Port Waratah Coal Services - Terminal 4

Brad Hazzard - Minister for Planning & Infrastructure. 22nd November, 2013
Bridge Street
Sydney.


Dear Minister,

RE: Submission the Proposal for Port Waratah Coal Services Terminal 4 (T4).

While I have been impressed with the integrity and professionalism of the Port Waratah Coal Services (PWCS) staff I have encountered over many years, through their quarterly community meetings, I also so realise that the real strategic decisions are made in board rooms outside Newcastle, indeed out of Australia.

I have been on the edge of the debate around the expansion of Port Waratah Coal Services expansion on Kooragang Island. My family marched with the hundreds on the streets of Newcastle to draw attention to a growing feeling of unease of people across the state. The level of mining and the destruction of the environment and prime agricultural land are out of hand. As currently the largest coal port in the world Newcastle is the destination for export coal and T4 signals further mining expansion. Both the negative and positive impacts of mining are felt across New South Wales.

The Minerals Council in a news broadcast recently drew attention to recent job losses in the Hunter. These were in direct correlation to the down turn in the coal price. Economics is the only true driver of the mining industry, but the cumulative impacts across the state of unchecked mining is the real Big Picture. This is the picture of Intergenerational Equity that all levels of government are bound to protect in the public interest.

I have been affected by the submissions of others on this expansion of PWCS with T4. Many will better point out the big issues, for example, the undoubted impacts on the health of individuals and the financial impacts on the health budget shared by the whole community. These are not the sole responsibility of PWCS, NCIG or even T4, but the movement of the coal along the coal chain from mine to port. Even the carcinogenic off-road diesel (World Health Organisation) which is used in the mine explosions, vehicles, and trains are part of the various effects of the approval for T4.

One of the most touching details from submissions is in the hidden effects beautifully exposed by the 200th submission on T4...

"In late March a pair of tiny birds prepare a scrape in the ground in the Siberian Tundra. The female has about a month to recover from her twelve thousand-kilometre flight and build the nutrients to lay four brown speckled eggs.

Their line has survived at least a million years.

Eggs will be laid in April and on the first day of May they will hatch. The parents gather small insects and feed the brood. The days rapidly lengthen.

As May passes they grow from thumbnail size caramel spots of fluff to darker striped feathered chicks.
If wolves or owls or an arctic fox do not find them, and if there is enough food and if a hawk kills neither of the parents they grow quickly. If there is not an unseasonal blizzard or a week of freezing rain they will be fully fledged by the end of June in high summer.
Twenty centimetres down the ground is permanently frozen but on the surface it is alive with grasses, wildflowers, lichens, mosses and millions of insects. By July the chicks have learned to fly. They are making small hops between shallow ponds and they are filling themselves with food twenty hours every day, building up their muscles and storing fat for the journey ahead.
The first day of August the family rises into the air at dawn and begins to fly south. A day later they cross from the Siberian Plateau to the Gobi desert. As the sky darkens they pass the Yin mountains then in the short night the Mu Us desert. The third day they are flying over central China and the fourth day they finally land on the busy coast of Korea. They have lost 30% of their body weight during their epic flight and desperately need food and rest. The wetlands are being bulldozed and filled for expanding cities. The water is polluted and the estuary is busy with boats and fishermen.

They are only halfway.

In the next five days they eat what they can find. A cruel snare that breaks its legs catches one of the parent birds and that evening it is eaten by a clam diggers family. On the sixth day the five birds rise into the air at dawn and continue south. They sweep out over the China Sea and gain altitude and speed. As night falls they are passing between the Indonesian Archipelago and Malaysia. At dawn the weakest chick has fallen behind and is captured by a frigate bird.
Day rolls into night, into day, into night. They cross Irian Jaya then the Arafura Sea and the Gulf of Carpentaria. Down the inland of Australia over Cloncurry and follow the western edge of the Great Divide south without a stop until they meet the sea near Coffs Harbour.
They are near the end of the journey now. Four or five more hours flying and they will find Newcastle Harbour, swing west and follow the Hunter River up to Swan Pond where they finally land.
They have flown for ten days and nights and travelled twelve and a half thousand kilometres. They have now lost half their body weight and are desperately in need of a safe haven with just the right mix of saline and fresh water, few predators, the right vegetation, the insects, fish and crustaceans that they eat and protection from pollution and destruction of their habitat.
The little family of Sharp-Tailed Sandpipers rest and begin to feed.
This is the only place they can survive.

Commissioners we are in a geological age called `The Anthropocene' when mans impact is such that we are changing the surface of the planet. As we do that we are often destroying in the blink of an eye habitats that birds and fish, plants and animals have relied on for millions of years. They can't just move or change their habits. They become extinct.
The Sharp-Tailed Sandpiper only stops once between Siberia and Newcastle because there is only one place to stop and that area of the Korean Coast is being rapidly degraded. There is simply nowhere else that suits their precise needs.
To destroy the Swan Pond and the Deep Pond for a superfluous fourth coal loader in order to inflate the books of a multi-national mining corporation will certainly destroy these tiny miraculous birds. It would be the worst kind of environmental vandalism and stupidity.
[by Len McCarthy of Newcastle]"

I implore the Minister to consider the picture in its widest sense, intergenerationally.
A diverse economic base for the port of Newcastle will in the long term benefit the state economy. Supporting our port is to all our benefits but in doing so we must consider the large and the smallest creatures that enhance our existence, and, are part of the building blocks that also support our environment across the centuries.

The ability to make a submission on this application is of great value to me.

Please receive the attached objection to the PPR for PWCS's T4 development.

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Word file attached, here is a copy and paste of it:
Objection to T4.

I want to be advised when the public hearing takes place so I can speak. This is prepared in a hurry, and had to submit today as not confident if I will have time to work on this any furhter before submission date.

I refer you to my previous submission, and ask that you take it into consideration as well, as none of those concerns expressed in it have been allayed at all by the PPR.

Niko Leka 0406296141 [email protected]
18/11/2013
The PPR contains deliberate falsehoods:

The Executive Summary at states:

"The T4 Project has been modified since the EA was publicly exhibited. The modifications have been made in response to submissions and government feedback, to further minimise environmental impacts, to reflect a reduced maximum proposed coal throughput capacity from 120 Mtapa to a nominal 70 Mtpa [roughly 40%], and to incorporate engineering improvements and the now fully developed biodiversity offset package, particularly the Tomago offset site." (E.1)

The `Executive Summary' is most influential part of any report. How it has been crafted here suggests the T4 proposal has been scaled down mainly because of submissions, government feedback, and to `further' minimize environmental impacts.

However it does not explain just how these were applied in working out the size of the "prefered" T4. We need to know the answers to some simple questions:

How was the concern to minimize environmental impacts translated into a 40% reduction of the project?

What reasons so compelling that the Mayfield site was removed?

What government submission reduced T4 by 50mtpa?

Many submissions said T4 would significantly contribute to global warming(or in PPR's terminology, "scope3 emissions"). You'd think this would be the reason. Instead the PPR claims Scope3 emissions are "beyond the control of PWCS...". So concerns about global warning are not why the T4 has been reduced.

Looking for government "feedback", there is none offered that explains the reduction.

Maybe the 50Mtpa reduction is because T4 will no longer stretch across the river to use the Mayfield site, so objections about the site must have been very convincing. But again, there is no evidence given about this.

So the statement in the Executive Summary is inaccurate. Yet so much care and effort has been taken in producing the report, that these three claims can't each be simple mistakes. Should there be an investigation to see if they were intended to mislead? What are the consequences for making misleading claims?

In any case, is it really necessary and reasonable to increase coal export capacity according to what PWCS suggests? To go from 120 Mtpa down to 70Mtpa within a few months smacks of guesswork- or, reckless speculation.

Maybe the reduction should go even further. If the Mayfield site can been eliminated from T4 , then why not the Carrington terminal?. I dont have the figures at hand, but I believe coal is being exported at about 60% of capacity. That means that CCT could be closed without affecting the volume of exports. If its all working well below capacity then CCT would be costing money wouldn't it? Time to close it down.

Let's return to the likelihood that these figures are speculative, or ambit claims. The PPR makes frequent reference to1) export capacity being a `nominal' 70Mtpa, 2) that T4 will be built in stages according to demand, and 3) that demand `fluctuates'.

Firstly, a `nominal' figure is just a big round number, a guess. That is not good enough given the environmental impact that even the Executive Summary admits is `significiant'. As a guess, the figure is a gamble probably far higher than what is reasonable.

Secondly building T4 in stages "according to demand" means it will be scaled up from some initial minimum capacity. What is that initial capacity? That is what should set the limit for this proposal, not guesswork.

The idea of scaling up capacity in accord to demand sounds straight forward, but it is not. Outide the T4 site it means unknown, abrupt and significant changes to land use, communities, jobs in other industries, and so on. If T4 starts at -say- 25Mtpa then decides to double that, its not simple as far as the consequences elsewhere are. MInes would have to be built, expanded, increases in traffic, dust, bigger stockpiles- a whole plethora of effects that are not necessarily an extension, that may involved novel consequences in some areas. So extending production requires new assessments.

It is absurd to proposed 70Mtpa, then suggest it could be extended to the full 120Mtpa within the one proposal(it's called the `foot in the door' technique). If two sites are needed to export 120Mtpa, then PWCS needs to clearly explain just how one site designed to export 70Mtpa can suddenly become capable of producing 120Mtpa.

Can PWCS explain how if the EA for the 120Mtpa at two sites did not identify any increase in jobs, can a few months later the PPR say 80 jobs will be created out of the same project made 40% smaller and contained on one site?

Thirdly, and most important, the PPR claims demand for coal fluctuates, and that T4 will be built "only in response to demands nominated by coal producers". There are two problems here.

First, demand for coal may have once fluctuated, but those reasons have largely been supplanted. Indications are that the demand for coal is and will continue to inevitably decline. Renewable energy sources are displacing coal in the market place and this will intensify, particularly as coal along with other fossil fuels is no longer acceptable nor tenable due to its contribution to greenhouse gasses.

Second, the "demands nominated by coal producers" is- yet again, another absurd statement. The coal producers are also the owners of PWCS: so what does this statement mean? It means that there is no conventional market-place operating here at all. It places all of the Hunter - its environs, its people, its economy- at the whim of a handful of overseas owners.

Now let me speculate, for a change.

Coal producers are not stupid, but they are desperate to make a profit at any cost. They are certainly aware that the long term prospect for coal are zero, and demand will decline until that is reached. How it is reached- a cavalcade of climate disasters, a collapse as the energy market seizes renewables, citizen resistance or goverment regulations- is secondary. The market for coal will diminish rapidly and considerably. That is why there is a major reduction of T4, and its further reduction into a modular format.

The modular format means the considerable economies of scale by building an initially larger terminal are lost. In turn, that means the benefits of the project to the community are overvalued. The benefit to the community is not simply scaled down by 40%, because as a result the cost of building T4 per unit of coal exported is higher. Taxes and royalties will be cut proportionally even deeper because of these increased costs.

What this shows is that however T4 is built- all at once to 70Mtpa, or in stages, the principle is the same: the community carries the cost of paying for it because that cost is deducted from profits, PWCS will only pay taxes on net profits. So basically, as far as PWCS is concerned, so long as it can make a profit then it does not matter how much it `costs' to make that profit- because someone else will pay for that cost.

It is quite likely that by 2017 the political, social and economic upheaval following the onset of climate chaos, plus advances in renewable technology, means T4 will go the way of all dinosaurs, into extinction, and won't be built. But that means a lot (there were hundreds of submissions against T4) of the community's valuable time, energy and attention has been wasted on a non-productive distraction from more pressing issues.

For instance, rather than having confidence and innovative capacity to develop an eco-friendly region utilising renewable energy sources, we will suddenly wake up to face the fact that the coal `producers' (what a misnomer that is!) see no money in it anymore and have taken off, squirelling their assets safely offshore.

Given the above, this report is insufficient to enable a reasonable assessment of the necessity, overall effects and consequent size of T4.

I recommend that sufficient information be provided so that members of the public could establish if a) T4 is necessary, b) its broad consequences, and accordingly, c) what it's capacity should be.

Climate chaos is happening NOW, not 50 years in the future
Along with some 500 others, I lodged a submssion to the EA in April last year. Most of those submissions were resoundingly negative on a wide number of grounds, the most common and significant of which was the massive increase in GHG as a consequence of T4 exports. But all those arguments were not enough. It means that PWCS wasted the community's time, as we have to go through it all over again.

Since then, things have changed dramatically for the worse. Australia has experienced its hottest January to September period, its hottest month on record, its hottest summer day and its hottest winter day. Most of Australia experienced record-breaking high temperatures from August to November- and we haven't got to summer yet. The massive typhoon that hit the Phillipines had unprecedented winds of 370kmh, and a 600km front. The ice in the Arctic is at present retreating, and its winter there. The Acrtic hasnt been warmer for 120,000 year. Gigantic plumes of methane are rising from the seabed. The recorded pace of climate change is 10 times faster than at any time in the past 65 million years.

In brief, we have been overtaken by the climate crisis that has been so much argued about. The climate crisis is NOW- not at some time in the future.

There is not crime ever committed that could possibly compare to the crime of proposing to massively add to GHC emissions at this time- except perhaps for an all out nuclear war. To knowingly add to GHC at this time is the ultimate act of cold-blooded murder on the most immense scale imaginable: all of life on this planet.

There is no way that there could be any economic benefit whatsoever from T4- not even to the proponents- except in the crudest possible fashion as a very short-term monetary profit to the proponents.

The PPR acknowledges that it will contribute to GHG, but then tries to minimise it with statististics that make it's appear minute. Yet it also acknowledges that the effects of GHG increases are non-linear: that is to say, that a small increment could have an very large effects. That is correct. For example, the increase in volume of water required at the point at which a smooth flow becomes turbulent flow is very small. But we are not delang with something as simple as water in a pipe.

GHG increases are non-linear - but also engender numerous additional feedback cycles that once started, cannnot be readily stopped. We are not dealing with commonplace turbulense here, but with something that is fatally catastrophic.

The PPR repeatedly disclaims responsibility for the production of coal. It argues that "Coal is not PWCS's product; it is the product of the mining companies that mine the coal
and the companies that then purchase the coal for its end use. PWCS is a service provider that handles the coal"(p181). This is disingenous. PWCS is jointly owned by the mining companies that mine the coal, and the PPR declares several times that T4 will be built only according to the demands of the producers.

Turning to what is closer at hand, hardly a day goes by without evidence of the onerous burden excessive coal mining is placing upon Hunter communities. Singleton: the highest prevalence of Ventolin prescription in Australia. A high quality engineering factory in the Hunter having to move because its precision equipment cannot function due to the appalling air quality. The viability of vineyards and horsefarms under threat. Aside from appalling air quality, Singleton, Muswellbrook and other towns endure vibration, noise as well as extended delays that could seriously impede emergency vehicles as well. There wre numerous submissions about the social and environmental costs that would be greatly increased if T4 went ahead. Yet rather than responding to these submissions, the PPR dismisses them with contempt:
"The T4 project is for a coal terminal at the Port of Newcastle and does not include upstream and downstream activities which are the responsibility of others"

That flagrantly contradicts the claims made in the Executive Summary cited above. In other words, those claim are lies. And, I stress that those upstream activities are not the responsibility of "others" but of the same companies that comprise PWCS.

Given the dismal record of environmental justice in this country, the corruption and'rubber stamp' mentality surround big developments (out of some 125 DAs last year only 9 were refused) there is a growing perception that resorting to "locking the gate" is the only option. The law has failed- because it does not serve the cause of justice. In the event of widespread community opposition to T4, what would be the consequences should T4 be approved for the community? What if communities simply decide to "lock the gate" on further coal mining? In other words, what will it take for communities to convince T4 and its individual mining company components that we are irrevocably opposed to its expansion, that we regard it as a matter of life and death and that we are reaching the end of our endurance in being harrassed by mining companies in the Hunter?

Let me say it again, and again, and again: People are alarmed about climate change. To think T4 will add about 300mt GHG, that it would add about 1/6 of the growth in global emissions, that in effect T4 will be the 30th largest polluter in the world- doesnt that rather demand to be considered? Forget people's alarm: what about the responsibility of the T4 proponents to the rest of the world? Or are they exempt from responsibility? At this critical time, it is absolutely essential that T4 NOT proceed.

The rest of the world is giving up coal. Demand is falling - no longer fluctuating as the PPR claims. Consider these articles- and these are not publications that can be regarded as the "left wing press": http://www.businessspectator.com.au/article/2013/7/31/energy-markets/coals-crippling-demand-roadblock
http://www.chinadaily.com.cn/business/chinadata/2013-08/21/content_16911283.htm
So to proceed under these circumstances is foolhardy. Is the plan to export immense amounts so that the falling price of coal will not cut into the sum profits of the multinationals that own PWCS? Isn't that rather irresponsible with regard to a nation's assets?

Let me repeat it again- PWCS may as well endure the repetition it has foisted on the community, and bear in mind that the PPR contains lies, and this is another one. T4 has been reduced NOT because of the claims made in the executive summary, and NOT because of fluctuations in demand. It has been reduced because the proponents know that demand for coal is falling and will continue to fall. As the lies and spin in the PPR demonstrate, the proponents are not stupid, but they are cunning in seeking to make a profit at any cost- even if, in the end, that cost will mean their own demise from the climate chaos they are responsible for.

Benefit to Australia
Lets move on to the rather autistic (ie meaningless in human terms) claims it makes about the benefit to Australia. This begins with the puzzling claim "Conservatively assuming 100% foreign ownership" (p227). I would hate to see an optimistic assumption- still, it would be handy for the PPR to list who the owners are, for the benefit of the community in making submissions.

First, I appreciate that foreign owned mining companies whose primary concern is their own survival and delivering profits to their shareholders, should be concerned about Australia's welfare.It is rather at variance of the repeated denial of interest in the effects of the whole chain of supply.

Now those projections (see below) that mining companies would be paying around 30+% up nearly 1/2 of their profits in royalties and taxes are absolute nonsense. It was mining companies that were instrumental in deposing an Australian Prime Minister who had the nerve to propose a resouce tax. The Federal Government claimed that mining companies pay 13-17% in taxes. The PPR claims are not credible.

Nor does this estimate include the billions already spent subsidizing the mining industry- fuel and electricity subsidies, access to cheap water, infrastructure paid for by the community- roads, rail, the health and environmental costs of producing profits that benefit others but which we pay for.

Second, whilst it is some relief to read the the BCA took into account "All the costs and
benefits to Australia of mining, transporting and exporting the additional coal through the proposed T4 Project", they did NOT actually do this. What they did was this:

They provided 3 scenarios. There was no explanation as to why these scenarios were provided, or which one is more likely. Therefore we cannot assess how realistic they would be. AS mentioned above, they provided hyperinflated estimates of taxes and royalties.

2) They went straight on to conclude that for the:

"T4 Project to be questionable from an economic efficiency perspective, all residual environmental impacts to Australia, including from associated coal mining, rail and port development would need to be valued by the community at greater than $6 B under Scenario 1 and $13 B under Scenarios 2 and 3.

"It is evident that there are potentially significant net production benefits to Australia that would be foregone, due to port capacity constraints."

So where, exactly in the PPR is there any estimate of the valuation of environmental impacts? There is none.

So it is certainly NOT evident of any potentially significant net benefits.

Further, T4 is being questioned by the majority of submissions on other grounds than "economic efficiency" so even the simplistic idea that some number could be derived to represent costs and if the potential net benefit is bigger- even that dumb and inssulting idea, is fundamentally irrelevant.

AS the PPR acknowledged, the many submssions, governement feedback as well as the non-economic efficiency notion of environmental impacts, are not concerned at all with whatever the PPR happens to think economic efficiency is.

Come to think of it, just what does the PPR mean by "residual" economic impacts?

We have here some of the largest multinational corporations in the world, well able to afford teams of experts, able to pay Gillespie Economics who knows how much to dress up this stuff and this nonsense, is the best they can come up with?

Let me point you in the direction of some sound research that's been done on the cost of coal mining to health, with a focus on the Hunter. That is Colagiuri R, Cochrane J, Girgis S. Health and Social Harms of Coal Mining in
Local Communities: Spotlight on the Hunter Region. Beyond Zero Emissions, Melbourne,October 2012. Don't you think the PWCS crew and their associates would have seen it? I bet you they have. They ignored it because it is damming.

Here are summary conclusions from the report (excuse messy coy/paste, I don't have the resources of Gillespie to make it look pretty)
Adults in coal mining communities have been found to have:
Higher rates of mortality from lung cancer, chronic heart, respiratory and kidney diseases Higher rates of cardiopulmonary disease, chronic obstructive pulmonary disease (COPD) and other lung diseases, hypertension, kidney disease, heart attack and stroke, and asthma Increased probability of a hospitalisation for COPD (by 1% for each 1,462 tons of coal mined), and for hypertension (by 1% for each 1,873 tons of coal mined).
Poorer self‐rated health and reduced quality of life

Children and infants in coal mining communities have been found to have:
Increased respiratory symptoms including wheeze, cough and absence from school with respiratory symptoms although not all studies reported this effect
High blood levels of heavy metals such as lead and cadmium
Higher incidence of neural tube deficits, a high prevalence of any birth defect, and a greater chance of being of low birth weight (a risk factor for future obesity, diabetes and heart disease)

Adults (and whole population) in communities near coal‐fired power stations and coal combustion facilities have been found to have:
Increased risk of death from lung, laryngeal and bladder cancer
Increased risk of skin cancer (other than melanoma)
Increased asthma rates and respiratory symptoms

Children, infants, and fetal outcomes in communities near coal‐fired power stations and coal combustion facilities have been found to have
Oxidative deoxyribonucleic acid (DNA) damage
Higher rates of preterm birth, low birth weight, miscarriages and stillbirths
Impaired fetal and child growth and neurological development
Increased asthma rates and respiratory symptoms.


Social injustice aaspects include
Environmental damage and perceptions of damage and health impacts
- slurry (fly ash) spills
- lack of community awareness of damage
disstress resulting from concerns and uncertainties about the health impacts of mining‐related pollution
Water quality and human occupations (activities)
-The impact of water pollution on securing safe water for drinking, producing food, swimming and fishing

Social and economic costs
- the cost of environmental damage to communities and society
- inability of the community to capture economic benefits
-Social changes inhibiting the generation of alternative means of economic capital to mining
-socio‐demographic changes resulting in labour shortages in other industries; reduced access to and affordability of accommodation; increased road traffic accidents
- increased pressure on local emergency services
- incr

see attached

I am attaching my family's written objection to the T4 Preferred Project Report.

See attached

Dear Ms Sommer,

Submission: T4 Project RTS and PPR (PWCS) - Application No 10_0215

I strongly objects to this project on the basis that the community health, environmental, and socioeconomic impacts will far outweigh any short-term benefits the project claims it will deliver.

I formally request the opportunity to present to the Planning Assessment Commission when it is called.

My formal submission is attached. It contains two supporting documents. They are:

Appendix A. Economic Analysis by Rod Campbell (TAI)
Appendix B. Table of objections and failings of the RTS/PPR on T4

I have read the Department's privacy statement and give consent for our details to be published. I have not given any reportable political donations.



Fee Mozeley
76 Dawson Street,
Cooks Hill, NSW 2300

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

Please see attached submission.

I would like to be called upon to speak also at the hearing, if possible.

CPCFM object to the T4 proposal, our submission is attached

I object to the T4 project based on what is outlined in the Preferred Project Report (PPR). Please see the attached submission.

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See attached.

Dear Sir/ madam

Personal Submission on the PWCS T4 Project



We have added these two additional lines to our submission, which is attached in the modified form:


1. We declare we have no vested commercial interests and have made no political donations.

2. We would like to speak at any PAC that may be empanelled to consider the approval of T4