31.5.2012 Re; Address to PAC re Ashton Mine Approval · twice NSWs total emissions. In global terms, 298.6 mt of CO2 is about 60% of the CO2 that was added to the atmosphere globally

Lynette L. MacBain

31.5.2012 Re; Address to PAC re Ashton Mine Approval On behalf of the Singleton Shire Healthy Environment Group [SSHEG] and my family and myself Mr. Sheppard, Ms Kibble, I thank you for allowing time to present today and I must say I do not envy your job. The SSHEG confirms its objection to this proposal despite new information presented by the applicant and do not believe this additional information has made any difference to our concerns about cumulative impacts on Air quality, health and the environment and other issues previously raised. We believe there is enough evidence from the Air Quality Network data and the commissioned reports on the impacts to Camberwell to say no! Enough is enough! However I would like to submit further information for your consideration. We would like to present a 24hr average graph from the Upper Hunter Air Quality Networks website for the period of mid July 2011 to yesterday. You will see that this early evidence confirms the impact already being felt and the real need to be cautious. We would also like to present articles in the form of;

1. Submissions against the T4 Coal Loader Application; in particular and whilst not directly related express the concerns of leading health professionals and strongly support our view and that of the Department of Health that the impacts on health and the environment are too great a price to pay.

One submission is written by leading health professionals Nick Higginbotham Phd, Ben Eweld MBBS Phd, Graeme Horton, MEnvStud,MBBS,Phd Candidate, John Hall, MBBS,MTH,FAFPHM, Abul Hasnat Milton, MBBS,M.Sc.[Epidemiology] Phd, Mark McEnvoy, Grad.Dip,[Genetic Counseling], MMedSci [Clinical Epidemiology, Phd Candidate and details the health impacts of further coal expansion and coal rail transport on an already overloaded system and supports the air quality concerns for both Lower and Upper Hunter Communities. The other submission is from Doctors for the Environment also expresses concerns.

2. ‘The Myth of Cheap Coal’ by Linda Connor Professor of Anthropology University of Sydney and

Stuart Rosewarne Senior Lecturer in Political Economy University of Sydney. May 2012.

3. The other items I wish to publically present are two letters; One directly address to the PAC from NSW Health which I believed or would hope you have copies and the other again rom Health to the NSW Planning.

Both letters clearly indicate that NSW Health does not support this application and would not consider it until and I quote “such time that other coal mines in the region cease to operate, leading to lower cumulative particulate impacts and further notes the unsatisfactory noise impacts.”

The reason we are presenting these letters is because as a community members we have never seen the original comments by the Health Department to the Department of Planning. In fact personally I have never ever seen comments like this before in all the years I have been associated with raising air quality issues. We would suspect there are other letters such as this from other Departments. You can spend hours looking for them only to get a blank page. We can only presume the Department of Planning gave the original submission and others the same weight as “I am going to buy an ice cream” as it continues to support this application and ignores warnings from Health in relation to mining related activity in this Valley. We find it extraordinary that the NSW Department of Planning in light of a direct comment from Health and I quote “ in their opinion the Air Quality model for Ashton is substantially underestimated” continues to support this development. Just one other thing the word receptor used to describe people or residents is offensive the word de humanizes this community. We have no confidence in the NSW Dept. of Planning’s assessment process when the Human and Environmental Health can be dismissed with a statement like this “the Department is satisfied with the projects residual impacts can be adequately mitigated, managed, offset and/or compensated ”. We do not have the confidence that the department can ensure the conditions of consent will protect us or others given the perceived culture that mining is King from a variety of Government bodies and when at present breeches appear to be also mitigated, managed and compensated or offset and fines are no more than a slap in the face to the community who are affected. The department makes statements based on their assessments; who checks their assessment process? We have never been anti mining; we have constantly and consistently said we want a balance and we will continue to raise these very serious concerns while ever the balance is out of kilter. It needs fixing, it needs a catalyst and Ashton should be the catalyst. The NSW Health Department said no to this development. Health should be at the apex of any decision made. It is not up for negotiation. Your first decision was the right one. The decision to say no to this development again will stimulate change, and perhaps have far reaching benefits for the Communities and residents of Camberwell, Singleton and the Upper Hunter. Thank You Lyn MacBain JP, ADLAH For the SSHEG 31.5.2012

Newcastle Public Health Professionals T4 Submission, 2 May 2012

Submission to NSW Dept of Planning & Infrastructure

Opposing PWCS T4 Coal Loader

2 May, 2012

From Newcastle Public Health Professionals

Contributors

Nick Higginbotham, PhD

Ben Ewald, MBBS, PhD

Graeme Horton, MEnvStud, MBBS, PhD Candidate

John Hall, MBBS, MTH, FAFPHM

Abul Hasnat Milton, MBBS, M.Sc (Epidemiology), PhD

Mark McEvoy, Grad. Dip. (Genetic Counseling),

MMedSci (Clinical Epidemiology), PhD Candidate


Summary

As public health professionals, we regard the Port Waratah Coal Services Terminal 4

development as a significant threat to public health.

When the Port of Newcastle reaches the planned 331 Mtpa in coal exports, coal train

movements from the Port of Newcastle to Muswellbrook and beyond will triple, with

108,000 coal train pass-bys per year (one every 4.9 minutes) in some townships. This

increase poses health risks for residents living alongside the rail corridor from

exposure to fugitive coal dust, diesel engine exhaust and train noise. T4 will contribute

39,344 of these annual train pass-bys.

Significantly, the EA has not modeled the cumulative impact of adding fugitive coal dust

and other pollutants into the air surrounding the rail corridor. For T4 bound trains it

gives PM10 estimates from loaded coal trains up to only 20 m beside the tracks (a

projected additional up to 13 ug/m3, 24 hours). Exposures for residents up to 300 m

away should be modeled.

The EA fails to assess baseline air quality along the rail corridor and how it will be

affected by all train movements when the port is operating at 331Mtpa. Emissions

modeling and actual measurement are essential to report the cumulative impact of

this continuous flow of trains in terms of PM10, PM2.5, diesel combustion pollution,

and concentrations of Ultra Fine Particles. Modeling should include both the residual

coal dust in unloaded wagons, as well as coal dust accumulated around the tracks over

time that becomes airborne by the passage of trains.

By 2020, residents near rail lines will be exposed to an almost continuous intrusion of

train noise and vibration. Round the clock movements will include 135 nightly pass-bys

(32 added by T4) when most residents are trying to sleep (between 11pm and 7am).

Sleep is a biological necessity and disturbed sleep from intrusive noise has adverse


health impacts, especially among children, the chronically ill and elderly, pregnant

women, people under stress and shift workers.

The EA states that rail noise increases at night will push the 60dBA level impact zone

from 320 m to 370 m from the tracks. This will increase significantly the number of

residents exposed to noise disturbance. In 2009 the European standard for night noise

was set at 40dBA.

The proponents state that T4 operations, with 120Mtpa of coal loaded onto 1,379

vessels annually at five berths, will achieve acceptable levels of dust emissions (PM10 &

PM2.5) for surrounding residents. Critical flaws in dust modeling cast serious doubt on

these predictions as they are based on assumptions about weather conditions, the

accuracy of other projects’ emissions estimates, and fidelity of implementing ‘world

best practice’ dust mitigation control operations, continuously, without fail.

The EA does not provide a Health Impact Assessment whereby population profiles of

affected residents near the Kooragang site and rail corridor are defined and potential

health impacts, especially on vulnerable groups (children, those in aged care facilities,

people with existing respiratory and cardiovascular morbidity) assessed. Many of the

local areas affected by the T4 include low income and elderly residents, who are most

disadvantaged in terms of health status and who are most vulnerable to the added

impacts of air and noise pollution.

The EA air quality modeling is inadequate to protect the public’s health because it fails

to include risk information about short-term exposures to particulates, which, over a

period of even a few hours, can trigger cardiovascular-related mortality and morbidity,

as well as adverse respiratory events. Even 15 minutes of exposure to diesel exhaust at

300ug/m3 produces significant cardiac ECG changes in susceptible people. Peaks of this


magnitude can frequently be hidden within a 24 hour average of less than 50ug/m3.

T4 provides the necessary conditions for burning 120Mtpa of black coal, producing

298.6 million tonnes of CO2 or 55% of Australia’s current CO2 emissions, and almost

twice NSW’s total emissions. In global terms, 298.6 mt of CO2 is about 60% of the CO2

that was added to the atmosphere globally in 2010 beyond the 2009 levels. This is a

significant contribution to the health damaging effects of global warming, in Australia

and overseas, produced through greenhouse gases.

Australian Academy of Technological Sciences and Engineering estimates that the

monetary costs of damages to health due to the pollution from coal-fired power stations

in Australia is $2.6 billion per annum, or $13/MWh. The T4 coal is destined to be burned

in foreign countries and we are concerned that this health burden will fall on the

population of those countries. The 120mt of T4 coal when burned will create costs

associated with pollution damage to human health of $11.7 billion.


I. Introduction

As a group of Newcastle public health professionals, who teach medical and public health

students, conduct public health research, and, in some cases, provide direct clinical care, we

oppose the proposed Port Waratah Coal Services Terminal 4 development based on its

significant threat to public health.

Our review of the proposal from a health perspective has identified 5 critical flaws in the EA

that merit the project’s rejection. These are:

unsafe assumptions underlying air quality monitoring;

failure to provide a Health Impact Assessment of vulnerable populations;

failure to consider cumulative impacts of increased pollution from coal wagons and

diesel locomotives on populations living near the rail corridor;

failure to consider research linking short term particulate exposures and

morbidity/mortality; and ,

neglect of the adverse health outcomes associated with global warming contributed, in

part, by mining, transporting, and burning coal.

II. Unsafe assumptions of the EA air quality modeling.

The EA assumed in its modeling of air quality associated with site operations that: 2010

meteorological conditions will prevail into the future; that an array of world best practice dust

suppression practices will be followed without fail; and that the environmental assessment data

from 5 approved future developments and expansions are accurate.

First, meteorological analyses used by Hunter councils (Blackmore & Goodwin, 2008, 2009)

have found that the projected frequency of weather patterns responsible for extreme storm

events along the NSW coast are likely to increase, suggesting a higher probability of an east

coast low formation during autumn/winter. Projected increases in the synoptic pattern linked


to high maximum temperatures during summer and autumn are likely to result in an increased

frequency of extreme heat days in both coastal and central zones by 2020. Such extreme

weather events, ironically brought on in part by CO2 from burning coal, would potentially

exacerbate pollutants escaping from the site, leading to more days exceeding air standards

than estimated based on 2010. Adding the turbulence of future weather patterns to the

modeling is essential. In particular, higher temperatures with predominantly westerly winds,

drying the air and blowing dust, will pose greater risk of higher particulate levels.

Second, air quality monitoring was based on presumed dust suppression practices at the site

that proponents stated will (or should) be implemented during operations (Table 12.10, pg 242,

Chpt 12). A reasonable person who has lived near an industrial site will be highly skeptical that

all of the 8 dust measure systems listed on page 242 will be implemented with fidelity on all

occasions without fail. Despite the best intentions of managers, breaches do occur, and can

lead to spikes in pollution. This recently occurred with ammonia releases from Orica reaching

residential areas of Mayfield, leading to people being overcome by fumes (Sydney Morning

Herald, 3/1/12).

Moreover, it would be difficult to estimate accurately, across all those suppression measures,

how much each contributes individually (or collectively) to a reduction in particulates escaping

into neighbouring areas. Table 39 (pg. 72) in the Air Quality Assessment presents the estimated

control efficiencies for 6 dust suppression techniques, which range from 25% to 85% efficiency.

With all these measures operating, the site still produces 0.8 tonne of TSP per day. Should they

not suppress dust as predicted there could be up to 2 tonnes of TSP per day emitted from that

site. Wind erosion of the stockpiles is 50% even with dust suppression, indicating that the

stockpiles should be enclosed. More realistic particulate concentrations should be presented,

based on real vs ideal suppression possibilities, in order for a proper assessment of the project

to be made.

Third, the cumulative concentration of air pollution is based on taking into consideration the EA

data from five other approved development sites. Given the goal of all EA applicants is to


minimise the estimated level of their predicted pollution contribution (as above), or to argue

that they will reliably apply pollution control procedures, it can be concluded that this T4 EA

underestimates significantly what the actual pollution levels will be when all these sites are

operational. One of the proponents included in the five sites is Orica. The findings of the NSW

Parliamentary Inquiry on the Kooragang Island Orica chemical leak stated that the approach by

the company was grossly inadequate to address the potential impact of the leak and that there

was an inadequate response by the company to the incident.

http://www.parliament.nsw.gov.au/Prod/parlment/committee.nsf/0/2aaffe5684a88ac6ca2579

ac007c4430/$FILE/120223%20Orica%20Report.pdf

It is therefore difficult to trust in the information on projected pollution levels promised by

these operators.

III. Missing Health Impact Assessment

Appendix D acknowledges the (deep and long held) concerns of Hunter residents about the

health risks from air pollution associated with coal mining, transport and burning. It is widely

recognized that these industries have imposed a risk to human and environmental health that is

unparalleled elsewhere in NSW if not Australia (Higginbotham, et al 2010). NSW Health has

recently responded to community sensitivities on this issue with a series of health reports and

by setting up of the air quality monitor network in the Upper Hunter. This response recognizes

that mining-affected residents of the Hunter expect, and will energetically pursue, a

trustworthy health impact study associated with developments such as the T4. Consequently,

the bar has been raised in terms of what is acceptable EA practice from the community’s

viewpoint. Air quality modeling alone is not sufficient. A proper best practice Heath Impact

Assessment, that includes equity aspects, is required as an essential component of the EA.

Doctors for the Environment Australia (DEA) has argued strongly for adoption of the 2001

Health Impact Assessment guidelines under which development proponents “explicitly address

potential impacts on human health.”

http://dea.org.au/images/uploads/submissions/MDB CSG Senate submission June 2011.pdf

https://groupwise-web.newcastle.edu.au/webaccess/webacc?User.context=mt7ix3Yd2lv7im8Pu2&merge=linkurl&Url.linkText=http%3a%2f%2fwww%2eparliament%2ensw%2egov%2eau%2fProd%2fparlment%2fcommittee%2ensf%2f0%2f2aaffe5684a88ac6ca2579ac007c4430%2f%26%2336%3bFILE%2f120223%2520Orica%2520Report%2epdf

https://groupwise-web.newcastle.edu.au/webaccess/webacc?User.context=mt7ix3Yd2lv7im8Pu2&merge=linkurl&Url.linkText=http%3a%2f%2fwww%2eparliament%2ensw%2egov%2eau%2fProd%2fparlment%2fcommittee%2ensf%2f0%2f2aaffe5684a88ac6ca2579ac007c4430%2f%26%2336%3bFILE%2f120223%2520Orica%2520Report%2epdf


Australian experts in this field (e.g., Harris and Harris-Roxas, 2010), have long engaged with

government stakeholders showing how to add assessment of human health in project EAs. An

appropriately designed Health Impact Assessment of T4 will undertake the following: a) Set up

a steering committee involving health experts, community stakeholders, and project personnel;

b) develop a population profile of affected residents (both around the site and all along the rail

corridor; c) collect information on potential health impacts affecting vulnerable groups such as

children, the elderly, pregnant women, people in aged care facilities, schools, as well a profile

of those with pre-existing morbidity; d) critically assess the information and prioritise health

impacts; e) develop recommendations for project proposal modification.

The current EA gives only general census data about Newcastle LGA. This is wholly inadequate

for anticipating health impacts on nearby vulnerable residents, based on their demographic and

current health status profile. Many of the local areas affected by the T4 include low income and

elderly residents, who are most disadvantaged in terms of health status and who are most

vulnerable to the added impacts of air and noise pollution. This entire dimension of

understanding of the project’s impact is left out and that is unacceptable to best practice and

community expectations.

IV. Significant increase in Uncovered Coal Wagons Along Rail Corridor

The EA downplays the significant adverse health risks from fugitive dust emissions, diesel

engine exhaust (DEE) and noise caused by the sharp increase in train movements along the rail

corridor from Muswellbrook to the Port.

It fails to put the modeled emissions (an additional 13 ug/m3, 24-hour PM10 concentrations

from uncovered wagons) into a cumulative emissions context. The EA does not give PM2.5

estimates or combustion-related emission concentrations from the diesel locomotives.

Moreover, dust from residual coal in unloaded wagons making the return trip to the mine sites

were not included, nor the return trip diesel exhaust.


These are significant omissions. Based on each train carrying a maximum of 6,100t of coal (as

per EA Air Quality Assessment pg 192), and the port capacity achieving over 330Mtpa by 2022,

then many residents living in proximity to the rail corridor can expect at least 108,000 coal

train movements past their houses per year (i.e., 54,000 round trips) with T4 trains

contributing 39,344 of these total pass-bys.

Oddly, the EA states that T4 will require 92 daily train movements or 33,580 per year (32 of

these each night). This figure, shown in Table 47, pg 60 (Noise & Vibration Impact Assessment),

appears to significantly underestimate the movements and should be explained. Table 47

shows 254 daily coal train pass-bys in areas close to Newcastle (92,710 per year). With the

addition of passenger and freight trains, it states there will be 388 daily train movements (i.e.,

approximately 140,000 per year). Community consultation by all the affected townships and

LGAs about this proposed burden on environmental health must be carried out prior to a

determination of the T4 EA.

(A) Poor air quality.

Further emissions modeling or actual field measurements must also be carried out to report the

cumulative impact of this continuous flow of all train movements in terms of PM10, PM2.5,

diesel combustion pollution, and concentrations of Ultra Fine Particles. Modeling should

include both the residual coal dust in empty wagons, as well as coal dust accumulated around

the tracks over time that becomes airborne by the passage of trains. The ‘uncovered’ wagon

estimates are most appropriate to anticipate risk.

The combined diesel combustion (plus un-combusted diesel) and dust emissions could generate

unacceptable concentrations in some areas and during certain weather conditions. Diesel

engine exhaust (DEE) is classified as a probable human carcinogen. In Great Britain, DEE was the

sixth most important occupational carcinogen, contributing 8.1% of the deaths and 5.9% of the

cancer registrations (Rushton, 2010). Rushton (2012) reviewed recent DEE studies, noting a

sharp rise in cancer risk at lower levels of diesel exhaust; background levels as little as of 1–2

μg/m3 were still likely to carry a small excess risk. Substantial proportions of the population

exposed at these low levels, would thus contribute to the burden of cancer from DEE. He


argues that reduction of DEE in the general environment, not just occupational control

measures, is becoming increasingly important and is essential if the health of large numbers of

people is not to be compromised.

Australian air quality authority Lidia Morawska (2010) has voiced considerable concern about

diesel engine exhaust along Sydney’s highest polluting motorways. In the M-5 tunnel, for

example, hourly heavy diesel vehicle (HDV) traffic volume was a very good determinant of

health damaging Ultra Fine Particle concentrations (Knibbs, 2009). She warned that the levels of

ultrafine particulate matter were so high that motorists suffering asthma, chronic pulmonary

disease or influenza would feel its effects ''immediately or very soon after'. ''Even in a healthy

person, with none of those conditions, chronic exposure in the form of using the tunnel daily

for a year or two could lead to respiratory problems.''). http://www.smh.com.au/national/m5-

east-pollution-harming-asthmatics-20090827-f183.html#ixzz1sI6anIna

Morawska’s research raises the question of what Ultra Fine Particle concentrations will arise

with the ultra heavy diesel locomotives operating at high frequencies along the rail corridor?

Furthermore, as described above, a Health Impact Assessment on the populations exposed to

these emissions along the track corridor must be performed. Figure 1F in the Air Quality

Appendix (pg. 193) indicates that residents up to 150 m from the rail line are expected to have

a continuous inflow of some TSP concentrations. But, we also expect those living further away

will be exposed to PM2.5 emissions and smaller particulates. Morawska (2010) has found that

“in terms of their number concentration, exposure to airborne particles is significantly

increased within the first 100 meters from the road, compared to average urban exposure

levels, and usually decreases to the urban background level at distances greater than 300 m

from the road.”

We need information on how many residents are within the range of particulate exposures

coming from these trains based on Morawska’s (2010) criterion of 300 m not the 20 m

suggested by the EA. We need to understand the exposed population’s age and social status,

the profile of illnesses in these areas and so forth. Of particular concern are those with existing

respiratory illnesses (especially children) and cardiovascular disease. NSW HNE Health data for

http://www.smh.com.au/national/m5-east-pollution-harming-asthmatics-20090827-f183.html#ixzz1sI6anIna

http://www.smh.com.au/national/m5-east-pollution-harming-asthmatics-20090827-f183.html#ixzz1sI6anIna


areas affected by coal mining and power generation show higher rates (compared to State

averages) of hospital attendance for respiratory conditions, including asthma, cardiovascular

disease and deaths from all causes and cardiovascular disease (NSW Health, May 2010). The

Upper Hunter Air Quality Monitoring data show that the existing ambient air quality of several

of the townships along coal freight lines can be poor. For example, 24-hour standard

exceedances were recorded in 2011 for PM10 in Singleton and PM2.5 in Muswellbrook (Dalton,

et al 2011), and the poor air quality in Camberwell is well documented.

(B) Physical and Mental health impact of noise.

Of considerable importance is establishing the adverse health impacts on residents exposed to

an increased (almost continuous) frequency of intrusive train noise and vibration. The

increased frequency of trains means that there will be round the clock movements. The EA

expects, for example, 135 nightly pass-bys (32 added by T4) when most residents are trying to

sleep (between 11pm and 7am) (Table 47, Noise Assessment). The health impact of the night

time cumulative intrusion of noise in particular must be assessed.

World Health Organization Europe (2009) recently reviewed night time noise impacts and set a

new nighttime standard of 40dBA to protect the public from adverse health effects of night

noise, particularly vulnerable groups such as children, the chronically ill and the elderly, but

also, pregnant women, people under stress and shift workers.

The scientific review concluded that:

• Sleep is a biological necessity and disturbed sleep is associated with a number of

adverse impacts on health. The review found sufficient evidence:

1. for biological effects of noise during sleep: increase in heart rate, arousals, sleep

stage changes and awakening;

2. that night noise exposure causes self-reported sleep disturbance, increase in

medicine use, increase in body movements and (environmental) insomnia;

3. Environmental insomnia leads to further consequences for health and wellbeing.


• Less conclusive evidence was found that:

1. disturbed sleep causes fatigue, accidents and reduced performance;

2. noise at night causes hormone level changes and clinical conditions such as

cardiovascular illness, depression and other mental illness. A plausible biological

model is available with sufficient evidence for the elements of the causal chain

(WHO Europe, 2009).

The EA acknowledges that rail noise will increase by 1.5dBA during Stage 3 operations, and that

this will add to rail noise levels that currently exceed OEH trigger levels and EPL goals at houses

less than 130m to tracks (daytime 65dBA) and less than 370 m from tracks (nighttime 60dBA).

The project impact during nighttime (LAeq(9hour)) will increase trigger levels and goals by up to

50m (60 dBA levels move from 320 m to 370 m from tracks).

It is critical to identify the number of houses within the 370 m nighttime noise impact zone and

assess the population’s vulnerability. If the 2009 European standards for nighttime noise were

adopted (40dBA), there would be far more houses in the night noise disturbance zone. This is a

major public health issue that must be mitigated with sound barriers all along the residential

areas exposed.

The list of towns and suburbs through which these trains pass is substantial, with many

residents living within 200 m of the tracks. These include: Warrabrook, Sandgate, Hexham,

Tarro, Beresfield, Thornton, Metford, East Maitland, South Maitland, Maitland, Telarah,

Rutherford, Allandale, Greta, Branxton, Belford, Whittingham, Singleton, Darlington, Singleton

Heights, Camberwell, Muswellbrook, Aberdeen, Scone, Murrurundi and all the way to Narrabri.

In addition, trains servicing the Carrington Coal Loader pass adjacent to the University of

Newcastle, Callaghan, then through densely populated urban areas of Waratah, Mayfield, and

Tighes Hill. Each of these townships is a stakeholder in the decision about the sharply increased

train traffic. Indeed, a proposed $66m retirement and aged-care complex at Shortland Waters

golf course was just announced. The map shows it borders the rail line to Carrington and lies

within 400 m of the line to Kooragang coal dumps.


The particulate impacts of these pass-by and noise level increases need to be fully understood

and analysed by health authorities before the project can be further considered. Community

and LGA consultation that fully explains this issue is essential. The EA listed figure of 100 houses

only being affected is implausible, and the magnitude of impact presented in the EA is

inconsistent with both the available data and the current scientific literature.

V. Inadequacy of Air Quality Standards

Through the transportation and loading of 120mtpa of coal, T4 will impose additional

unwelcomed health risks from particulates, combustion gases, and noise on residents living

near the port and railway lines. Residents shouldering an excess burden of environmental ill

health should have a significant say in the final decision. If this does not occur, then by

definition, the government has imposed environmental injustice on these citizens, which is

intolerable in a society valuing democracy and fairness.

(A) Literature Review

A key question is whether air quality standards adequately protect the Newcastle urban and

Hunter township communities from the impacts of T4 operations, particularly residents more

vulnerable to the effects of increased pollution due to their age, existing health status,

economic circumstances, housing conditions, and proximity to the rail and port. The EA

concludes that current standards are adequate because coal dust (referred to obliquely as

‘particles derived from mechanical attrition processes’) is less toxic than combustion-related

particulates found in urban areas, which agencies used as the basis for setting PM10 limits.

The EA also concludes that particle size may be more important than composition in

determining health effects, implying that coal dust, which is larger, will have less effect on

health than any particulates that are smaller.

We found the literature cited in the EA review did not justify these conclusions. Both types of

particulates are toxic but may produce a different disease pattern (David Shearman, personal

communication, 23 April, 2012). The review was at best superficial and distorted the findings of


several studies that were cited. For example, the EA cites the National Institute for

Occupational Safety and Health (NIOSH, 2010) literature review to support the point that coal

dust does not cause cancer. Yet, the NIOSH report notes that “Lung cancer has been suspected

to arise in coal miners because of their exposure to crystalline silica dust, which is a Group I

carcinogen (p. 25). Thompson et al (2007), cited in the EA, state that ‘coalmine dust….[is a]

mixed dust that includes silicates and small concentrations of crystalline silica…the toxicity of

coal lies between that of titanium and silica” (p145). Moreover, NIOSH (2010), while noting

conflicting findings linking coal dust and lung cancer, did find a recent British coal mining study

which included cumulative crystalline silica dust exposures. This study, by Miller & MacCalman,

( 2010) found evidence of an association between increased risks of lung cancer and increased

quartz exposure, particularly at a lag of 15 years. (It is worth noting that NIOSH (2010) reported

a rising prevalence of Coal Workers’ Pneumoconiosis (CWP). Younger workers are developing

CWP, which may be caused, in part, by increases in crystalline silica exposure. This increase is

occurring despite the Coal Mine Health and Safety Act.

Second, the EA referes to a study by Hendryx & Ahern (2008) linking health survey data on

16,400 West Virginia residents with proximity to coal production. This study found an effect on

COPD, cardiopulmonary and lung disease, among others. The EA dismisses the value of this

study by repeating a list of criticisms written by Entech (2010) on behalf of Scottish Coal. The

EA misses an opportunity to explore the value of Hendryx & Ahern’s body of work in this field

and to describe the trends in their population-based approach to linking proximity to coal

production with mortality and morbidity. Hendryx & Ahern’s initial survey was a “screening test

to examine whether coal mining poses a health risk for adults living near the mining sites.” They

followed up this study with further research examining elevated lung cancer mortality in

Appalachian coal mining areas; elevated mortality from heart, respiratory, and kidney disease in

these areas; and, most recently, the association between mountaintop mining and birth defects

among live births in central Appalachia, 1996–2003 (Hendryx, 2009; Hendryx, O’Donnell, &

Horn, 2008; Ahern & Hendryx, et al., 2011). Interestingly, NIOSH (2010) found that Hendryx &

Ahern’s study area was a ‘hot spot’ for re-emergence of Coal Workers’ Pneumoconiosis.


One further example of the distortions evident in the EA literature citation is the statement (p.

199) that Thompson et al’s (2007) “key outcome” was their recommendation to adopt a 24-

hour maximum PM10 criterion of 70 ug/m3 at Port Hedland because the mining dust is less

hazardous than combustion derived pollution in urban areas. A close reading of the Thompson

et al. document suggests that they would have recommended a more stringent level had the

local dust been from coal mining. Significantly, their “most important” recommendation was

that “reliable, valid data should be collected in order to inform future decisions.” This was

warranted because, “In the absence of informative data, it is difficult to reach a conclusion

regarding an Air Quality Standard that would be appropriate for the Port Hedland community

(p146).” The “interim” standard of 70 ug/m3, appeared to have been very reluctantly made,

and was based on the standard suggested by a 2005 US EPA Clean Air Science Advisory

Committee for the USA.

(B) Short term Pollution Effects Must be Considered

We believe current standards, and the modeling approach adopted for this EA, are inadequate

to protect the public’s health because they fail to include risk information about short-term

exposures to particulates, which, over a period of even a few hours, can trigger CVD-related

mortality and nonfatal events including MIs, heart failure, arrhythmias, strokes, and adverse

respiratory events. Experimental work has demonstrated that even 15 minutes of exposure to

diesel exhaust at 300ug/m3 produces significant cardiac ECG changes in susceptible people.

Peaks of this magnitude can frequently be hidden within a daily mean of less than 50ug/m3

(Mills, 2007).

Experimental, clinical, and population data demonstrate the necessity of considering short-term

exposures in planning decisions, and informing the public of air quality hazards on a continuous

monitoring basis, rather than 24 hour averages which mask possible pollution spikes. Such an

approach is supported by research findings showing that, in terms of the relationship between

particulate concentrations and adverse health endpoints: a) there is no threshold in response;


b) the response is linear; c) despite the differences in particle composition, the response is

similar over different geographic settings (Morawska, 2010, citing Pope & Dockery, 2006).

Moreover, Pope & Dockery’s (2006) comprehensive review found that numerous researchers

using various methods, consistently observe adverse mortality associations with short-term

elevations in ambient particulates.

Other research supporting the significance of considering short-term exposures includes

McCreanor et al (2007) who found clinical effects of traffic-related pollutants among persons

with asthma. Asthmatic adults walking for only 2 hrs along a street in the center of London had

a significant decrease in lung function as opposed to walking in a nearby park. In Darwin,

Johnson et al (2006) examined the relationship between particulates generated by deliberately

lit vegetation fires and daily respiratory health in 251 adults and children with asthma over a 7-

month period. PM10 ranged from 2.6 - 43.3 ug/m3 and was significantly associated with onset

of asthma symptoms, commencing oral steroid medication, the mean daily symptom count and

the mean daily dose of reliever medication. The importance of this study was that there was

only 1 exceedence of the 50ug/m3 PM10 standard during the study period. It documented

significant adverse health effects well below the accepted air quality standard for PM10

particulates. (See also Morawska’s statements above about the M5 tunnel.)

Weinmayr et al. (2010) completed a meta-analysis of the short-term effects of PM10 on

respiratory health among children with asthma (mean 24 hour average for PM10 ranged from

11- <100ug/m3). Across 36 studies in the analysis, they found clear evidence of effects of PM10

on the occurrence of asthma symptom episodes, and to a lesser extent on cough and PEF, and

conclude that there is a need to protect asthmatic children with strict air quality standards for

PM10.

Complementing the respiratory studies is the 2010 Scientific Statement from the American

Heart Association reviewing new evidence linking short term PM2.5 exposure with

cardiovascular disease (AHA, 2010). They conclude that short-term exposure to PM2.5 over a


period of a few hours to weeks can trigger CVD-related mortality and nonfatal events among

susceptible individuals (including women and obese). The PM2.5 concentration—cardiovascular

risk relationships for short-term exposures appear to be linear (monotonic), extending below 15

ug/m3, without a discernable ‘safe’ threshold. Thus, public health benefits would accrue from

lowering the PM2.5 concentrations even below the present day USA standards. Many potential

biological mechanisms exist whereby PM2.5 exposure could exacerbate existing CVDs and

trigger acute events over the short term. They conclude that the evidence is consistent with a

causal relationship between PM2.5 exposure and CVD morbidity and mortality.

In sum, health effects occur even at exposure levels below current air quality guidelines,

and for many pollutants, it is unclear whether a safe threshold exists. The burden of disease

is proportional to the level of exposure. These findings appear the same in all communities

studied throughout the world (Shearman & Selvey, 2012; and

http://dea.org.au/images/general/DEA_Air_Pollution_Policy_03-12.pdf).

VI. Cost of Global Warming from Burning 120mtpa of Coal

The EA report obscures the impact of Scope 3 GHG emissions by placing it in the context of

expected 2030 global emissions. From the EA, readers would not understand that burning

120mtpa of black coal, which produces 298.6 million tones of CO2, is actually about 55% of

Australia’s current CO2 emissions (550mt), will be 37% of Australia’s projected CO2 emissions in

2030, and is almost twice NSW’s total CO2 emissions (161mt in 2009). In terms of today’s

decision-making, this project alone will export about half of our current CO2 GHG burden to

other countries. Ironically, given global warming is a planetary problem, combustion of this coal

will boomerang to affected Australia, which is especially vulnerable to global warming effects,

as described below.

(A) Health Costs (Externalities).


Economists and public health experts have collaborated to estimate the monetary costs of

public health damages due to coal mining and combustion (i.e. externalities). More broadly,

however, Yale University economists have estimated air pollution damage from different USA

industries (Muller, et al. 2011). Solid waste combustion, sewage treatment, stone quarrying,

marinas, and oil and coal-fired power plants have air pollution damages larger than the

monetary value they add to the general economy. The largest industrial contributor to external

costs is coal-fired electric generation, whose damages range from 0.8 to 5.6 times the economic

value added by the industry (Muller, et al. 2011). In other words, the public health costs of

treating disease caused by coal-fired electricity is between 0.8 and 5.6 times the value of the

electricity that is produced. Similarly, a group coordinated by Harvard Medical School estimated

the public health burden in mining communities and from air pollution from combustion to be

$75 billion and $188 billion respectively in the USA (Epstein, et al., 2011).

The Australian Academy of Technological Sciences and Engineering (ATSE, 2009) estimated that

the total health damage cost from coal-fired power station emissions in Australia is about $A2.6

billion per annum based on a figure of $13/MWh. Researchers found that the ExternE

methodology for estimating health damage costs of emissions in Europe is applicable to

Australian power stations, and that reasonable relative cost estimates result when the

methodology is used to scale down health damage in proportion to Australia’s lower population

density. A senior Sydney University political economist independently reviewed the ATSE

modeling, along with the two American studies, and concluded: “The estimates of externalities

provided by Muller, et.al., and Epstein, et.al., are generally accepted within academic debate

and probably err on the conservative. The ATSE report does this in effect.” (Dr. Stuart

Rosewarne, personal communication, 22 April, 2012).

If the figure of $13/MWh is applied to burning 120mtpa from T4, the adverse public health

impost of this combustion would be $11.7 billion dollars per annum in Australia (assuming 1

tonne black coal generates 7.5MWh; thus, T4 exports produce 900 million MWh x $13/MWh).

Japan, Korea and China are the likely combustion locations for the exported coal. Their higher


population densities would increase levels of health damage, while their health care systems

costs are likely to be both more expensive (Japan) and less expensive (Korea, China) than ours.

On balance, therefore, these health damage costs may well be applicable.

(B) Health Impacts

The World Health Organization also regards climate change as one of the greatest threats to

public health, as it will affect a number of the basic determinants of health (clean air and water,

food security, levels of disease vectors, etc), especially in countries with lower incomes. Current

estimates for global annual deaths attributable to climate change are 300,000 to 400,000 (DEA,

2011). As with increased particulate concentrations, it is the elderly, the very young, the

pregnant, the poor and the chronically ill who are most vulnerable to the impacts of global

warming.

Haines et al. (2006) describe the pathways by which climate variability and change produce a

range of adverse health effects, including heat stress, storm injuries, enhanced air pollution

illnesses, vector-borne infectious diseases and diarrhoeal diseases. Most critically, extremes of

temperature and rainfall (e.g., heat waves, floods, drought) will have direct immediate effects

on mortality. Biodiversity and the ecosystem goods and services that we rely on for human

health will be detrimentally affected. Sea level rise, flooding and environmental degradation

will lead to population displacement and more environmental refugees (Haines, et al., 2006). In

particular, interruption of food security will directly and indirectly lead to increased mortality in

developing countries.

CSIRO (2011) describes future Australian climate scenarios. The best estimate of annual average

warming by 2030 (above 1990 temperatures) is around 1.0ºC across Australia, with warming of

0.7–0.9ºC in coastal areas and 1–1.2ºC inland. By 2070 warming is expected to be between

2.2ºC and 5ºC. Recent emission observations by the US Department of Energy confirm that the

2007 IPCC worst-case emission trajectories have been exceeded

(http://cdiac.ornl.gov/trends/emis/perlim_2009_2010_estimates.html).

http://cdiac.ornl.gov/trends/emis/perlim_2009_2010_estimates.html


Drying is likely in southern areas of Australia, especially in winter, and in southern and eastern

areas in spring, due to a contraction in the rainfall belt towards the higher latitudes of the

southern hemisphere. Changes in summer tropical rainfall in northern Australia remain highly

uncertain. Intense rainfall events in most locations will become more extreme, driven by a

warmer, wetter atmosphere. The combination of drying and increased evaporation means soil

moisture is likely to decline over much of southern Australia. An increase in fire-weather risk is

likely with warmer and drier conditions (CSIRO, 2011).

For Australia, heat waves are likely to have a major impact on human health (CSIRO, 2011).

Heat-related deaths for people aged over 65 in six of Australia’s largest cities are likely to

increase from around 1100 per year at present to around 2300–2500 by 2020 and 4300–6300

by 2050 (allowing for demographic change). During a 2-week heat wave in early 2009, 374 heat-

related deaths were recorded in Victoria. While most attention is focused on extreme heat

events, there is also the chronic effect of increased heat loads, which is exacerbated in urban

environments by the urban heat island effect.

Australia can expect an increase in disease due to the spread of insect vectors, with 0.6 to 1.4

million more people exposed to dengue fever by 2050, as well as a rise in waterborne and food-

borne diseases. Higher temperatures are likely to cause an increase in the concentrations of

volatile organic compounds (VOCs) and ozone in the atmosphere. An analysis of future climate

found that under a relatively high emission scenario, increased ozone pollution is projected to

cause a 40% increase in the projected number of hospital admissions by the period 2020–2030,

relative to 1996–2005, and a 200% increase by the period 2050–2060 (CSIRO, 2011). The T4 EA

did not provide any estimates of ozone pollution.

In 2010, the world released about 512 million tonnes more carbon into the air than it did in

2009, an increase of 6 per cent

http://cdiac.ornl.gov/trends/emis/perlim_2009_2010_estimates.html).

In this context, T4’s annual 298.6 mt of CO2 would be equivalent to about 60% of the CO2

that was added to the atmosphere globally in 2010 (beyond the 2009 levels).

http://cdiac.ornl.gov/trends/emis/perlim_2009_2010_estimates.html


In summary, while T4 will not directly combust the 120mtpa of black coal, it will create the

necessary conditions for doing so, and is therefore directly causally linked to consequent

adverse health conditions, and their costs, affecting Australia and other nations.

VII. References

Ahern, M.M., Hendryx, M. et al., (2011). The association between mountaintop mining and birth defects among live births in central Appalachia, 1996–2003. Environmental Research. (2011, in press) Aug; 111(6), 838-46. Epub Jun 22. American Heart Association (AHA). (June, 2010). Particulate matter air pollution and cardiovascular disease: An update to the scientific statement from the AHA. Circulation. 121, 2331-2378. (R.D. Brook, et al.). Blackmore, K.L. & Goodwin, I.D. (2008). Report 2: Climate variability o f the Hunter, Lower North Coast and Central Coast Region o f NSW. A report prepared for the Hunter and Central Coast Regional Environmental Management Strategy, NSW. Blackmore, K.L. & Goodwin, I.D. (2009). Report 3: Climatic change impact for the Hunter, Lower North Coast and Central Coast Region o f NSW. A report prepared for the Hunter and Central Coast Regional Environmental Management Strategy, NSW. CSIRO. (2011). Climate change: Science and solutions for Australia. Edited by H. Cleugh, et al. hhtp://www.publish.csiro.au/books/download.cfm?ID=6558 Dalton, C., Porigneaux, P., & Durrheim, D. (September, 2011). Community Briefing Notes, Particulates and Health. NSW Health, Hunter and New England Health, Population Health. Doctors for the Environment, Australia (DEA) (2011). Briefing from DEA on the health impacts of coal mining and pollution.

(http://dea.org.au/topics/article/briefing paper on the health aspects of coal and renewables) Entech. (February, 2010). Fine particulate matter from surface coal mining and public health. Final report. Report compiled by the consultancy Entec UK Ltd on behalf of the Scottish Resources Group. Epstein, P.R., Buonocore, J.J., Eckerle, K. (2011). Full cost accounting for the life cycle of coal. Annals of the New York Academy of Science. 1219, 73–98. Haines, A. & Kovats, R.S. (2006). Climate change and human health: Impacts, vulnerability, and mitigation. Lancet. 367, 2101-09.

http://dea.org.au/topics/article/briefing_paper_on_the_health_aspects_of_coal_and_renewables

http://dea.org.au/topics/article/briefing_paper_on_the_health_aspects_of_coal_and_renewables


Harris, P. & Harris-Roxas, B. (2010). Assessment of human health and wellbeing in project environmental assessment. In Project environmental clearance: Engineering and management aspects. Wide Publishing, 357-379. Hendryx, M. & Ahern, M.M. (2008). Relations between health indicators and residential proximity to coal mining in West Virginia. American Journal of Public Health, 98(4), 669-671. Hendryx, M. (2009). Mortality from heart, respiratory and kidney disease in coal mining areas of Appalachia. International Archives of Occupational and Environmental Health. 82, 243–249. Hendryx, M., O’Donnell, K., Horn, K. (2008). Lung cancer mortality is elevated in coalmining areas of Appalachia. Lung Cancer. 62, 1–7. Higginbotham, et al (2010). Environmental injustice and air pollution in coal affected communities, Hunter Valley, Australia. Health and Place. 16 (2), 259-266. Johnston F.H, Webby R.J., Pilotto L.S., et al (2006).Vegetation fires, particulate air pollution and asthma: a panel study in the Australian monsoon tropics. International Journal of Environmental Health Research. 16(6), 391-404. Knibbs, L., deDear, R., Mengersen, K., & Morawska, L. (2009). On-road ultrafine particle concentration in the M5 East road tunnel, Sydney, Australia. Atmospheric Environment. 43, 3510-3519. McCreanor, J. et al. (2007). Respiratory effects of exposure to diesel traffic in persons with asthma. New England Journal of Medicine. 357, 2348-58. Miller B.G., & MacCalman L. (2010). Cause-specific mortality in British coal workers and exposure to respirable dust and quartz. Occupational & Environmental Medicine. 67, 270–276. Mills, N., Tornqvist, H., &Gonzalez, M. (2007). Ischemic and thrombotic effects of dilute diesel-exhaust inhalation in men with coronary heart disease. New England Journal of Medicine. 357 (11), 1075-82. Morawska, L. (2010). Airborne particles and health. Air quality and climate change. 44 (2), 13-15. Muller, N.Z., Mendelsohn, R., & Nordhaus, W. (August, 2011). Environmental Accounting for Pollutionin the United States Economy. American Economic Review. 101, 1649–1675. The Australian Academy of Technological Sciences and Engineering (ATSE) (2009). The hidden costs of electricity: Externalities of power generation in Australia. ATSE, Parkville, VIC: Ian McLennan House. National Institute for Occupational Safety and Health (NIOSH). (2010). Coal mine dust exposures and associated health outcomes: A review of information published since 1995. Current Intelligence Bulletin 64. NSW Health. (May 2010). Respiratory diseases and cancer among residents in the Hunter New England

Area Health Service. (www.health.nsw.gov.au/pubs/2010/pdf/HNE Respi Cardio Disease.pdf) NSW Parliamentary Inquiry on the Kooragang Island Orica Chemical Leak (2012).

http://www.ncbi.nlm.nih.gov/pubmed?term=%22Johnston%20FH%22%5BAuthor%5D

http://www.ncbi.nlm.nih.gov/pubmed?term=%22Webby%20RJ%22%5BAuthor%5D

http://www.ncbi.nlm.nih.gov/pubmed?term=%22Pilotto%20LS%22%5BAuthor%5D

http://www.health.nsw.gov.au/pubs/2010/pdf/HNE_Respi_Cardio_Disease.pdf


Pope, C.A. & Dockery, D.W. (2006). Health effects of fine particulate air pollution: Lines that connect. Journal of Air and Waste Management Association. 56, 709-742.

Rushton, L. (2012). The problem with diesel. Journal of National Cancer Institute. 104 (11), 1-2. Rushton, L., Bagga, S., & Bevan, R., et al. (2010). Occupation and cancer in Britain. British Journal of Cancer. 102(9), 1428–1437. Shearman, D. & Selvey, L. (2012). Something in the air: time for independent testing in coal areas. The Conversation. 9 March, 6.35am AEST

https://theconversation.edu.au/something-in-the-air-time-for-independent-testing-in-coal-areas-5763 Thompson,P., Misso, N. & Woods, J. et al. (April, 2007). Literature review and report on potential health impacts of exposure to crustal material in Port Hedland. (Undertaken by the Lung Institute of WA & Institute of Occupational Medicine, UK, on behalf of the Dept of Health, WA). Weinmayr, G., et al. (2010). Short-term effects of PM10 and NO2 on respiratory health among children with asthma or asthma-like symptoms: A systematic review and meta-analysis. Environmental Health Perspectives. 118(4), 449-457. WHO Europe. (2009). Night noise guidelines for Europe. Cophenhagen: WHO Regional Office for Europe.

https://theconversation.edu.au/something-in-the-air-time-for-independent-testing-in-coal-areas-5763

https://theconversation.edu.au/something-in-the-air-time-for-independent-testing-in-coal-areas-5763

The following are members of our Scientific Committee and support the work of Doctors for the Environment Australia

Prof. Stephen Boyden AM; Prof. Peter Doherty AC; Prof. Bob Douglas AO; Prof. Michael Kidd AM; Prof. David

de Kretser AC; Prof. Stephen Leeder AO; Prof. Ian Lowe AO; Prof Robyn McDermott; Prof. Tony McMichael AO; Prof. Peter Newman; Prof. Emeritus Sir Gustav Nossal AC; Prof. Hugh Possingham;

Prof. Lawrie Powell AC; Prof. Fiona Stanley AC; Dr Rosemary Stanton OAM; Dr Norman Swan; Professor David Yencken AO

Port Waratah Coal Services Terminal 4

Environmental Impact Statement

Submission from Doctors for the Environment Australia

http://dea.org.au/images/uploads/submissions/T4 Coal Port Expansion -

Newcastle 05-12.pdf A massive coal port expansion (T4 coal port expansion) is proposed for

Newcastle. This will export 120 megatons of coal every year, which is almost

double the amount of coal currently exported from Newcastle.

Doctors for the Environment Australia is an independent, national, public health,

non-government, organisation of medical doctors.

Doctors for the Environment Australia has submitted comments on the EIS for

this proposal and strongly recommends that the coal port expansion does not go

ahead.

Newcastle is already a very polluted city, and according to the World Health

Organisation criteria, has levels of particulate pollution that will be harming

people’s health. Chronic exposure to particulate pollution has been linked to

heart and lung disease and even short term exposure to particulates is enough to

affect lung function and trigger asthma attacks in susceptible people. If the coal

port expansion goes ahead, together with at least five major developments that

have already been approved, the air quality in Newcastle can only get worse.

The EIS also underestimates the contribution of the proposed port expansion to

pollution in Newcastle. A low baseline is used, and a number of assumptions

made in the modelling are questionable.

Given that Newcastle is already polluted, a detailed characterisation of the air

pollution is warranted, together with a health impact assessment of the current

level of pollution. Only after this has been done should any other major project

proposals such as the port expansion be considered.

Dr Linda Selvey is available at

Monday 7th May

Tuesday 8th May 7-9 am Perth time and after 12.30pm Perth time.

http://dea.org.au/images/uploads/submissions/T4_Coal_Port_Expansion_-_Newcastle_05-12.pdf

http://dea.org.au/images/uploads/submissions/T4_Coal_Port_Expansion_-_Newcastle_05-12.pdf

The Myth of Cheap Coal Linda Connor and Stuart Rosewarne “Cheap coal” is a myth. And like all myths, we accept its wisdom without thinking. On a recent ABC Q&A show, Senator Nick Minchin said Australians “are blessed with hundreds of years of coal and gas resources” that give us “a comparative advantage in cheap energy” providing jobs for “thousands upon thousands of Australians.” The NSW government and the Minerals Council praise the benefits of coal: besides employment, it is the source of huge company profits as well as mining royalty payments ($1.17 billion in 2010-11). Burning coal generates most of the State’s electricity and coal is the State’s largest export revenue earner. But, what is the story behind coal? The numbers of people directly employed in mining in NSW is small, currently 47,600 or 1.36% of a 3.5 million workforce, with about 19,000 in the Hunter (6% of the region’s workforce). The benefits must be weighed against many hidden costs, including government subsidies to the industry; the damage to people’s health and the environment; and lost opportunities because of failure to develop other industries, including ‘clean’ energy. Both State and Federal governments provide subsidies to the coal industry. Direct subsidies include coal terminal lease fees and providing infrastructure, like expanded rail capacity and more rail stock, so that coal can be transported to electricity generators or to port loading facilities. In NSW, recent Federal government funding for the Hunter Valley Corridor Capacity Strategy rail upgrading totals almost $700 million, with further funding in the pipeline. The whole mining industry receives a subsidy in the form of a tax credit on the diesel that fuels the trucks and machinery. Unlike the rest of us, mining companies do not pay the Federal government tax on fuel. This subsidy currently amounts to $2 billion dollars per year or an $87 annual contribution from each and every Australian. NSW residents subsidise the price of coal to power stations as well as pay higher electricity prices. The previous Labor government undertook to supply coal from the NSW government owned Cobbora mine to electricity generators at a third of the price that coal could sell for in export markets, in order to secure the viability of state generators prior to privatization. As a result, the government (and the people of NSW) will forego $2.7 billion in revenue, based on current export prices, through to 2020. The coal industry will receive compensation once the carbon tax commences in July 2012. In NSW, instead of closing the ‘gassy mines’ that produce high levels of greenhouse gases from methane gas leakage, NSW coal owners can draw on the $1300 million allocated to the Coal Sector Jobs Package over six years. Governments also assume responsibility for many aspects of mine site remediation and rehabilitation. State and Federal governments develop many sustainability initiatives, and explore solutions to reduce carbon emissions, such as by funding clean coal projects. Let’s follow the lead of the Doctors for the Environment (Newcastle Herald 12/5/12) and consider the health costs from increased air pollution from mining, transport and

loading of coal, and coal-fired power generation in the Hunter Region. Air pollution’s harm to human health is well-documented, leading to a range of illnesses and reductions in life expectancy. The 2010-2011 National Pollution Inventory for Singleton and Muswellbrook reports that particulates (PM10) from mines and power stations have increased to 62,600 tonnes (45% of NSW total). Power stations emit over 100,000 tonnes of the harmful gas SO2, 40% of NSW’s emissions. The Australian Academy of Technological Sciences and Engineering (ATSE, 2009) estimated the total health care bill from coal-fired power stations in Australia at $A2.6 billion per annum. Costs reflect the full range of negative effects, such as deaths, cancers, hospital admissions, asthma attacks, symptom days, and heart failure. The substantial costs to the natural environment and farming land are hard to estimate in dollar values. While the NSW Minerals Council claims “coalmining is a temporary use of land,” in fact, coal mining leaves large tracts of sterile landscape, punctuated by former open cut voids filled with toxic fluid. Creek beds and aquifers are punctured and cracked. Contaminated mine water is released into river systems, which adds to salinity and harms native species. The expansion of mining threatens sustainable rural enterprises such as agriculture, viticulture and horse breeding, and the communities these industries sustain. On a global scale, coal is the main industrial source of climate change. The burning of coal for electricity has grown faster than any other source of greenhouse gas emissions, and now accounts for more than half of world emissions from stationary sources (IPCC 2007). The time has arrived to leave behind the myth of ‘cheap coal’. Added together, the hidden costs of this ‘black gold’ are unaffordable, for Australians and the planet. Linda Connor is Professor of Anthropology and Stuart Rosewarne is Senior Lecturer in Political Economy, both at the University of Sydney.

ENVIRONMENTAL HEALTH BRANCH

NSW Department of Health ABN: 92 697 899 630

PO Box 798 Gladesville NSW 1675 Building 11, Gladesville Hospital

Victoria Road, Gladesville NSW 2111 Telephone (02) 9816 0234 Fax (02) 9816 0240

Website www.health.nsw.gov.au

Wednesday, 5 October 2011 Megan Webb Senior Planner NSW Planning Assessment Commission L13, 301 George Street, Sydney GPO Box 3415 Sydney NSW 2001 Dear Ms Webb,

Re: NSW Health advice following the meeting to discuss the Ashton Coal Mine held on 20 September.

Further to discussions between the Planning Commision, the Chief Health Officer (Dr Kerry Chant) and I on 20 September, NSW Health has reviewed the revised documentation, particularly around cumulative particulate matter. NSW Health advice remains unchanged. NSW Health has received expert input from Dr Mark Hibberd on the issue of background levels of PM10 that are included in the PAE Holmes air modelling summaries. Dr Hibberd is of the opinion that an annual average of 5 microns as assumed by PAE Holmes is a substantial underestimate of the background level, and this background figure needs to be increased substantially for the modelling to be appropriate. Under those circumstances, the modelled levels of PM10 would likely result in a far greater frequency of unacceptable exceedences. NSW Health is therefore of the opinion that any approval for proposed Ashton Coal Mine development is deferred until such time that other coal mines in the region cease to operate, leading to lower cumulative particulate matter impacts. NSW Health also notes that the noise levels remain unsatisfactory for quality of life at some residences. Yours sincerely, Professor Wayne Smith Director, Environmental Health Branch NSW Health

Documents

31.5.2012 Re; Address to PAC re Ashton Mine Approval · twice NSWs total emissions. In global terms, 298.6 mt of CO2 is about 60% of the CO2 that was added to the atmosphere globally