30 January 2019
Dear Premier Berejiklian
CC Leader of the Opposition, Michael Daley
The NSW EPA has just concluded its review of pollution licences for three of the state’s five coal-fired power stations (EPLs 761, 13007 and 1429). The review has failed to strengthen the licences by requiring additional pollution controls.
Coal-fired power stations are the state’s biggest source of toxic air pollutants including sulfur dioxide (170 million kg each year), oxides of nitrogen (121 million kg each year) and fine particle pollution. According to a recent health study, this air pollution kills 279 people each year and will cause the deaths of an additional 3,429 people before their planned closure.
These pollution licences allow NSW power stations to emit toxic pollution at concentrations many times higher than allowed in countries including the United States, Europe, Japan and China. In these countries, stricter emission limits have forced power stations to fit emission controls such as selective catalytic reduction and flue gas desulfurisation: technologies that can reduce toxic pollution by 85% or more.
In NSW, power station pollution licences are reviewed every five years. The EPA minimised community involvement in the review process by not notifying polluted communities or public interest organisations, concluding the review over Christmas and refusing to allow an extension of time for submissions. Although the EPA says it will accept public submissions at any time, they finished the reviews well before the review date and did not consider submissions made by the scheduled review date.
The EPA failed to conduct a proper public consultation our organisation ran community consultations. We convened six public meetings throughout the state and encouraged community members to have their say. Several thousand people made submissions, expressing overwhelming support for the power stations to install emission controls to reduce pollution. On the Central Coast and in Lithgow, there was also strong support for air pollution monitoring in neighbourhoods and from stacks, and for monitoring data to be readily available to community members.
Independent U.S. pollution control expert Dr Ron Sahu made submissions on all three licences. Dr Sahu identified a range of options for overdue pollution control and observed that these controls are mandatory in most countries. Submissions were also made by the NSW Nurses and Midwives Association, the Climate and Health Alliance, Doctors for the Environment Australia, the Australian Conservation Foundation, the Nature Conservation Council of NSW, and local government authorities including the Central Coast and Muswellbrook councils.
On 22/1, the EPA confirmed that the review was complete and that no changes would be made to these pollution licences. The EPA’s justification for leaving the licences unchanged is that, “While there is technology available to reduce power station emissions, the EPA’s statutory reviews of the Eraring, Mount Piper and Vales Point power stations environment protection licences found that imposing a requirement to significantly upgrade the power stations was not warranted.”
In our view, the EPA has mismanaged this process and fallen short of their legal duty to protect NSW residents and the environment from pollution. We believe there is a compelling case to review the pollution licences for all five coal-fired power stations in NSW and to demand that they install best practice pollution controls. We urge you to take responsibility for this process where the EPA and Environment Minister Gabrielle Upton have failed.
Director of Advocacy and Research
Environmental Justice Australia
Level 3, 60 Leicester St
Carlton, Vic 3053