"Dear Sir Madam


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:

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 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."

"I object to this project because I strongly believe that the community health, environmental and socioeconomic impacts will have far outweigh any short term benefits it is claimed it will deliver. In particular:

The operation of the terminal would contribute unacceptably to the global warming problem: The burning of an additional 70Mt of coal a year, planned to be exported through the terminal, 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 construction of the terminal would pose an unacceptable risk to many species of waterbirds found in the Hunter including nationally and internationally listed threatened species.

The terminal would be an inappropriate and unacceptable use 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.

The additional coal to be transported to and stored at the terminal would have an unacceptable impact on air quality in Newcastle and other Hunter Valley communities. PWCS's air quality modelling is flawed as it continues to use 2010 as a base year. NSW Health has suggested that PWCS should have included "a justification for assuming the PM10 levels in 2010 would be a realistic baseline for modelling future particulate levels or alternatively use, as a baseline, average levels over a longer period of time". This recommendation is ignored in the PPR.

The PPR also does not address air quality issues from rail transport returning to the Upper Hunter Valley. PWCS continues to focus on air quality impacts within 20m of the rail corridor, but there are almost 30,000 people living within 500m of the rail corridor and 23,000 students attend 16 schools in that vicinity. The submission to the EA by NSW Health noted that the contribution of coal dust from coal trains beyond 20m from the rail corridor needs to be carefully considered, but this recommendation is ignored.

There is no justification for the project. PWCS does not commit to building T4 and only suggests an indicative build date of 2015 with operation maybe in 2017. During a major downturn in global coal demand, Newcastle's already approved coal export port capacity of 211Mt seems unrealistic. When serious action is taken to address climate change, as it must be in the next few years, it is inconceivable that the additional planned capacity will be needed.

The 120 Mt facility proposed in the EA identified no additional employment would result from its operation. The revised T4 project of 70Mt million of the RT/PPR is identified as employing 80 additional people. How is this possible? This dubious additional employment is not explained.

PWCS's claimed economic benefits to the region are based on a type of economic modelling the Australian Bureau of Statistics calls "biased" and the Productivity Commission says is regularly "abused", usually to overstate the economic importance of specific projects. The original economic assessment of the T4 project suggests its annual operating costs will only be between $45-50 million a year. Since that assessment was made, the size of the project has "almost halved", so the amount of money it will "inject" into the economy has presumably declined considerably. For the terminal to achieve its economic potential, a lot more coal has to be dug up and exported. This means that a lot more bush and agricultural land needs to be turned into coal mines. A lot more coal trains need to pass through Newcastle's suburbs. At the site of the proposal, a significant wetland would have to be destroyed. And, of course, the extra coal being burned would contribute to climate change. None of these costs are considered in the economic assessment commissioned by PWCS.

In short, there are compelling reasons why this project should not be approved.

Thank you."

"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 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."

"I object to this project and strongly believe that the impacts of this development on the environmental integrity of our region, our community's health and the socioeconomic consequences will far outweigh any short-term benefits the project claims it will deliver. These impacts include:

1. Global warming: The burning of an additional 70Mt of coal a year will add 174.2Mt of carbon dioxide to the atmosphere. This is equal to 30% of Australia's total annual GHG emissions. The International Energy Agency predicts that to limit global warming to under 2 degrees Celsius, global coal demand must peak in 2016, at least a year before PWCS indicates T4's will begin operation.

2. The Hunter Estuary supports 112 species of waterbirds and nationally and internationally listed threatened species, including the Australasian bittern (Botaurus poiciloptilus), listed as endangered under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).

3.Deep and Swan Ponds: The Project will wipe out 80% of Deep Pond, which supports at least 11 species of migratory recorded and above the threshold of 0.1 per cent of the Australian flyway population for three migratory shorebird species, and will develop part of Swan Pond which supports three species in numbers that exceed the threshold of 0.1 per cent of the Australian flyway population.

4.Misuse of public conservation lands: Swan Pond is public land, owned and managed by the National Parks Service under Part 11 of the NSW National Parks and Wildlife Act. It is part of a highly successful long-term restoration project, the Kooragang Wetland Rehabilitation Project (KWRP) and has been the site of significant hours of volunteer labour by the local bird watching club.

5. Air quality: Newcastle and the Hunter Valley communities are impacted by dust from the mining, transport and stockpiling of coal. An additional 70Mt of coal exported will mean about an additional 7000 trips of 80 wagon trains between the Hunter mines and the port and back again per year, the capacity to export coal from an additional 8 to 10 mega mines and four new 1.5km coal stockpiles will substantially add to PM10 emissions in Newcastle and the Hunter Valley.

6. Air quality modelling flaws: PWCS's air quality modelling continues to use 2010 as a base year. NSW Health has suggested that PWCS should have included "a justification for assuming the PM10 levels in 2010 would be a realistic baseline for modelling future particulate levels or alternatively use, as a baseline, average levels over a longer period of time". This recommendation is ignored in the PPR.

7. Particle pollution from rail transport: The PPR does not address air quality issues from rail transport returning to the Upper Hunter Valley. PWCS continues to focus on air quality impacts within 20m of the rail corridor, but there are almost 30,000 people living within 500m of the rail corridor and 23,000 students attend 16 schools in that vicinity. The submission to the EA by NSW Health noted that the contribution of coal dust from coal trains beyond 20m from the rail corridor needs to be carefully considered, but this recommendation is ignored.

8. Justification for the project: There is no justification for the project. PWCS does not commit to building T4 and only suggests an indicative build date of 2015 with operation maybe in 2017. During a major downturn in global coal demand, Newcastle's approved coal export port capacity of 211Mt seems optimistic. Last year only 141Mt of coal was exported meaning 60Mt or 42 per cent of capacity was uninstalled.

9. Employment: The 120 Mt facility proposed in the EA identified no additional employment would result from its operation. The revised T4 project of 70Mt million of the RT/PPR is identified as employing 80 additional people. How is this possible? This dubious additional employment is not explained.

10. Economics: PWCS's claimed economic benefits to the region are based on a type of economic modelling the Australian Bureau of Statistics calls "biased" and the Productivity Commission says is regularly "abused", usually to overstate the economic importance of specific projects. The original economic assessment of the T4 project suggests its annual operating costs will only be between $45-50 million a year. Since that assessment was made, the size of the project has "almost halved", so the amount of money it will "inject" into the economy has presumably declined considerably. For the terminal to achieve its economic potential, a lot more coal has to be dug up and exported. This means that a lot more bush and agricultural land needs to be turned into coal mines. A lot more coal trains need to pass through Newcastle's suburbs. At the site of the proposal, a significant wetland would have to be destroyed. And, of course, the extra coal being burned would contribute to climate change. None of these costs are considered in the economic assessment commissioned by PWCS."

"Please do not approve this NEW coal loader.
We should not be wrecking our environment for more coal export. The coal must be left in the ground where it cannot be burned to increase the world's carbon problem.
NSW MUST start to support alternatives to being welded to the coal wagon."

"I am writing to object to this project. I believe that the economic benefits are limited to a few, and are short-term, while the potential damage to society will be extensive and very long term. The community will suffer a range of damage, including to individual health (costly to all in society) and to the wider range of long term economic and social possibilities of the Newcastle area.

Some aspects that need serious consideration include:
a) The burning of coal is a major contributor to greenhouse gas pollution, which 97% of qualified climate scientists have accepted is happening, and is causing serious imbalances in the world's climate systems. It is likely that there will be action to curtail the mining and use of coal for energy generation in the near future, so to build this project is a waste of time and money.

b) The location is significant for a number of threatened bird species. Damage to wetlands on which migratory birds depend is the same as deliberately exterminating them. To allow the loss of habitat for commercial convenience is criminal.

c) Some public conservation lands under National Parks & Wildlife Management will be damaged or compromised. This is both unacceptable use of land set aside for conservation purposes and also denigrates the work of volunteers who have been involved for many years in maintaining and developing the quality of this habitat area.

d) Air quality along the rail corridor will have substantial impacts on the population of the area; respiratory disease is obvious, but also the filth of coal dust pollution affects people by making their houses and yards dirty, making hanging washing dirty and affecting the health and safety of children as they play in their own back yards.



It is clear that the costs will outweigh the benefits of this project."

"I am a resident of Mayfield.There can be no doubt that 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.

The end result is a further reduction in the air quality for residents in the path of the coal mines, wagons and stock piles. The coal dust that collects in and on our house and therefore is in the air we breath is direct evidence of the impact coal mining and transportation has on the people in the Hunter. This is indisputable.

I understand there are many other concerns apart from the impact on air quality but this reason alone should be sufficient to refuse permission for an expansion to the coal loading facilities at Port Waratah.

To coin an old but too true cliche, the Department of Planning and Infrastructure must represent the well being of the community and: Put people before profit."

"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 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. (Read Rod Campbell's economic analysis here.)"

"Dear Sir,

I am strongly opposed to the construction of another coal loader. Coal, as an energy source is one of the most dirty and dangerous fuels available. A recent study published on March 7th 2013 entitled " The unpaid health bill; How coal power makes us sick" estimates that the health cost from air pollution derived from coal-fired power stations is a financial burden to the European population of up to 42.8 billion Euro a year. This estimate takes into account the health costs resulting from PM2.5, SO2 and NOx emissions only (excluding other externalities resulting from processes such as transport, mining, water impacts or other emissions such as mercury or dioxins) and is confined to EU nations only, although the point is emphasised that air pollution crosses borders (travelling hundreds if not thousands of kilometres) and if the estimates were to include Turkey, Croatia and Serbia the figure would be closer to 54.7 billion Euro annually.
This report was developed by the Health and Environment Alliance (HEAL), a leading European not-for-profit organisation that aims to address how the environment affects health in the European Union. The report details how coal emissions in the EU are responsible for more than 18,200 premature deaths, about 8,500 new cases of chronic bronchitis, and over 4 million lost working days each year. Resulting respiratory and cardiac disease are the most common health effects.
A separate report was also published last week in conjunction with GreenPeace "Coal Kills; an assessment of death and disease caused by India's dirtiest energy source which found that pollution from coal plants resulted in 85,000-115,000 premature deaths in 2011-2012. Australia is the world's largest coal exporter and India is our 4th largest market. We are therefore an accessory to a crime against humanity.
As in Australia, the external costs to health (and therefore to individuals, health care budgets and the general community) from coal power generation have been missing in the debate and policy decisions concerning Europe and India's future energy mix. DEA has advocated strongly for their inclusion in Australia for several years (parliamentary briefings, papers, posters, and countless media interviews and articles) as we work towards promoting health through care of the environment.
Addressing the two-fold burden on human health from coal derived air pollution and climate change could be one of the greatest public health advances of this century, with not only significant health and environmental advantages but also financial ones. Yet we do the opposite and provide subsidies for the coal industry that make them appear competitive with clean energy technologies.

Don Owers"

"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:

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 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."