorebirds, and the Tomago offset site will not mitigate those impacts. The Tomago idea is an interesting one, but there is no evidence in the documentation that it would work, and regardless it would not work for all species. The proposed Tomago site has the potential to offer good habitat for Red-necked Stint, Sharp-tailed Sandpiper, Curlew Sandpiper, and possibly Marsh Sandpiper, Common Greenshank. However, there is no indication that what is proposed would offer good habitat for those species. In artificial habitats throughout the world, most rely on pumping water into vegetated ponds, then allowing that water to sit long enough to kill the plants, drive up the nutrient load, and then before most of the shorebirds arrive allowing those water levels to draw down. In all cases I'm aware of, a successful artificial habitat of this sort requires active adaptive management that aims to manage water levels, keep mudflats, and roosting habitats clear of vegetation etc etc. It really does appear to be as much an art as a science to deliver good management of shorebirds at artificial habitats. There are numerous examples of this throughout the world. There is an example of the creation of new tidal habitats in England, but this proposal does not look to have the required rigor to work for shorebirds in any meaningful way, the plan did not appear to account for the permanent need to actively manage the area within an adaptive framework, and makes no mention of what contingencies kick in if in a few years this plan does not work.

Further, and most importantly, no artificial habitats that I am aware of are used by species that forage primarily on coastal habitats like Eastern Curlew, or Bar-tailed Godwit. Therefore this offset will not work for some of the most threatened species of migratory shorebird.

2. The Migratory shorebirds in the Hunter Estuary are doing more poorly than most places in Australia.

The Hunter Estuary is the most important place for migratory shorebirds in NSW, yet recent preliminary analyses of over 30 years of count data from over 100 areas from throughout Australia indicates that migratory shorebirds are declining more rapidly at the Hunter than at other locations. I've recently completed these analyses as part of my PhD studies at the University of Queensland. This indicates that there is a continuing problem that is impacting shorebirds at the Hunter Estuary. For example, most species are declining a bit in some places, and increasing a bit in others, however, most all migratory shorebirds appear to be declining at the Hunter Estuary. Whimbrel is a species that appears to be increasing on average at the over 100 areas I included in a hierarchical regression analysis, however, Whimbrel at the Hunter Estuary are declining at a higher percent per year than most any other site in Australia. Similarly, Eastern Curlew is listed on the IUCN red list of threatened species as globally Vulnerable, with documented declines of on average of well over 40% in 30 years. The rate of decline of Eastern Curlew at the Hunter Estuary is among the highest in Australia. Similarly, Bar-tailed Godwit and Pacific Golden Plover are declining more at the hunter than at most places throughout the country. Alternatively, Curlew Sandpiper are declining at the Hunter Estuary, but they are declining by up to 90% at many areas throughout the country suggesting that Curlew Sandpiper populations are being impacted more outside the Hunter Estuary while migrating than inside it. Clearly many species at the Hunter, however, are being impacted more in the Hunter than they are throughout much of the rest of the country.

3. Irresponsible to potentially exacerbate impacts to migratory shorebirds

While we do not know why migratory shorebirds at the Hunter Estuary are declining it would be irresponsible to potentially exacerbate the impacts with yet another big project on Kooragang Island. As the most important place for migratory shorebirds in NSW it is critical that we first understand what is driving accelerated declines in the area, before any further approvals are allowed which may in fact simply continue to impact these species.

4. The importance of foraging habitat, and the risks this project adds.

Anything that impacts the flow, sediment or water quality in the Hunter Estuary could impact the availability of food for migratory shorebirds. I suspect changes to those environmental conditions are the most likely explanation for the accelerated population declines of shorebird populations at the Hunter, something that is now evident in Australia's shorebird monitoring data. Dredging, drainage from the upstream Tomago site, and increased shipping traffic all has potential to continue to degrade foraging habitat. That has not, as far as I can, tell been assessed and it would need to be.



5. Earlier thoughts on the T4 project

Generally I would agree that the potential impacts to migratory shorebird feeding areas adjacent to the proposed activities need to be better assessed, especially given that migratory shorebirds have been impacted more in the Hunter Estuary than in other areas in the country.

Opinion on the adequacy of the methodologies described in the Environmental Assessment to accurately identify and record the presence and extent of migratory or threatened species, populations or ecological communities or their habitats that are present or likely to be present on the site, with reference to any relevant documents;

Overall the reports that I looked at regarding T4 were detailed, easy to read and understand, well organised, and covered a lot of ground. I did feel that not all species / concerns were given equal time and consideration, with the greatest focus on the Golden Bell Frog. The other matters of state and national significance seemed to be treated much less thoroughly. The reports did, however, seem to cover much of what I'd have expected to see, with a few good surprises.

I am not familiar enough with the area, or the scale of work done in the area historically to know if the methods used here would have been sufficient to cover any gaps in knowledge of the distribution of various ecological components.

It is always possible to miss things in this kind of assessment and further explorations in the historical records can reduce such omissions. In cases where historical understandings are poor, greater survey effort throughout seasons and years is often required to accurately identify presence. I'm guessing the historic foundation for this area is fairly good though.

HBOC and BirdLife Australia are just two of many additional sources of data.

The potential impacts the T4 Project (if undertaken as proposed) and associated dredging project may have on any migratory or threatened species, populations or ecological communities or their habitats

This was something where a lack of equal time on all the species / populations identified was striking. Perhaps a better understanding of the area would lead me to the same conclusions, but detail seemed to be lacking for many of the species, populations, or ecological communities that appear to have been judged as less important than the Golden Bell Frog.

Overall, I found it hard to gauge the adequacy of the assessment of potential impacts in large part due to 1) my lack of understanding of the agreed targets, objectives, and ecological values for conservation of Kooragang Island, the adjacent parks, and Ramsar wetland, 2) my lack of understanding of the historical context in which to view the reported current state of the regions biodiversity.

I assume there are many well articulated conservation goals for the region, and know that generally the ecological character of the area is meant to be maintained, but more detail regarding conservation goals, objectives, values etc would have helped me assess this EA in a more focussed way.

I'm guessing previous projects have been assessed on the island, and similar adaptive management, monitoring and mitigation has been recommended or done. It would be of great benefit to be able to assess the effectiveness of previous proposed management, monitoring and mitigation associated with previous project approvals on the island and in the wider region. Similarly, it would be helpful to have an understanding of the change in abundance and diversity of ecological components since those projects broke ground.

In the T4 reports I read, some conclusions appeared to be reached without any real evidence to support those conclusions. One example of concern to me was the conclusion that the project activities would not impact on the adjacent Ramsar wetland or national park. I may have missed something or it may have been covered elsewhere, but I did not see a clear explanation of that conclusion. There were a few other conclusions, where a judgement appears to have been made, but the criteria for that judgment remained unclear.

Again, this may have been covered elsewhere, and I expect Phil Straw and HBOC would have covered much of what I have questions about, but to me there is still a lack of understanding regarding recent impacts to migratory shorebirds in the Hunter Estuary. Data which I looked at a few years ago from the Hunter seemed to indicate that migratory shorebirds are declining more in places like the Hunter Estuary, and Botany Bay than in other key areas around the country that support large numbers of migratory shorebirds. We expect many populations of migratory shorebirds are being impacted by habitat destruction in SE Asia, but some species populations using the Hunter Estuary appear to be declining despite not showing wider declines elsewhere (i.e. Red-necked Stint). Are the suggested declines at Hunter really greater than being seen elsewhere? If so, what is driving those local declines? I know a recent Phd student did some work on this topic, so it may have been addressed recently, but I still have the opinion that something might be impacting migratory shorebirds at the Hunter which we are not seeing in many other locations.

Outstanding Questions:

Have previous human activities on Kooragang Island reduced the number of migratory shorebirds in the region, either through degradation of foraging habitat (loss of benthic fauna), and / or loss of access to foraging areas through loss of suitable proximate roosts, increased levels of disturbance, lack of open areas which reduce predation pressure at feeding and roosting areas, etc.? I'd guess that foraging habitat has been impacted in both Botany Bay, and the Hunter, but that is something that would require more study to prove, and further study might identify alternative drivers of decline.

If that understanding were more fully developed it would be easier to assess how likely this project might impact migratory shorebirds throughout the estuary?

Some shorebirds use foraging habitat that is relatively irreplaceable. I've never seen an example of shorebird foraging habitat being created for species like Great Knot, Red Knot, Eastern Curlew, or Bar-tailed Godwit. Therefore, the impacts to these species is potentially much more severe, and is why greater certainty regarding the potential impacts of dredging are important.

I did not find the assessment of fauna impacts in the dredging document very compelling. I assume more work will be done, or has been done. That document had no detail in which to assess their conclusions. In my view the dredging assessment was incomplete and not at all adequate.

Foraging habitat is dynamic, but responds to changes in flow, sediment, and water quality. The potential for this dredging to impact those features is not well understood, and certainly was not addressed in the document I saw. Other dredging projects have been conducted near shorebird habitat and in estuaries, so there is potential to identify potential problems or highlight the lack of previous problems.


Additional mitigation measures that you believe should be undertaken as part of the project to minimise impacts on any migratory species etc.

Again the mitigation measures seemed much better articulated for some species than others. The potential for the artificial ponds on the island to support significant numbers of migratory shorebirds is mentioned in one report, but further details are not expanded on.

Some shorebird species, such as Curlew Sandpiper, Sharp-tailed Sandpiper, Marsh Sandpiper, Red-necked Stint among others can thrive in ephemeral, managed artificial wetlands that are sufficiently large, shallow, free of vegetation, and actively managed to maintain those open habitats (alternatively flooding ponds to kill tall vegetation, while leaving suitable foraging shallow ponds elsewhere). The success of this kind of adaptive management approach is well documented in the greater Melbourne area at the Western Treatment Plant, and the former Altona saltworks. Again the reason those areas support so many shorebirds, is because of active ongoing adaptive management, with an active monitoring component (something which HBOC could likely continue to provide).

Again, it is important to understand that mitigation does not work well for all migratory shorebirds, but it does appear to work for many of those listed (not sure how oystercatchers might respond). There are also examples of artificial roosts being created, some have been successful, and some have not, something which highlights the need for an adaptive management framework.

I agree that the importance of the Hunter Estuary for migratory shorebirds is clear, and likely the most important area for them in NSW. Habitats for these birds clearly need to be maintained, however, there are large threats impacting migratory shorebirds in SE Asia, and a portion of any biobanking that included preservation of those habitats would potentially be of great importance in the short term.

I know little of bats or some of the other species / communities listed, but those mitigation plans seemed similarly underdeveloped.

I like the bio-banking idea, so long as it is additive, not a replacement for considered site planning.

Are there agreed thresholds of ecological character that can be lost for an area, beyond which projects thought to have significant impacts in an area will no longer be approved? I am concerned of the potential for cumulative impacts to slowly erode the ecological values that make the Hunter Estuary such an amazing place. This is another reason it would be useful to have a sense of the historic loss of biodiversity in the estuary.

An agreed threshold of acceptable losses in ecological character for an area needs to be established.

I suspect many who live in the region, feel their quality of life, and the economic value of their properties are somewhat tied to the natural values of the Hunter, so this question goes beyond the intrinsic ecosystem services that the Hunter Estuary provides, and the measures of biodiversity.

Finally, as this is the most important wetland estuary in the state, if these questions are not addressed seriously now, the unique values in the area may simply continue to degrade until future generations will be left to wonder why the adjacent areas were designated as a park or Ramsar site in the first place.

Thank you for your consideration and time on this matter.

Sincerely -

Rob Clemens

I wish to submit on behalf of Star Electrical, a statement of support for the T4 project and PWCS. Please see attached a letter outlining our support for the project.

See attached pdf file

HinterNet's submission attached

See attached submission

I support the development of the Terminal 4 project. Please see attached letter of support.

I have a great deal of confidence and trust in PWCS as they have proven to be a responsible developer, operator and active member of the community in Newcastle as history shows. PWCS has been operating and expanding their business in Newcastle for over 30 years contributing greatly to the local economy. The opportunity they provide as a large employer for training and jobs for young people and security for families cannot be understated.

Please find support letter attached.

Submission is included in attachment

As an aging engineer in the Newcastle area, I feel this project needs to go ahead to keep the construction workforce employed. Currently there is very little development in the area. This terminal will also bring financial significant benefits to the Newcastle and Hunter Region

I support the T4 project as something that will help with future employment while benefiting the economy of Newcastle and NSW. I am also satisfied that all necessary environmental issues have been or are being addressed.

Please find submission on the T4 project attached.

submission has been uploaded

See attached document.

see attached pdf