Comments on the Coalpac EA Dr Haydn Washington, Visiting Fellow Institute of Environmental Studies, UNSW; and Hon., Sec. Colo Committee My background • Environmental scientist and writer with 30 year experience of Wollemi and Gardens of Stone • Visiting Fellow, Institute of Environmental Studies, UNSW • Former CSIRO scientist for 7 years working on heavy metal pollution and acid mine drainage • Plant ecologist with decades of experience in area, who did the original Gardens of Stone Vegetation Survey in 2001. • Author of 5 books on environmental issues, including ‘Climate Change Denial’ (2011) and ‘Human Dependence on Nature’ (2012). • Member of the Greater Blue Mountains World Heritage Advisory Committee • Hon. Secretary of the Colo Committee since 1974, and speaking today on behalf of that group. • Lead author of 2011 scientific paper ‘The Geoheritage and Geomorphology of the Sandstone Pagodas of the North-western Blue Mountains Region (NSW)’ Proc. Linn Soc. NSW, 132, pp. 131-143). Concerns re environmental and climate science • Extensive and repeated basic mistakes in climate science that seek to downplay the significant greenhouse impacts of the proposed project. • Major gaps in flora survey that missed c. 100 plants, and major mistakes in naming species • Dismissal of risks of acid mine drainage • Dismissal of concerns re highwalling and proximity of open cut to escarpment. Climate science mistakes • Coalpac EA states on p. x Exec. Summ. that: ‘estimated current global emissions of 3000 gigatonnes of carbon dioxide equivalent per annum’. • Repeated on p. 119 main report • Human anthropogenic emissions are in fact c. 28.9 Gt CO2/yr, as noted by their consultant, PAE Holmes, on p. 110 of Appendix G • Coalpac is using the figure for the total atmospheric reservoir of CO2, not human emissions. By so doing they seek to reduce the % this project increases human emissions. • 7 Mt CO2/yr is 0.007 Gt and this is 0.02% of world emissions not 0.0003 % as repeatedly stated in the Coalpac EA. • This mistake was pointed out in submissions and yet Coalpac continues in its ‘Response to Submissions’ to seek to deny their basic mistake in climate science. Climate science mistakes - 2 • Confusion over scope 1, 2, and 3 • P. 55 Coalpac response says Australia’s carbon footprint already includes emissions of scope 2 and 3, yet clearly they don’t include emissions for a mine that is not yet built. • It also states ‘any coal bound for export markets (currently accounted for within the Project’s Scope 3 emissions) will comprise part of Australia’s annual GHG emissions’ • This is incorrect. The Australian National Accounts data does not include exported coal. The CO2 in exported coal amounts to 520 Mt/ yr and is clearly not part of the total footprint of 546 Mt/yr • The proposed increase of 7 Mt CO2 is thus significant and does in fact represent 1.3% of the current Australian carbon footprint. It is misleading to refer only to scope 1 emissions (fuel use on site) in regard to a coal mine. Its greenhouse impact occurs when the coal is burnt. Acid Mine Drainage Risk • Past history of acid mine drainage in Western Coalfields (e.g. Wallerawang colliery, which I studied in 1980s) • Sulphide in overburden up to 0.8% is quite high. The presence of framboidal pyrite can lead to a spike in AMD. • Only leaching of samples over time can determine if AMD is likely to occur. This was not carried out. • AMD is not easily managed and ‘monitoring’ is not enough. Above: Acid mine drainage from coal mine Below: Invincible colliery borehole Biodiversity and plant ecology • Flora survey of site clearly inadequate • Missed c. 100 native plants • Missed locating the threatened Persoonia marginata (one of largest populations known), which had to be found by a local botanist • Species list was full of incorrect spellings for species, indicating no overall quality control • Response to submissions focuses primarily on biodiversity offsets. However, these are not fully ‘like for like’ and will not replace the high conservation value habitat in the project area. Highwalling • P. 77 their response notes: ‘Coalpac acknowledges the significance of the sandstone pagodas, escarpments and cliffs within and surrounding the Project Boundary’ • However, highwalling will produce only 1.9 million tonnes of an estimated 70-100 million tonnes of coal to be mined • Therefore responsible compromise would be to abandon proposed highwalling to protect the pagodas and cliffs that Coalpac says it agrees are significant. Distance from open cut to escarpment • The EA proposes only a 50 metre buffer zone between the open cut and the escarpment. • P. 77 of Coalpac Response says Coalpac has been mining for some years within 100 metres of the escarpment without impact. • If 100 metres is safe, why is only 50 metres proposed? They merely suggest a ‘100 metre risk review zone’, which is inadequate. • By the logic of its earlier statement on p. 77, it would seem prudent to enforce a 100 metre buffer zone between any open cut and the escarpment. Renewable energy alternatives • The Coalpac EA and Response continue to ignore rapidly decreasing costs of viable renewable energy alternatives to coal-fired power. • Coalpac cites IEA (2011) to argue against renewable energy. However, the IEA has several scenarios and in their ‘Blue Map’ Scenario, renewables generate half global electricity in 2050, while coal's contribution is reduced to 12%. • Ellliston et al (2012) in Australia and Hand et al (2012) in the USA show that it is feasible to reach 80-100% renewable energy far more quickly than the IEA suggests (Prof. Mark Diesendorf, UNSW, pers. comm). The Climate Commission recently reported that the cost of renewables was dropping rapidly and uptake accelerating. • The rationale used to justify the Coalpac proposal is thus misleading. Other impacts • Major impact on the Greater Blue Mountains World Heritage area in terms of visual impact on a major visitor gateway to the area. • Major impact on the proposed GOS2 State Conservation Area supported by community environment groups and the Greater Blue Mountains World Heritage Area Advisory Committee • Major impact on the local community of Cullen Bullen and nearby areas in terms of dust, noise and visual pollution. Conclusion • The Coalpac EA and ‘Response to submissions’ continues to promulgate major scientific errors • There has been no attempt to compromise on any of the criticisms of the project • The rationale for the need for the project is flawed • The impact of the proposal is simply too great on many levels – on climate, on natural values, on the local community • The project is the worst way to source coal, even worse than longwall mining • The Colo Committee thus calls on the PAC to deny the Coalpac proposal.
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