Nigel Waters prepared this submission on behalf of Port Stephens Greens and EcoNetwork – Port Stephens for presentation to the Planning Assessment Commission public meeting 13 July 2015 against the Port Waratah Coal Services Terminal 4 (T4) development application.
I pay my respects to the elders past and present of the Awabakal and Worimi people, the traditional owners of the land in this area. I appreciate the opportunity to address the PAC today, and stand with over 90% of speakers opposed to the T4 project.
I previously gave evidence at the Public Hearing on 26 August as an individual. On this occasion I speak on behalf of two organisations: Port Stephens Greens, an autonomous local group within The Greens NSW, and EcoNetwork Port Stephens, a long established non-partisan umbrella organisation representing 30 separate local environmental groups. Port Stephens is the local government area immediately to the north of Kooragang Island and parts of the LGA are within a few kilometres of the T4 site.
Members of Port Stephens Greens and of EcoNetwork Port Stephens are very concerned that approval of T4 would fly in the face of all evidence, trends and sensible policy directions. Rather than increasing coal export capacity, the precautionary principle demands that the Hunter Region implements a planned and just transition away from mining, transport and export of coal.
T4 would be have major adverse consequences both locally and on an international scale.
Locally, T4 would worsen already poor air quality, with direct human health consequences, all along the Hunter valley coal supply chain. There may also be serious health consequences from disturbance of contaminated land and riverbed – too big a risk to take. T4 would threaten habitat and species in an internationally recognized environment, and would be a misuse of public conservation land.
Globally, T4 would facilitate the production, export and eventual burning elsewhere of up to 70 million tonnes of coal each year – adding massively to carbon pollution of the atmosphere – equivalent to around a third of Australian’s total current emissions. This at a time when the overwhelming international consensus is that we must act urgently to reduce emissions if we are to avoid major environmental damage and serious social and economic consequences. The 2014 Assessment Report asserted that these issues are ‘outside and beyond the NSW planning assessment process.’ We submit that this is not the case – on the contrary the EPA Act requires the PAC to consider these issues under the EPA Act – under both s.79C(1)(b) – ‘likely impact on the .. natural environment’ and s.79C(1)(e) – ‘the public interest’.
There is no rational justification for T4 – it represents the tail end of a dying industry and a bankrupt unsustainable carbon based economy. It is not even clear that it will ever be either needed or commercially viable – the Department states that:
‘…it is assumed that the project would not be needed until at least 2023 but this will be driven by international government policy and global demand which cannot be readily predicted.’ (Addendum to the Secretary’s Environmental Assessment Report, June 2015, page 9)
We reject this prevarication – given widespread international acceptance of the scientific evidence of human induced climate change, and accelerating worldwide action to reduce fossil fuel emissions, it can be confidently predicted that the economic case for T4 will continue to weaken.
The Hunter coal industry has brought great wealth and prosperity to the region in the past but at too great a cost. It can continue to provide employment and income for many years as it is phased out in a just transition to a renewable energy future.
But it must not be allowed to expand. To approve T4 would be an act of reckless irresponsibility, with blindness to the long term consequences.
If, despite all the evidence and voices to the contrary, the Commission is minded to approve the project, we submit that it should mostly maintain at least the positions set out in its draft recommendations in its December 2014 Review Report.
The Department’s response to the PACs recommendations, set out in Table 2 of its Addendum (pp 2-8) and further explained in later pages is in our view a mixture of denial, over-optimistic and unjustified assumptions, and blatant assertion of many issues raised as ‘someone else’s problem’, which is inexcusable.
In particular:
– We find the Department’s arguments for rejecting the recommendations 1&3 for a shorter (5 year) lapse period unconvincing. The PAC should confirm a 5 year lapse period and also specify commencement criteria to avoid the intention of a lapse period being circumvented.
– We strongly object to the Department’s arguments that construction could start within one year of the new Tomago wetland offset being available. We strongly urge the PAC to confirm its recommendation (4) that the new offset be given three years to prove itself successful before construction could commence.
– We find the Department’s reasons for rejecting Recommendation 6 concerning remediation unconvincing, as are its reasons for rejecting three of the EPAs recommendations (PAC Recommendation 7).
– We reject the Department’s assertion that extending air quality conditions to cover shipping and rail traffic, as recommended by the PAC (R8) is ‘out of scope’ for the approval process – the Commission rightly took a holistic view of the overall impact of the T4 operation, and should confirm this position.
– We were disappointed that in addressing the issue of dust from coal wagons (Recommendation 10 &11) the PAC did not recommend mandatory covering of wagons, and call on it to do so in its final approval – there is simply too much uncertainty over the health impacts of coal dust along the entire rail network to take the risk of continuing to allow uncovered wagons.
– We submit that the Department’s excuse for rejecting Recommendations 13 & 14 on noise – essentially that it is too difficult to separate the noise effects of T4 from those of the existing KCT – is inadequate and unacceptable.
– We reject the Department’s response to Recommendation 16, that economic forecasts be considered in the final design of T4. This goes to the overall argument about the need to take wider impacts into account – we strongly support the Commission’s view that forecasts are relevant, and urge it to go further in taking account of overall trends in climate change and energy policies worldwide.
Thank you for the opportunity to present our views. We strongly urge the Commission to take the significant consensus of community views against the T4 project into account in its final determination.