Environmental Protection and Biodiversity Conservation (EPBC) Submissions
FOE Submission
WWF Submission
Wildlife Carers Submission
Friends of the Earth
Submission in support of referral of
Waratah Coal, Rail and Port Proposal to the EPBC Act
Friends of the Earth Brisbane
PO Box 5702
West End
Qld 4101
14 August, 2008
epbc.referrals@environment.gov.au
Dear Sir/Madam,
Submission in support of referral to the EPBC Act re: Waratah Coal mine and port proposal
Friends of the Earth support the referral of the above project for EPBCA assessment.
We are fundamentally opposed to the development of any new coal mines and to the siting of a port of any kind in the Shoalwater Bay (SWB) region, especially as it is within RAMSAR listed wetlands. This proposal does not meet any of the criteria of environmental sustainability.
The coal mine proposal is contrary to contemporary environmental advice on climate change, the port and rail link threatens a unique and irreplaceable coastal wetlands wilderness area and both threaten to pollute local land and water. The port and rail proposal also threaten the native title claims of the local Darumbal indigenous people.
Below is a summary outline of our objections to this proposal.
Sincerely
Kim Stewart & Emma Brindal
for Friends of the Earth Brisbane
Phone: Kim 0413 397839
Email: kim.stewart@foe.org.au
Submission in support of referral of
Waratah Coal, Rail and Port Proposal to the EPBC Act
prepared by Kim Stewart and Emma Brindal
Friends of the Earth Brisbane
August 14, 2008
Contact: kim.stewart@foe.org.au
Mob: 0413 397839
Contents:
Introduction
1. Climate Change
1.2 Impacts of climate change on matters of national significance
1.3 Impacts of the Greenhouse emissions from the Galilee project
1.4 Greenhouse Trigger needed in EPBC Act
2. Habitat destruction
3. Local pollution
4. Social issues: indigenous sovereignty and human health
Friends of the Earth are fundamentally opposed to the development of any new coal mines and to the siting of a port of any kind in the Shoalwater Bay (SWB) region, especially as it is within RAMSAR listed wetlands.
Our objections are detailed below.
1. Climate Change
Climate change is the most threatening process facing mankind. The impacts of climate change are now occurring at a faster rate and at lower temperatures than previously predicted. Even moderate additional greenhouse emissions are likely to push Earth past critical tipping points. Scientists have been warning for several years that such tipping points are the greatest threat from manmade global warming — and what makes it potentially catastrophic for civilization.
The opening up of new coal mines is contrary to preventing catastrophic and irreversible changes to the earth’s climate as coal use is one of the major contributors to increased carbon in the atmosphere. As one of the world’s most eminent climate scientists, James Hansen from the NASA Goddard Institute for Space Studies, has said: “preservation of (the) climate requires that most remaining fossil fuel carbon is never emitted into the atmosphere”. Every tonne of coal extracted fuels climate change.
The indirect greenhouse gas (GHG) emissions from the use of Australian coal exports (585.7MtCO2-eq) is greater than emissions from all activities within Australia (569Mt CO2-eq).
Australia has a global responsibility as one of the world's biggest per capita emitters to curb our greenhouse gas (GHG) emissions produced both domestically, and also indirectly through our coal exports.
1.2 Impacts of climate change on matters of national significance
Climate change is already impacting on matters of national environmental significance and, unless major changes are made in current greenhouse gas emissions, will severely impact on matters of national environmental significance in the future.
There is strong scientific evidence of severe impacts on the Great Barrier Reef World Heritage Area (GBRWHA) in coming decades due to climate change. In Hoegh-Guldberg and Hoegh-Guldberg, Implications of Climate Change for Australia’s Great Barrier Reef, the best case scenario for the GBRWHA is recoverable loss if global temperature increases remain below 2 degrees. Under the worst case scenario, coral populations will collapse by 2100 and the re-establishment of coral reefs will be highly unlikely over the following 200-500 years.
There is similar strong scientific evidence of severe impacts on the Wet Tropics World Heritage Area (Wet Tropics WHA) in coming decades due to climate change. The Rainforest Cooperative Research Centre, Environmental Crisis: Climate Change and Terrestrial Biodiversity in Queensland, concluded that the likely impacts of climate change on terrestrial biodiversity within the Wet Tropics WHA would be very serious and could be catastrophic under some scenarios. Even moderate levels of warming, well within the envelope defined by the IPCC, have the potential to pose serious threats to biodiversity.
1.3 Impacts of the Greenhouse emissions from the Galilee project
The referral states that “the open cut mine is intended to have an initial export capacity of 25 million tonnes per annum, with the capability to expand substantially to 50Mtpa and beyond”.
The greenhouse gas emissions from the use of 25Mtpa of coal would produce 50.3 MtCO2-eq, increasing to 100.6 MtCO2-eq at 50Mtpa. Although not stated in the referral the ultimate purpose of the action is to burn the coal for power production.
The production of greenhouse gases is certain to occur as a result of the action and can reasonably be imputed as within the contemplation of the proponent of the action. As you are aware, in Minister for the Environment and Heritage v Queensland Conservation Council [2004] FCAFC 190 (the Nathan Dam Case) at [57] the Full Court indicated that for the purposes of section 75 of the Act:
…… all adverse impacts’ includes each consequence which can reasonably be imputed as within the contemplation of the proponent of the action, whether those consequences are within the control of the proponent or not.
Applying this principle the Victorian Civil and Administrative Tribunal found that a planning scheme amendment to allow an expansion of a coal mine was required to consider the indirect impacts of greenhouse gas emissions resulting from the burning of the coal at a power station.
The burning the coal from the Galilee Project will have an impact on climate change. How much of an impact the production of this amount of greenhouse gases will have on climate change and, consequently, on matters of national environmental significance is more difficult to determine but must, at the very least, be considered when assessing the likely impacts of the action.
Consideration of the impacts of the action under section 75 of the EPBC Act must consider the potential impacts of greenhouse gas emissions from the burning of the coal on climate change and the consequential impacts on matters of national environmental significance.
When the ultimate greenhouse gas emissions are considered the proposed action will have a significant impact on matters of national environmental significance, including the World Heritage Areas.
1.4 Greenhouse Trigger needed in EPBC Act
Reform of the EPBC Act is required so that direct and indirect greenhouse gas emissions from new mines trigger assessment. The EPBC Act aims to protect matters of environmental significance such as World Heritage properties, but does not effectively regulate the greatest threat to those matters – that of climate change. This indicates that a trigger based on direct and indirect greenhouse emissions is required under the act.
2. Habitat destruction:
The entire Waratah coal port project is within the Great Barrier Reef World Heritage Area.
The siting of a coal port and rail link at SWB will contribute to the degradation of a currently intact habitat. The construction of port, road and rail will require clearing including a 30m wide railway access. Inroad clearing is a known contributer to contamination by alien species of flora. Some of the likely damage includes: land disturbance, mine subsidence, acid mine drainage, dust, vibration, noise pollution, methane release. Light pollution from the port will affect migratory birds and other local fauna, threatening JAMBA and CAMBA international migratory bird agreements. The mine itself will transect three rivers and use water from Lake Dalrymple, deemed of national significance.
Dredging will be a necessary component for the deep water port proposal. The ship proposed for use by Waratah Coal will be bigger than any currently employed by the coal transport industry. Dreging can involved both scraping of the benthic layer and blasting of rock and coral. Dredging will increase the turbulence and dissipation of sediment in the local undersea area, putting at risk delicate seagrass meadows that the endangered dugong population depend on. Dredging (along with climate change) is recognised by the Aust. Institute of Marine Sciences as one of the major threats to the world's reefs. It is unclear where dredge materials will be dumped.
Dredging also poses a great risk to the wetlands & underlying freshwater acquifer: dredging for the Port of Savannah in Georgia has led to the loss of more than 6000 acres of wetlands, increased local groundwater salinity and decreased available oxygen in the water - "devastating...fishery, damaging habitat of endangered (species) and erasing vast areas of freshwater marsh"(Batley 2004:48).
Dredging is more difficult to monitor than onshore activities. On more than one occasion it has been illegally carried out resulting in damage to irreplaceable ecosystems such as that which destroyed coral and seagrass beds in Port of Miami, similarly where wetlands were destroyed in Port of Savannah.
3. Local pollution: coal not only contributes to global warming, it is polluting in itself.
Water - Coal processing and runoff from stockpiles such as can be expected at a port will contribute to acidity of groundwater and 'acid mine drainage'. Water acidity increase caused by coal runoff can lead to the dissolution of poisonous heavy metals into groundwater including aluminum, arsenic, zinc, copper and selenium. Coal runoff from the proposed port will effect both the seagrass meadows of the SWB and RAMSAR listed wetlands. Particulate runoff from coal ports in other regions is known to cause undersea sediment layers for many metres offshore.
as described above, dredging can damage the freshwater acquifer, as it did in Port of Savannah where Florida's biggest drinking water acquifer is now contaminated with salt water (Batley 2004:48).
Increased shipping increases risk of chemical & fuel spills, contamination from anti-fouling agents, waste disposal and introduction of foreign pest species like zebra mussels through expulsion of ship bilge water.
The proposed port facilities are wholly within the water catchment for the township of Yeppoon.
Air - Coal mining and transport is linked to increased particulate matter in air and concurrent reduction in environmental health as a result. In fact, specialised port yard equipment can be at lease 15 times more polluting than trucks according to the US based National Resources Defense Council.
Soil: Depending on the type of coal stored at the port site, the coal stockpiles alongside the proposed port can be between 2 and 5 kms square. In addition to coal falling form uncovered vehicles, dust in dry conditions and runoff in wet, local soil communities will be effected. We have been advised that the thermal coal to be stored there is highly combustible, which means current estimates of the size of the stockpile maybe underestimated and that sprinkling measure may be necessary, exacerbating the possibility of groundwater and soil contamination on the sandy substrate.
4. Social issues: indigenous sovereignty & human health
The SWB region is the traditional land of the Darumbal indigenous people. The siting of a port and rail line here will affect their native title claims. Their views on the use and possible destruction of their ancestral land has not been gauged.
Human Health: Chronic illness in humans has been linked to coal mining pollution. Coal-processing chemicals, equipment powered by diesel engines, explosives, toxic impurities in coals, and dust from uncovered coal trains and mines themselves cause environmental pollution. People living in coal mining areas are affected by increased incidence of respiratory diseases from inhaled particulates and live with coal dust pollution in their homes. Mines and ports contribute noise and light pollution which also affects human health.
Diesel powered trains, machinery and shipping will contribute significant pollution to the area: diesel emissions create 71% of the cancer risk in air pollution including NOx, ozone, benzene, toluene, and SOx as well as particulates (Batley 2004).
As one of the biggest coal producers in the world, Queensland and Australia have a duty globally to reduce our greenhouse contribution and ceasing to open up new coal mines is a powerful way to do this.
National Estate and Commonwealth Heritage listing would be compromised by this development.
Local protected areas including the Byfield National Park and the Great Barrier Reef Marine Park will be compromised by the proposal and boundaries will have to be amended.
Attachment:
McGrath, C 2008. Regulating Greenhouse Gas Emissions from Australian Coal Mines
References:
Batley, D. & Plenys, T et al. 2004. "Harbouring Pollution: The Dirty Truth About US Ports" National Resources Defense Council
http://www.coalitionforcleanair.org/pdf/reports/cca-reports-harboring-pollution-the-dirty-truth-about-US-ports.pdf
2008. "Chronic Illness Linked To Coal-mining Pollution, Study Shows" ScienceDaily, Mar. 27
http://www.sciencedaily.com/releases/2008/03/080326201751.htm
2008. "Coal plant pollution threatens U.S. parks - report" http://uk.reuters.com/article/oilRpt/idUKN1530011820080515
Evans, L. 2008. "Coal Ash Pollution Contaminates Groundwater, Increases Cancer Risks" Earth Justice News Sept 2007. http://www.earthjustice.org/news/press/007/coal-ash-pollution-contaminates-groundwater-increases-cancer-risks.html
Upper Hunter Coal Dust Air Pollution
http://www.parliament.nsw.gov.au/Prod/Parlment/HansArt.nsf/V3Key/LC20060928017
World Coal Institute
http://www.worldcoal.org/pages/content/index.asp?PageID=126
Bouwer, H. Etal. 1990. Surface Coal Mining Effects on Ground Water Recharge, Commission on Engineering and Technical Systems (CETS). National Academy Press: Washington, US
Frew, W. 2007 "Coal's come too close for comfort" Sydney Morning Herald, December 12.
http://www.smh.com.au/news/environment/coals-come-too-close-for-comfort/2007/12/11/1197135463520.html
Wildlife Carers EPBC Submission
Joy Davison-Lee
Wildlife Carers Network
Post Office Box 345
Yeppoon Qld. 4703
August 12, 2008
The Premier
The Hon. Anna Bligh
Post Office Box 15185
City East Qld. 4002
I write of behalf of the Network and refer to the proposed coal terminal, port facilities and railway close to the Byfield Township and adjacent to the Byfield National Park with a railway line through the Byfield forest into Shoalwater Bay Training Area along the National Park boundary.
Network members believe the implications of this huge project on the environment, wildlife and local residents are appalling and fly in the face of the Federal Governments carbon trading initiative and their call for Australians to “think climate, think change”.
Investigations show that this project is already well advanced and highlights your government’s lack of openness and transparency in this matter. Our understanding of the project as below:
These FACTS were revealed by the IAS and from the Capricorn Conservation Councils meeting with Waratah Coal’s CEO Peter Lynch:
The projected 100 million tonnes per annum facility will be located 3 km north of Five Rocks Beach (Three Rivers) and 20km from Byfield town.
Port is located wholly within RAMSAR wetlands.
Port will require amendment of the GBR zone plan to allow shipping access.
Waratah Coal admits that there will be disturbance to many endangered terrestrial and marine species.
Page 2
Dredging will be in pristine sea beds and sediment will be dumped unconfined at sea, affecting habitats.
The Port will affect fish, turtles, dugongs, dolphins and whales.
The project will affect the Darumbal people’s native title claims and indigenous use.
Port will consume 800 mega litres of water per annum and require a 40 Mw powers supply through a new transmission grid.
Air quality, dust, noise and vibration will impact on neighbouring communities, waterways and beaches.
Access to the port will be via the Byfield – Yeppoon road, the railway will cross Waterpark Creek and North Sandy Creek just north of Byfield Township.
The proposal states the rail line will only cross five kilometres of military training area, but will cross the Byfield State Forest and terminate along the boundary of the Byfield National Park.
Ships may be up to 440,000 tonnes in capacity twice the size of those currently in use elsewhere and drawing up to 24m.
Ship and Chinese port construction for this class vessel has already commenced in China. Engineering plans are well advanced for the $5.1 billion rail port project and mine design. How long have the Chinese known about this project?
Trains will be 21,240 tonnes, with 180 wagons, 6 locomotives, 3.2km long and bottom dumping, operating 24 hrs per day.
Port facilities are wholly within the Waterpark Creek catchment area for the Capricorn coast.
Coal stockpiles will be 2.5million tonnes and 2.5km x 160m in size with expansion capabilities.
Page 3
A 1.7-km wharf will berth 2 ships loading 10,000 tonnes per hour.
Port will also include stockpile reclaimers, conveyors, loaders, two rail loops. A tug harbour and barge dock will possibly be situated in Port Clinton.
Port construction workforce will be up to 600 persons with a permanent staff of 100.
The Wildlife Carers Network believes the above proposal is scandalous and the Queensland government is putting money before the environment, climate change and future generations.
We strongly believe we are fighting for our grandchildren’s future and the future of many species of wildlife and the survival of one of the last pristine environments left in Queensland.
The wildlife Carers Network along with other wildlife conservation groups, environmental groups, individuals and community groups totally condemn the actions of the government in this matter and will fight it, up to and including a campaign against Labour in the upcoming elections.
Joy Davison-Lee
On behalf of
The Wildlife Carers Network