Letter requesting UniSuper divest from gas investments by Alec Roberts Figure 1 Remaining Carbon Budget 22 5 September 2020
UniSuper Level 1, 385 Bourke Street Melbourne VIC 3000 E: [email protected] Dear UniSuper, I am writing to challenge the fund’s stated view that “gas will be an important transition fuel to a low carbon world”. I ask that you reconsider this position and divest from all companies seeking to expand gas production. I am a member of UniSuper and have my investment options in Sustainable High Growth and Global Environment Opportunities so not to be investing in Fossil Fuels. However, this is not enough. UniSuper need to divest fully from Fossil Fuels including gas and oil. The divestment of several thermal coal mining companies was a great first step in aligning UniSuper’s portfolio with my principles. I ask that you apply the same reasoning to gas producers, recognising the decline in gas production required to limit global warming to 1.5°C, and divest from all companies whose future prospects rely on expanding the sector. Natural gas as a “transition fuel”? Natural gas has often been touted as the “transition fuel” for the electricity sector to replace coal’s greenhouse gas emissions and eventually paving the way for an emissions free future for Australia. In response to an open letter on April 8 calling for UniSuper to immediately divest from companies that are actively undermining climate action, UniSuper Chairman Ian Martin stated that "Our base case is that gas will be an important transition fuel to a low carbon world."[1] This supported UniSuper’s “Climate risks and our investments” document which noted Natural Gas as being often cited as a transition fuel and that “In order for natural gas to fulfil its role as a transition fuel, infrastructure will need to be built.”[2] The concept of gas as a transition fuel is out of date and I believe incorrect. It is simply too expensive and too emissions intensive to be so. Methane leaks from natural gas production can make the process nearly as carbon intensive as coal. The use of gas in electricity production has reduced in recent years and modelling of the future electricity grid and further evidence has indicated that it is unlikely that gas will play a major role in the transition from coal-fired power plants to renewable energy and storage. The electricity market has already moved away from gas in Eastern Australia, with a 59% decline in usage in the National Electricity Market since 2014, whilst renewable energy has increased by 25% during the same period.[3] Furthermore, flexible gas plants already in the grid are running well below capacity.[4] AEMO forecast that increasing renewable generation developments in the NEM are expected to continue to drive down system normal demand for gas-powered generation (GPG). [5] The AEMO modelled the future electricity grid in its Integrated Systems Plan.[6] [7] The results showed for all scenarios that the transition from coal to renewable energy would not be via gas.10 The role of gas would be reduced with a decline in gas generation through to 2040.9 The report notes that to firm up the inherently variable distributed and large-scale renewable generation, there will be needed new flexible, dispatchable resources such as: utility-scale pumped hydro and large-scale battery energy storage systems, distributed batteries participating as virtual power plants, and demand side management.12 13 It also noted that new, flexible gas generators such as gas peaking plants could play a greater role if gas prices materially reduced, with gas prices remaining low at $4 to $6 per GJ.13 However this is unlikely as gas prices have tripled over the past decade and expected NSW gas prices (for example) are over 60% more than this price.10 [8] AEMO noted that the investment case for new GPG will critically depend on future gas prices, as GPG and batteries can both serve the daily peaking role that will be needed as variable renewable energy replaces coal-fired generation. In their 2020 Gas Statement of Opportunities report, AEMO predicted that as more coal-fired generation retired in the long term, gas consumption for GPG in the National Electricity Market was forecast to grow again in the early 2030s, recovering to levels similar to those forecast for 2020.11 However, in a later report, AEMO determined that by the 2030s, when significant investment in new dispatchable capacity is needed, new batteries will be more cost-effective than GPG. 13 Furthermore, the commissioning of the Snowy 2.0 pumped hydro project in 2026 will result in less reliance on GPG as a source of firm supply.11 AEMO noted that stronger interconnection between regions reduces the reliance on GPG, as alternative resources can be shared more effectively. 13 The expansion of network interconnections enables the growth of variable renewable energy without a significant reliance on local gas generation.[9] Supporting this assertion, the AEMO announced a series of actionable transmission projects including interconnector upgrades and expansions and network augmentations supporting recently announced renewable energy zones.[10] 13 AEMO noted that as each of these new transmission projects is commissioned, the ability for national electricity market regions to share resources (particularly geographically diverse variable renewable energy) is increased, and therefore demand for GPG is forecast to decrease.11 The Marinus Link is forecast to be commissioned in 2036, with surplus renewable generation from Tasmania then being available to the mainland National Electricity Market, which would see further declines in gas-fired generation, despite continuing coal-fired generation retirements.11 AEMO recently noted that GPG can provide the synchronous generation needed to balance variable renewable supply, and so is a potential complement to storage, with the ultimate mix depending upon the relative cost and availability of different storage technologies compared to future gas prices. 5 However, the current installation of synchronous condensers in South Australia and in the eastern states to increase system strength and stabilise the electricity network will reduce the need for gas-fired generators acting in the role of synchronous generators as more renewables enter the grid.[11] Ancillary services are likely to utilise battery storage and synchronous condensers in the future and no longer require the use of GPG. Need for additional gas? Gas demand has been declining in recent years and predictions are that gas demand will not increase in the future and may decrease, therefore it is unlikely that additional gas will be required in the Eastern Australian domestic gas market to meet residential, commercial, and industrial gas demand. From 2014 to 2018, annual consumption of natural gas in NSW fell by 15 per cent, with the major contributor of this fall in consumption being the reduction in the use of gas for power generation.[12] Whereas domestic demand for gas has fallen for use in manufacturing by 14%, it has dropped by a staggering 59% for power generation by since 2014. 9 ACCC recently stated that “overall consumption of gas in the east coast was largely unchanged over the first five months of 2020 relative to 2019”[13] and that the COVID-19 pandemic has not had a material effect on the overall level of production or consumption in the East Coast Gas Market. However, they stated that it is unknown whether the contraction in economic activity brought about by the COVID-19 pandemic will result in a decline in domestic and/or international demand for gas in 2021. Commercial and Industrial gas user (C&I) consumption is predicted to be flat or fall. C&I’s utilise gas for applications such as a heat source for boilers and furnaces, for producing steam, or for drying processes, and as a feedstock to produce fertilisers, explosives, chemicals, and plastics. ACCC reported that a number of suppliers expected GPG and C&I demand to be lower in 2020 and that many C&I users reported that they are slowing production due to the COVID-19 pandemic which raised the potential for significant adverse consequences for these users in having to pay for gas that they cannot use or on-sell (with take or pay contract obligations). ACCC concluded that there is now a considerable degree of uncertainty surrounding the demand for gas by gas users (non GPG) following the COVID-19 pandemic and the impact this has had on economic activity, both domestically and internationally.19 Whereas 2019 was somewhat of an anomalous year with failures in Coal Powered Generation resulting in additional GPG being utilised, the ACCC reported that GPG demand over the first five months of 2020 was 36% lower than over the same period in 2019. Furthermore, AEMO forecast that, demand for GPG is predicted to continue to fall by over 85% from 2019 levels by 2028.[14] As an investment, gas is on shaky grounds. Since 2014, Santo’s write-downs are approaching $8bn. Internationally things are not better for gas. In the U.S., the number of operating drill rigs has fallen 73% in the last 12 months. And US LNG exports have more than halved so far in 2020. Deloitte estimates that almost a third of U.S. shale producers are technically insolvent at current oil prices.[15] Moving away from gas The ACT is planning to go gas free by 2025. This is expected to reduce their overall emissions by 22%. As part of the ACT Climate Change Strategy 2019-2025, all government and public-school buildings will be completely powered by 100% renewable energy eliminating the need for natural gas. The ACT has also removed the mandatory requirement for new homes built in the ACT to be connected to the mains gas network and will begin to introduce new policies to replace gas appliances with electric alternatives. Some 14% of residents have already converted over to 100% electric. [16] There are moves in other jurisdictions to remove the mandatory requirement for a gas connection in new developments such as in South Australia. AEMO forecasts further reductions in gas use as consumers fuel-switch away from gas appliances towards electrical devices, in particular for space conditioning. The Commonwealth and NSW Government are exploring options to free-up gas demand through electrification, fuel switching and energy efficiency. [17] Fuel switching from gas appliances towards electrical devices can often be more economic. A 2018 study of household fuel choice found that 98% of households with new solar financially favoured replacement of gas appliances with electric. With existing/no solar 60-65% of households still favoured replacement of gas appliances with electric. [18] In the residential sector, for example, reverse-cycle air-conditioning is expected to reduce gas demand that could have arisen due to gas heating.[19] Therefore, it is unlikely that additional gas will be required in the Australian domestic gas market to meet residential, commercial, and industrial gas demand. The role of natural gas in a low-carbon economy To address the issue of dangerous climate change, Australia, along 196 other parties, is a signatory to the Paris Agreement, which entered into force on 4 November 2016. The Paris Agreement aims to strengthen the global response to the threat of climate change, by: Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change.[20] The IPCC report provides an estimate for a global remaining carbon budget of 580 GtCO2 (excluding permafrost feedbacks) based on a 50% probability of limiting warming to 1.5 degrees relative to 1850 to 1900 during and beyond this century and a remaining carbon budget of 420 GtCO2 for a 67% chance (See Figure 1 for details). [21] Figure 1 Remaining Carbon Budget[22] - see above Committed emissions from existing and proposed energy infrastructure represent more than the entire carbon budget that remains if mean warming is to be limited to 1.5 °C and perhaps two-thirds of the remaining carbon budget if mean warming is to be limited to less than 2 °C. Estimates suggest that little or no new CO2-emitting infrastructure can be commissioned, and that existing infrastructure may need to be retired early (or be retrofitted with carbon capture and storage technology) in order to meet the Paris Agreement climate goals.[23] Australia’s remaining emission budget from Jan 2017 until 2050 for a 50% chance of warming to stay below 1.5C warming relative to pre-industrial levels was estimated to be 5.5 GTCO2e.29 Adding the GHG emissions expended in 2017[24], 2018[25], and 2019[26], this leaves just 3.8 Gt CO2e remaining as at December 2019. This leaves 6-7 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C. Therefore, at current emissions rates, Australia will have exceeded its carbon budget for 2050 by 2026. It therefore follows that no new fossil fuel development in Australia that is not carbon neutral can be permitted because its approval would be inconsistent with the remaining carbon budget and the Paris Agreement climate target. It follows that gas infrastructure development would contribute to an unacceptable increase in greenhouse gas emissions. This includes Santo’s Narrabri Gas Project, which is estimated to result in 94.2 million tonnes of greenhouse gases over the life of the project Greenhouse gas and climate change – Fugitive emission The CSIRO report “Fugitive Greenhouse Gas emissions from Coal Seam Gas Production in Australia” [27] noted that fugitive emissions for Natural Gas in Australia are estimated to be 1.5% of gas extracted. It should be noted that if fugitive emissions exceeded 3.1% then the emissions intensity would match that of coal (due to the fact that methane is 86 times more powerful as a greenhouse gas than CO2 over 20 years and 34 times more powerful over a 100-year time period).[28] They also noted that unconventional gas industry such as Coal Seam Gas would result in greater levels of fugitive emissions than the conventional gas industry. Therefore, the use of natural gas to displace coal-fired power generation would not necessarily reduce CO2 emissions. Alternative sources of gas Other alternative sources of gas exist that have significantly lower emissions than the natural gas and in the long term could replace the need for new natural gas infrastructure. It should be noted that these technologies Green Hydrogen, Biogas and Biomethane not only look to transition electricity generation away from natural gas but also for other uses such as combustion for heat. Hydrogen Hydrogen is a colourless, odourless, non-toxic gas that is an excellent carrier of energy and can be used for a broad range of energy applications including as a transport fuel, a substitute for natural gas and for electricity generation.[29] Hydrogen gas can be produced from water in a process known as electrolysis, and when powered by renewable energy, the hydrogen produced is free from carbon emissions, making it an attractive way to decarbonise transport, heating and electricity generation.40 AEMO stated that, “Hydrogen has the exciting potential to become an alternative energy storage technology and a new export commodity for Australia” which could be used to help decarbonise the domestic heat, transport and the industrial and commercial sectors in Australia and noted that development of the hydrogen industry would potentially impact both natural gas and electric demands.24 12 Several developments involving green / renewable hydrogen are either planned or underway in Australia. AEMO highlighted the potential for green steel production in Australia due to abundant renewable resources and the increased demand for low emissions industrial commodities worldwide. 24 ‘Green steel’ can be made via a direct reduction process which uses hydrogen (made from renewable energy) as the heat source and reducing agent to produce pig iron. The by-product of the iron reduction process using hydrogen is water, rather than carbon dioxide in conventional steel making. Renewable energy is then used by an electric arc furnace to produce low-emissions green steel. The Arrowsmith Hydrogen Project, which will be built at a facility in the town of Dongara, located 320km north of Perth, will utilise dedicated onsite renewable energy 85MW of solar power, supplemented by 75MW of wind generation capacity to generate 25 tonnes of green hydrogen a day and will be operational in 2022.[30] ATCO’s Clean Energy Innovation Hub, located in Jandakot in Western Australia, is being used to trial the production, storage and use of renewable hydrogen to power a commercial-scale microgrid, testing the use of hydrogen in different settings and applications including in household appliances.[31] This includes optimising hydrogen storage solutions, blending hydrogen with natural gas and using hydrogen as direct use fuel. Green hydrogen will be produced from on-site solar using electrolysis, fuelling a range of gas appliances and blending hydrogen into the natural gas pipeline. The $3.3 million development project will evaluate the potential for renewable hydrogen to be generated, stored, and used at a larger scale. ATCO aims to assess the practicalities of replacing natural gas with hydrogen at a city-wide scale across a municipality.[32] The new chair of the Australian Energy Regulator, Clare Savage recently stated: “The national gas industry could also undergo significant change as some jurisdictions move towards a zero carbon emissions policy. This could have significant consequences for the future of gas pipeline networks. In response, the AER recently supported the future recovery of Jemena’s investment in trialling the production of hydrogen from renewable energy for injection into its Sydney network. If hydrogen trials such as Jemena’s prove successful, the natural gas networks could be re-purposed to distribute hydrogen. If not, the economic life of the assets could be limited.” [33] Biogas and Biomethane Biogas is a renewable energy source, that is continuous and dispatchable, reliable, and local source of energy. Biogas can be converted into heat and/or electricity using boilers, generators or with Combined Heat and Power units.[34] Biogas also provides an alternative route for waste treatment and, as such, can help divert waste from landfill. Biogas consists primarily of methane and carbon dioxide, with trace amounts of other gases such as hydrogen sulphide, water vapour, oxygen, and ammonia.[35] Biogas can also be upgraded into biomethane: a renewable gas that can replace natural gas with a chemical composition very similar to natural gas. Biomethane is produced from the separation of methane from the other gases. 46 Biogas and its industry offer many benefits:
Australian business, industry and utilities recently signed an open letter to the Commonwealth Government advocating for biomethane to be injected into the gas distribution networks to enable the lowest cost transition to a decarbonised energy market and address a number of challenges including:
Both Renewable Hydrogen and Biogas/Biomethane can displace or replace natural gas as a fuel significantly reducing GHG emissions. These technologies show promise in Australia with the resources available locally. Once developed these would see future assets such as Santo’s proposed Narrabri Gas project left stranded. In summary, gas can no longer be considered a transition fuel to a low carbon economy. Surely any company seeking to expand the fossil fuel industry such as the Gas industry is taking unacceptable risks with our future as well as its own and is not ethically compatible with my retirement savings and those of my fellow members. I and my fellow members will continue to campaign until UniSuper has divested from all such companies. Thank you for taking the time to read my letter and I look forward to your response. Sincerely, Alec Roberts REFERENCES [1] UniSuper (2020, May 8). Letter in response to UniSuper Divest open letter 8 May 2020. Retrieved from https://unisuperdivest.org/wp-content/uploads/2020/05/Letter-in-response-to-UniSuper-Divest-open-letter-8-May-2020.pdf [2] UniSuper (2019, November) Climate risk and our investments. Retrieved from https://www.unisuper.com.au/~/media/files/forms%20and%20downloads/investment%20documents/climate-risk-and-our-investments.pdf?la=en [3] Robertson, B. (2020, July 23). IEEFA update: Australia sponsors a failing gas industry. Retrieved from https://ieefa.org/ieefa-update-australia-sponsors-a-failing-gas-industry/ [4] Morton, A. (2020, March 8). 'Expensive and underperforming': energy audit finds gas power running well below capacity. Retrieved from https://www.theguardian.com/environment/2020/mar/08/expensive-and-underperforming-energy-audit-finds-gas-power-running-well-below-capacity [5] AEMO (2020, March). Gas Statement of Opportunities, March 2020, For eastern and south-eastern Australia. Retrieved from https://aemo.com.au/en/energy-systems/gas/gas-forecasting-and-planning/gas-statement-of-opportunities-gsoo [6] AEMO (2019, December 12). Draft 2020 Integrated System Plan - For the National Electricity Market. Retrieved from https://aemo.com.au/-/media/files/electricity/nem/planning_and_forecasting/isp/2019/draft-2020-integrated-system-plan.pdf?la=en [7] AEMO (2020b, July 30). 2020 Integrated System Plan - For the National Electricity Market. Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/final-2020-integrated-system-plan.pdf?la=en [8] ACCC (2020, January) Gas inquiry 2017-2025 – Interim Report. Retrieved from https://www.accc.gov.au/system/files/Gas%20inquiry%20-%20January%202020%20interim%20report%20-%20revised.pdf [9] AEMO (2020c, July 30) 2020 ISP Appendix 2. Cost Benefit Analysis. Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/appendix--2.pdf?la=en [10] Energy Source & Distribution (2020, July 30). AEMO reveals Integrated System Plan 2020. Retrieved from https://esdnews.com.au/aemo-reveals-integrated-system-plan-2020/ [11] Parkinson, G. (2020, May 25) Big spinning machines arrive in South Australia to hasten demise of gas generation. Retrieved from https://reneweconomy.com.au/big-spinning-machines-arrive-in-south-australia-to-hasten-demise-of-gas-generation-64767/ [12] Pegasus Economics (2019, August) Report on the Narrabri Gas Project. Retrieved from https://8c4b987c-4d72-4044-ac79-99bcaca78791.filesusr.com/ugd/b097cb_c30b7e01a860476bbf6ef34101f4c34c.pdf [13] ACCC (2020, July) Gas inquiry 2017–2025 Interim report July 2020. Retrieved from https://www.accc.gov.au/system/files/Gas%20inquiry%20July%202020%20interim%20report.pdf [14] AEMO (2020, March 27) National Electricity & Gas Forecasting 2020 GSOO Publication. Retrieved from http://forecasting.aemo.com.au/Gas/AnnualConsumption/Total [15] Robertson, B. (2020, July 23). IEEFA update: Australia sponsors a failing gas industry. Retrieved from https://ieefa.org/ieefa-update-australia-sponsors-a-failing-gas-industry/ [16] Mazengarb, M. & Parkinson, G. (2019, September 16). ACT to phase out gas as it launches next stage to zero carbon strategy. Retrieved from https://reneweconomy.com.au/act-to-phase-out-gas-as-it-launches-next-stage-to-zero-carbon-strategy-92906/ [17] Energy NSW. (2020, January 31). Memorandum of understanding, Retrieved from https://energy.nsw.gov.au/government-and-regulation/electricity-strategy/memorandum-understanding [18] Alternative Technology Association (2018, July) Household fuel choice in the National Energy Market. Retrieved from https://renew.org.au/wp-content/uploads/2018/08/Household_fuel_choice_in_the_NEM_Revised_June_2018.pdf [19] AEMO (2020a, July 30). 2020 ISP Appendix 10. Sector Coupling. Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/appendix--10.pdf?la=en [20] IPCC (2018). Global Warming of 1.5°C: An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty, Intergovernmental Panel on Climate Change. Retrieved from https://www.ipcc.ch/sr15/ [21] Meinshausen, M. (2019, March 19). Deriving a global 2013-2050 emission budget to stay below 1.5°C based on the IPCC Special Report on 1.5°C. Retrieved from https://www.climatechange.vic.gov.au/__data/assets/pdf_file/0018/421704/Deriving-a-1.5C-emissions-budget-for-Victoria.pdf [22] Figueres, C., Schellnhuber, H. J., Whiteman, G., Rockström, J., Hobley, A., & Rahmstorf, S. (2017). Three years to safeguard our climate. Nature, 546(7660), 593–595. https://doi-org.ezproxy.newcastle.edu.au/10.1038/546593a [23] Tong, D., Zhang, Q., Zheng, Y., Caldeira, K., Shearer, C., Hong, C., Qin, Y., & Davis, S. J. (2019). Committed emissions from existing energy infrastructure jeopardize 1.5 °C climate target. Nature, 572(7769), 373-377. https://doi-org.ezproxy.newcastle.edu.au/10.1038/s41586-019-1364-3 [24] Climate Council (2018) Australia’s Rising Greenhouse Gas Emissions. Retrieved from https://www.climatecouncil.org.au/wp-content/uploads/2018/06/CC_MVSA0143-Briefing-Paper-Australias-Rising-Emissions_V8-FA_Low-Res_Single-Pages3.pdf [25] Cox, L. (2019, March 14). Australia's annual carbon emissions reach record high. Retrieved from https://www.theguardian.com/environment/2019/mar/14/australias-annual-carbon-emissions-reach-record-high [26] DISER (2020, May) National Greenhouse Gas Inventory: December 2019. Retrieved from https://www.industry.gov.au/data-and-publications/national-greenhouse-gas-inventory-december-2019 [27] CSIRO (2012). Fugitive Greenhouse Gas Emissions from Coal Seam Gas Production in Australia. Retrieved from https://publications.csiro.au/rpr/pub?pid=csiro:EP128173 [28] Robertson, B. (2020, January 30). IEEFA Australia: Gas is not a transition fuel, Prime Minister. Retrieved from https://ieefa.org/ieefa-australia-gas-is-not-a-transition-fuel-prime-minister/ [29] Tasmanian Government. (n.d.). Hydrogen. Retrieved from https://www.stategrowth.tas.gov.au/energy_and_resources/energy/hydrogen [30] Mazengarb, M. (2020, April 29). Massive hydrogen project gets green light after securing $300m investment. Retrieved from https://reneweconomy.com.au/massive-hydrogen-project-gets-green-light-after-securing-300m-investment-68959/ [31] Energy Source & Distribution (2018, October 4). Nel awarded contract for Australia’s first hydrogen microgrid. Retrieved from https://esdnews.com.au/nel-awarded-contract-for-australias-first-hydrogen-microgrid/ [32] ARENA (2018, July 3). Green hydrogen innovation hub to be built in WA. Retrieved from https://arena.gov.au/news/green-hydrogen-innovation-hub-to-be-built-in-wa/ [33] West, M. (2020, July 3). A Savage Call: energy tsar calls time on Australia’s gas cartel. Retrieved from https://www.michaelwest.com.au/a-savage-call-energy-tsar-calls-time-on-australias-gas-cartel/ [34] Ramos-Suárez, J. L., Ritter, A., Mata González, J., & Camacho Pérez, A. (2019). Biogas from animal manure: A sustainable energy opportunity in the Canary Islands. Renewable and Sustainable Energy Reviews, 104, 137–150. https://doi-org.ezproxy.newcastle.edu.au/10.1016/j.rser.2019.01.025t [35] Carlu, E. Truong, T. Kundevski, M. (2019, May). Biogas opportunities for Australia. ENEA Consulting – March 2019. Retrieved from: https://www.energynetworks.com.au/resources/reports/biogas-opportunities-for-australia-enea-consulting/ [36] Hughes, J. (2020, July 15). Business, industry and utilities back biogas for net zero Australia. Retrieved from https://www.worldbiogasassociation.org/business-industry-and-utilities-back-biogas-for-net-zero-australia/ [37] Bioenergy Australia (2020, June 9). Joint letter in support of Australian biomethane market development. Retrieved from https://www.bioenergyaustralia.org.au/news/joint-letter-in-support-of-australian-biomethane/
1 Comment
Newcastle Climate Change Response Inc.Submission to Council’s Climate Action Plan 2020-202531/8/2020  Newcastle Climate Change Response Inc. |
| 26 May 2020 Senate Select Committee on COVID-19 My concerns about the National Covid-19 Coordination Commission Dear Senators, The effectiveness of the National Covid-19 Coordination Commission (NCCC) in assisting the government mitigate the economic effects of the Covid-19 pandemic is being compromised by perceived conflicts of interest, a pro-gas agenda, a lack of transparency, and inability for the public to have input into the process. Gas is not the mooted transition fuel to a low carbon economy and gas industry connections in the NCCC may compromise the opportunity for a renewable energy led economic recovery from the Covid-19 crisis. As part of the Australian Government's response to the COVID-19 pandemic, the Prime Minister announced on 25 March 2020 the “creation of a new National COVID-19 Coordination Commission (NCCC) that will coordinate advice to the Australian Government on actions to anticipate and mitigate the economic and social effects of the global coronavirus pandemic.” “The Commission will ensure the Government receives the most comprehensive advice to meet the challenges ahead to cushion the economic impact of the coronavirus and help build a bridge to recovery.” I am very concerned with the pro-gas agenda of the Prime Minister’s hand-picked National Covid-19 Coordination Commission (NCCC). I’m concerned that the potential conflicts of interests and the networks of the gas-linked Commissioners will influence their advice. The Covid-19 Commission needs to be transparent and publish the details of their industry links and dealings. Recently the Commission chair Neville Power stated that a $2 billion liquid ammonia plant at Narrabri, proposed by Santos and Perdaman Industries, and proposed to be fuelled by Santos’ proposed Narrabri Gas Project, ‘tops the list’ of ventures that the NCCC will back. The Commission chair has also mooted the west-east gas pipeline from the North West Shelf previously rejected by the federal government. Furthermore, a leaked NCCC report calls for Australian taxpayers to underwrite gas industry expansion. Several of the NCCC members have strong links to the fossil fuel industry, and yet there is no publicly available conflict of interest register, no published diary to see who the Commission are meeting with, and no opportunities for the community to have a say. Specifically:
The NCCC needs a transparent conflict of interest register of all members, including special advisors. Furthermore, all findings and advice from the NCCC should be made in the best interests and in full view of the Australian people. It is unlikely that a gas led recovery will deliver the goods for an economic recovery. The industry is not a large employer and pays little or no tax. Analysis by The Australia Institute noted that the gas sector was one of the worst options to choose for mass job creation and that investment in other sectors would create more jobs. Gas supply on the east coast of Australia has tripled since 2014. However, domestic gas prices have also tripled in the same period. Gas prices in Australia have remained at levels far in excess of international parity prices. Whilst prices have fallen somewhat, they have not fallen by nearly as much as those in Asia or Europe. Consequently, gas has become uncompetitive as a fuel source for power generation in Australia and demand for gas-powered generation has fallen by 41% since 2014. Not surprising that at present there are no committed new investments in gas-fired power generation. Furthermore, as over 70% of Australian gas is exported as LNG, increases in supply are unlikely to affect to domestic prices into the near future and any potential flow on effect to the Australian economy. Methane leaks from natural gas production can make the process nearly as carbon intensive as coal. The CSIRO report “Fugitive Greenhouse Gas emissions from Coal Seam Gas Production in Australia” noted that fugitive emissions for Natural Gas in Australia as a whole are estimated to be 1.5% of gas extracted, whereas if fugitive emissions exceeded 2% then the emissions intensity would match that of coal (due to the fact that methane is 86 times more powerful as a greenhouse gas than CO2 over 20 years). They also noted that unconventional gas industry such as Coal Seam Gas would result in greater levels of fugitive emissions than the conventional gas industry. Natural gas has often been touted as the “transition fuel” for the electricity sector to replace coal’s greenhouse gas emissions and eventually paving the way for an emissions free future for Australia. It is simply too expensive and too emissions intensive to be so. In the case of the Narrabri Gas project supported by the NCCC, the proposed Narrabri Gas project will unlikely contribute to a reduction in gas prices, as gas extraction from this field will be more expensive than other existing fields in the eastern gas region. Moreover, the Narrabri Gas field has very high levels of CO2 which will be vented into the atmosphere as part of gas extraction adding to the methane fugitive emissions from the implementation of this project. The CSIRO GenCost report indicated that renewables (wind and solar photovoltaic) with storage (such as pumped hydro) were now cheaper than gas for electricity generation in Australia. Furthermore, the current installation of synchronous condensers in South Australia and other eastern states to increase system strength and stabilise the electricity network will reduce the need for gas-fired generators acting in the role of synchronous generators as more renewables enter the grid. As such, it is expected that demand for gas for electricity generation will decline in the future. The IMF stated that all economic stimulus post pandemic should have clear aspects and focus on decarbonisation, long term cost benefit, that there should be jobs and clear accountability from an emissions point of view what these projects will do. Expansion of the gas industry is unlikely to realise these important objectives. This month the International Energy Agency (IEA) stated that each country’s economic recovery packages post COVID-19 should be aligned to the Paris agreement to best meet agreed climate and sustainability objectives. A gas led recovery would not achieve this. They noted we need to look beyond fossil fuel candidates and look to new investment in job creating renewable energy and energy efficiencies that will decrease costs of energy and boost the economy. IEA also highlighted the massive opportunity open to us now in laying down the foundations for the huge technology driven growth in electric vehicles, batteries, and zero emission hydrogen-producing electrolysers. I’m concerned about gas industry connections in the NCCC potentially compromising the opportunity for a renewable energy-led recovery from the Covid-19 crisis. The consensus among economists is that we face long term financial impacts from the Covid-19 pandemic. We need long term, socially, economically and environmentally sustainable solutions to create the pathway out of the current economic downturn. Expansion of the gas industry is unlikely to achieve this. Monies and efforts are best spent in other areas. Furthermore, it is very important that the public have a say on the economic recovery efforts after Covid-19. There needs to be a process to allow diversity of industries to have a meaningful voice in the next steps for Australia. Our local communities and regional areas have so much to offer. Thank you for taking the time to read my submission. | Archives May 2020 |
Q&A Modern Monetary Theory with Prof Bill Mitchell
by Newcastle Climate Change Response
Newcastle Climate Change Response is very excited to facilitate a Q&A session with the amazing Bill Mitchell on Modern Monetary Theory and how peering through this lens may be useful to ensure a socially just and environmentally sound economic recovery from Covid-19 and how NCCRs and others may act to make this happen. If you don’t know what I’m on about, check this one out and then join us tomorrow from 4-5 with questions a ready!
Recording of Q&A
A recording of the Q&A session is below (recording starts shortly into the Q&A session).
To download the recording select the vertical ellipsis (3 dots) and select "Download".
To download the recording select the vertical ellipsis (3 dots) and select "Download".
Note: Submissions close May 1st 2020.
17/04/2020
Dear Professor Samuel and Independent Review Panel,
Thank you for the opportunity to provide a submission into the 2019-2020 Independent Review of the EPBC Act.
I live in the Lake Macquarie / Newcastle region in NSW. I work for the University of Newcastle, School of Environment and Life Sciences as a Project Officer and previously worked at the Tom Farrell Institute for the Environment. My current role involves conducting an environmental assessment for Norfolk Island. In a volunteer capacity, I am a committee member of several organisations including the Hunter Environmental Institute, Richmond Vale Rail Trail Inc., Newcastle Climate Change Response, Hunter Innovation and Science Hub, and the Clean Energy Association of Newcastle and Surrounds. I am also a member of the Charlestown chapter of The Wilderness Society. I am involved in what could be termed environmental outreach, informing the public on environmental information, news and activities through newsletters, conducting seminars, events and conferences. I have helped run the annual Mined Land Rehabilitation Conference and the Hunter Valley Electric Vehicle Festival over the last 4 years. On the ground I am involved with Landcare work for the Richmond Vale Rail Trail.
The EPBC Act is 20 years old and has failed to address the loss in biodiversity and extinction prevention of plants and animals or habitat destruction within Australia. The Act is complex and unwieldy and is in drastic need of reform. The Act needs to address the environmental threats that we face including climate change and habitat destruction through land clearing.
Rather than amending and modernising the Act, a new Act should be drafted with biodiversity conservation and environmental protection being the key drivers. The new Act should provide government leadership on environmental protection, include safeguards for plant and animal extinction including stopping habitat destruction of endangered species, and to increase resilience of plants and animals and their habitats to key challenges such as climate change.
The principle of Ecologically Sustainable Development is a key aspect with the Act and should be modernised and strengthened to include principles of continuous improvement and non-regression of environmental standards, goals, and policies; achieve high levels of environmental protection through best practices; and increased resilience to climate change and other pressures on the environment.
With my involvement with the Mined Land Rehabilitation Conference I have seen the effects of cumulative approvals of mines and mine expansion in the Hunter Valley on the environment, the decreased resilience to change, the health impact on individuals living and working within the area. For example, there is a cumulative issue relating to air quality in the Upper Hunter that needs attention. Average levels of coarse particle pollution in the Hunter Valley have increased at a rate higher than the rest of NSW. Air quality in the local area has been deteriorating over time, reaching 470 air quality alerts in 2019 prior to the bushfires. The top three for PM10 particulate levels of air pollution in NSW are in the local area. This air pollution contributes to heart disease, stroke, deaths, diabetes, low birth weight for babies, restricted lung growth in children, lung cancer in non-smokers, asthma and emphysema. A planned expansion of the Glendell Mine this year in the area would exacerbate an already dire set of circumstances with respect to air quality and health issues in the local area. However, the mine expansion went ahead as cumulative impacts are not considered in planning laws. The Act needs to explicitly consider cumulative impacts of past, present and future developments and decisions. The use of strategic environmental assessments may assist in assessing cumulative impacts.
The impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australian native wildlife, the Australian people and the wealth of the nation as noted by the recent catastrophic bushfires and devastating drought.
To ensure the health and resilience of the Australian environment and its people in the face of such challenges, laws and processes will need to be enacted to mitigate climate change and address the impacts of climate change, extreme weather and drought. This would include sustainably managing environments affected by climate change and rebuilding and restoring ecosystems burnt by bushfires. Although climate change is the most significant environmental threat it is not mentioned anywhere in the Act. The Act should address and regulate the impacts of climate change on biodiversity.
For example, following the recent catastrophic bushfires, koala populations are at a crisis point and it is imperative that urgent action be taken to ensure the survival of this iconic species within south eastern Australia.
Climate change is predicted to affect koala habitat conditions and cause more severe weather conditions (such as the recent severe drought and catastrophic bushfires) which will impact koala survival rates. Climate change is predicted to affect koala habitat by altering the structure and chemical composition of koala food trees, changing the composition of plant communities, and changing the range of important habitat species.
In my local area, changing sea levels as a result of climate change will impact on low lying priority habitat, within the Port Stephens area and Stockton Bight, further fragmenting habitat stands.
The ability of Koalas to migrate due to the effects of climate change are impacted by the connectivity across the landscape. Particular attention is required to remove or mitigate the barriers to connectivity and to preserve and enhance existing connectivity, such as undertaken in the Hunter Valley with the Great Eastern Ranges initiative. For example, regional and local conservation planning should consider protecting existing connectivity and enhancing connectivity of koala habitat patches that are within 100m of another patch.
Climate change considerations need to be included in the Act to identify and protect habitat and corridors that will support species resilience to more extreme heat and natural disasters, even if there is no population in those areas now.
Matters of national environmental significance (triggers) are an essential part of the Act that trigger assessment processes under the Act. These triggers should be retained and expanded to include vulnerable ecological communities (alongside other threatened specifies and ecological communities), significant land-clearing activities, significant water resources (in addition to coal seam gas and large coal impacts)., the National Reserve System, significant greenhouse gas emissions and nationally important ecosystems (key biodiversity areas and areas of high conservation value).
Any biodiversity offsetting must be based on clear scientific principles and limits and maintaining or improving ecological outcomes. The government should avoid lowest common denominator standards that rely on the market such as with the NSW system. The Act should not allow ‘offsetting’ critical habitat, endangered species and ecological communities. Furthermore, offset land should be of similar habitat (like-for-like), should provide an improvement for the impacted species or ecological community, must comply with the provision of no net loss of biodiversity, must be protected in perpetuity, should be consistent with any species recovery plans, cannot be substituted by the payment of money, such as into a Biodiversity Conservation Fund, and should be a last resort following efforts made to mitigate impacts.
Offset land must be an additional protection. For example, a developer cannot use existing parkland to offset koala habitat such as was proposed by Lendlease near Campbelltown in NSW last year.
From my personal experience with the Mine Rehab Conference, Mine Rehab land is unlikely to be an effective offset (in line with like-for-like habitat, no net loss of biodiversity, etc) and should be excluded. The former NSW Office of Environment and Heritage noted that “there is no certainty that functioning ecosystems can be restored to their original value through rehabilitation” and questioned whether restoration of biodiversity on a degraded site was even possible.
Offset land must be secured prior to development / land clearing going ahead. For example, after seven years and multiple time extensions, Whitehaven’s Maules Creek mine has failed to secure over 5000 hectares of biodiversity offsets for their clearing the critically endangered box gum grassy woodland ecological community near Narrabri and is now in court. Only 5% of this iconic woodland still exists and provides habitat for the Regent Honeyeater, Superb Parrot and Squirrel Glider.
Ecosystem services underpin human existence, health and prosperity, with biodiversity central to the production of ecosystems services. In recognising the intrinsic importance of the environment to Australia, the Act needs to acknowledge the value of ecosystem services. The assessment and value of ecosystem services also needs to be included in decision making to ensure potentially hidden social costs or benefits are considered.
To ensure government accountability and effective decision making, greater public transparency is required together with effective community consultation and the right of appeal. Decisions should be informed by community engagement (including public submissions) and the reasoning behind the decisions documented and provided back to the community. Specifically, the Act should provide information on policies, policy changes, and specific assessments, decisions and actions to the public in a timely and accessible manner. It should not be necessary to undertake lengthy and expensive FOI requests to get the reasoning behind decisions. The right of appeal should extend to the courts with judicial review of government decisions such that is available in the states. Similarly interested parties should be able to seek merits review of decisions.
To facilitate reform and effectiveness of the new Act, a national ecosystem assessment should be undertaken to establish a baseline and determine indicators of success / failure. National ecosystem assessments could then be undertaken periodically to help measure, maintain, and improve environmental outcomes.
To improve governance, a new national Environmental Protection Authority (EPA) needs to be established as the chief environmental regulator and to assess and approve projects, monitor compliance and take enforcement action. Furthermore, a new National Sustainability Commission be established to set national environmental goals and standards, coordinate national plans and actions, develop policy responses to current and future environmental impacts and in light of scientific evidence, and publicly report through Parliament each year on the state of the environment, impact of actions and environmental outcomes. The government should be required to respond to these reports.
And finally, resourcing has been a constant issue for the effective implementation of the Act. Government funding should be increased to enable this, such as resourcing to enable the effective implementation of environmental protection and restoration, and the listing and conserving of threatened species and ecological communities.
Thank you for your consideration of my submission
Sincerely,
Alec Roberts
Chair CLEANaS
References
Department of the Environment, Water Heritage and the Arts (2010) Ecosystem services: Key concepts and Applications. Retrieved from https://www.environment.gov.au/system/files/resources/b53e6002-4ea7-4108-acc8-40fff488bab7/files/ecosystem-services.pdf
Eco Logical Australia 2013. Lower Hunter Koala Study. Prepared for Dept Sustainability, Environment, Water, Population and Communities’.
Environmental Defenders Office (2020, April 3) Court challenge over coal mine’s critically endangered woodlands offsets failure. Retrieved from https://www.edo.org.au/2020/04/03/court-challenge-over-coal-mines-critically-endangered-woodlands-offsets-failure/?fbclid=IwAR0_7Ffv9e2_JD1R83l-VPEoU5lUwx05J1F5hs8TfnVjPJ_FVQkRBTUPjeM
Hannam, P. (2016, March 16) 'Very poor': Environment office opposed miners using rehabilitation work as biodiversity offset. Retrieved from https://www.smh.com.au/environment/very-poor-environment-office-opposed-miners-using-rehabilitation-work-as-biodiversity-offset-20160315-gnjfb3.html
Hannam, P. (2017 November 9) 'Greed trumps nature': Leaked report points to big offset savings for developers. Retrieved from https://www.smh.com.au/environment/greed-trumps-nature-leaked-report-points-to-big-offset-savings-for-developers-20171109-gzhnln.html
Hannam, P. (2018, October 29) 'Scam': Developer to use parkland to offset koala habitat destruction. Retrieved from https://www.smh.com.au/environment/conservation/scam-developer-to-use-parkland-to-offset-koala-habitat-destruction-20181028-p50cfz.html
Additional Sources (not included in submission):
Wildlife Preservation Society of Queensland (n.d.) Extension to submissions for EPBC Act review. Retrieved from https://wildlife.org.au/extension-to-submissions-for-epbc-act-review/
Australian Conservation Foundation (n.d.) How to write a great a submission to strengthen our national environment laws. Retrieved from https://docs.google.com/document/d/1lTIX62hfOOEp1kZVibVPHg7_axJoZuzt7GR7M1IUxbI/edit
WWF Australia (n.d.) Now is our chance to end animal extinction: Here is the message we are sending: Submission in response to the EPBC Act Review. Retrieved from https://www.wwf.org.au/get-involved/stop-australias-extinction-crisis
Hunter Bird Observers Club (n.d.) Submission to the 2019 Review of the Environment Protection and Biodiversity Conservation Act 1999. Retrieved from https://www.hboc.org.au/wp-content/uploads/EPBC-Act-Review-2020.pdf
Environmental Defenders Office (n.d.) EDO Submission to the EPBC Act Review Discussion Paper. Retrieved from https://www.edo.org.au/publication/submission-10-year-review-epbc-act/
Environmental Defenders Office (2020, April 3) Guide for making a submission to the EPBC Review. Retrieved from https://www.edo.org.au/publication/guide-for-submissions-to-epbc-review/
Samuel, G. (2019, November 21) Independent review of the EPBC Act: Discussion Paper. Retrieved from https://epbcactreview.environment.gov.au/resources/discussion-paper
Wilderness Society (n.d.) EPBC submission guide. Retrieved from https://www.wilderness.org.au/make-your-voice-heard
To submit your submission
Submissions close May 1st 2020.
To submit your submission complete questions 1 & 8, and attach your submission in question 7 in the link below
https://environment.au.citizenspace.com/epbc-review/epbc-act-review-submission-discussion-paper/consultation/
17/04/2020
Dear Professor Samuel and Independent Review Panel,
Thank you for the opportunity to provide a submission into the 2019-2020 Independent Review of the EPBC Act.
I live in the Lake Macquarie / Newcastle region in NSW. I work for the University of Newcastle, School of Environment and Life Sciences as a Project Officer and previously worked at the Tom Farrell Institute for the Environment. My current role involves conducting an environmental assessment for Norfolk Island. In a volunteer capacity, I am a committee member of several organisations including the Hunter Environmental Institute, Richmond Vale Rail Trail Inc., Newcastle Climate Change Response, Hunter Innovation and Science Hub, and the Clean Energy Association of Newcastle and Surrounds. I am also a member of the Charlestown chapter of The Wilderness Society. I am involved in what could be termed environmental outreach, informing the public on environmental information, news and activities through newsletters, conducting seminars, events and conferences. I have helped run the annual Mined Land Rehabilitation Conference and the Hunter Valley Electric Vehicle Festival over the last 4 years. On the ground I am involved with Landcare work for the Richmond Vale Rail Trail.
The EPBC Act is 20 years old and has failed to address the loss in biodiversity and extinction prevention of plants and animals or habitat destruction within Australia. The Act is complex and unwieldy and is in drastic need of reform. The Act needs to address the environmental threats that we face including climate change and habitat destruction through land clearing.
Rather than amending and modernising the Act, a new Act should be drafted with biodiversity conservation and environmental protection being the key drivers. The new Act should provide government leadership on environmental protection, include safeguards for plant and animal extinction including stopping habitat destruction of endangered species, and to increase resilience of plants and animals and their habitats to key challenges such as climate change.
The principle of Ecologically Sustainable Development is a key aspect with the Act and should be modernised and strengthened to include principles of continuous improvement and non-regression of environmental standards, goals, and policies; achieve high levels of environmental protection through best practices; and increased resilience to climate change and other pressures on the environment.
With my involvement with the Mined Land Rehabilitation Conference I have seen the effects of cumulative approvals of mines and mine expansion in the Hunter Valley on the environment, the decreased resilience to change, the health impact on individuals living and working within the area. For example, there is a cumulative issue relating to air quality in the Upper Hunter that needs attention. Average levels of coarse particle pollution in the Hunter Valley have increased at a rate higher than the rest of NSW. Air quality in the local area has been deteriorating over time, reaching 470 air quality alerts in 2019 prior to the bushfires. The top three for PM10 particulate levels of air pollution in NSW are in the local area. This air pollution contributes to heart disease, stroke, deaths, diabetes, low birth weight for babies, restricted lung growth in children, lung cancer in non-smokers, asthma and emphysema. A planned expansion of the Glendell Mine this year in the area would exacerbate an already dire set of circumstances with respect to air quality and health issues in the local area. However, the mine expansion went ahead as cumulative impacts are not considered in planning laws. The Act needs to explicitly consider cumulative impacts of past, present and future developments and decisions. The use of strategic environmental assessments may assist in assessing cumulative impacts.
The impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australian native wildlife, the Australian people and the wealth of the nation as noted by the recent catastrophic bushfires and devastating drought.
To ensure the health and resilience of the Australian environment and its people in the face of such challenges, laws and processes will need to be enacted to mitigate climate change and address the impacts of climate change, extreme weather and drought. This would include sustainably managing environments affected by climate change and rebuilding and restoring ecosystems burnt by bushfires. Although climate change is the most significant environmental threat it is not mentioned anywhere in the Act. The Act should address and regulate the impacts of climate change on biodiversity.
For example, following the recent catastrophic bushfires, koala populations are at a crisis point and it is imperative that urgent action be taken to ensure the survival of this iconic species within south eastern Australia.
Climate change is predicted to affect koala habitat conditions and cause more severe weather conditions (such as the recent severe drought and catastrophic bushfires) which will impact koala survival rates. Climate change is predicted to affect koala habitat by altering the structure and chemical composition of koala food trees, changing the composition of plant communities, and changing the range of important habitat species.
In my local area, changing sea levels as a result of climate change will impact on low lying priority habitat, within the Port Stephens area and Stockton Bight, further fragmenting habitat stands.
The ability of Koalas to migrate due to the effects of climate change are impacted by the connectivity across the landscape. Particular attention is required to remove or mitigate the barriers to connectivity and to preserve and enhance existing connectivity, such as undertaken in the Hunter Valley with the Great Eastern Ranges initiative. For example, regional and local conservation planning should consider protecting existing connectivity and enhancing connectivity of koala habitat patches that are within 100m of another patch.
Climate change considerations need to be included in the Act to identify and protect habitat and corridors that will support species resilience to more extreme heat and natural disasters, even if there is no population in those areas now.
Matters of national environmental significance (triggers) are an essential part of the Act that trigger assessment processes under the Act. These triggers should be retained and expanded to include vulnerable ecological communities (alongside other threatened specifies and ecological communities), significant land-clearing activities, significant water resources (in addition to coal seam gas and large coal impacts)., the National Reserve System, significant greenhouse gas emissions and nationally important ecosystems (key biodiversity areas and areas of high conservation value).
Any biodiversity offsetting must be based on clear scientific principles and limits and maintaining or improving ecological outcomes. The government should avoid lowest common denominator standards that rely on the market such as with the NSW system. The Act should not allow ‘offsetting’ critical habitat, endangered species and ecological communities. Furthermore, offset land should be of similar habitat (like-for-like), should provide an improvement for the impacted species or ecological community, must comply with the provision of no net loss of biodiversity, must be protected in perpetuity, should be consistent with any species recovery plans, cannot be substituted by the payment of money, such as into a Biodiversity Conservation Fund, and should be a last resort following efforts made to mitigate impacts.
Offset land must be an additional protection. For example, a developer cannot use existing parkland to offset koala habitat such as was proposed by Lendlease near Campbelltown in NSW last year.
From my personal experience with the Mine Rehab Conference, Mine Rehab land is unlikely to be an effective offset (in line with like-for-like habitat, no net loss of biodiversity, etc) and should be excluded. The former NSW Office of Environment and Heritage noted that “there is no certainty that functioning ecosystems can be restored to their original value through rehabilitation” and questioned whether restoration of biodiversity on a degraded site was even possible.
Offset land must be secured prior to development / land clearing going ahead. For example, after seven years and multiple time extensions, Whitehaven’s Maules Creek mine has failed to secure over 5000 hectares of biodiversity offsets for their clearing the critically endangered box gum grassy woodland ecological community near Narrabri and is now in court. Only 5% of this iconic woodland still exists and provides habitat for the Regent Honeyeater, Superb Parrot and Squirrel Glider.
Ecosystem services underpin human existence, health and prosperity, with biodiversity central to the production of ecosystems services. In recognising the intrinsic importance of the environment to Australia, the Act needs to acknowledge the value of ecosystem services. The assessment and value of ecosystem services also needs to be included in decision making to ensure potentially hidden social costs or benefits are considered.
To ensure government accountability and effective decision making, greater public transparency is required together with effective community consultation and the right of appeal. Decisions should be informed by community engagement (including public submissions) and the reasoning behind the decisions documented and provided back to the community. Specifically, the Act should provide information on policies, policy changes, and specific assessments, decisions and actions to the public in a timely and accessible manner. It should not be necessary to undertake lengthy and expensive FOI requests to get the reasoning behind decisions. The right of appeal should extend to the courts with judicial review of government decisions such that is available in the states. Similarly interested parties should be able to seek merits review of decisions.
To facilitate reform and effectiveness of the new Act, a national ecosystem assessment should be undertaken to establish a baseline and determine indicators of success / failure. National ecosystem assessments could then be undertaken periodically to help measure, maintain, and improve environmental outcomes.
To improve governance, a new national Environmental Protection Authority (EPA) needs to be established as the chief environmental regulator and to assess and approve projects, monitor compliance and take enforcement action. Furthermore, a new National Sustainability Commission be established to set national environmental goals and standards, coordinate national plans and actions, develop policy responses to current and future environmental impacts and in light of scientific evidence, and publicly report through Parliament each year on the state of the environment, impact of actions and environmental outcomes. The government should be required to respond to these reports.
And finally, resourcing has been a constant issue for the effective implementation of the Act. Government funding should be increased to enable this, such as resourcing to enable the effective implementation of environmental protection and restoration, and the listing and conserving of threatened species and ecological communities.
Thank you for your consideration of my submission
Sincerely,
Alec Roberts
Chair CLEANaS
References
Department of the Environment, Water Heritage and the Arts (2010) Ecosystem services: Key concepts and Applications. Retrieved from https://www.environment.gov.au/system/files/resources/b53e6002-4ea7-4108-acc8-40fff488bab7/files/ecosystem-services.pdf
Eco Logical Australia 2013. Lower Hunter Koala Study. Prepared for Dept Sustainability, Environment, Water, Population and Communities’.
Environmental Defenders Office (2020, April 3) Court challenge over coal mine’s critically endangered woodlands offsets failure. Retrieved from https://www.edo.org.au/2020/04/03/court-challenge-over-coal-mines-critically-endangered-woodlands-offsets-failure/?fbclid=IwAR0_7Ffv9e2_JD1R83l-VPEoU5lUwx05J1F5hs8TfnVjPJ_FVQkRBTUPjeM
Hannam, P. (2016, March 16) 'Very poor': Environment office opposed miners using rehabilitation work as biodiversity offset. Retrieved from https://www.smh.com.au/environment/very-poor-environment-office-opposed-miners-using-rehabilitation-work-as-biodiversity-offset-20160315-gnjfb3.html
Hannam, P. (2017 November 9) 'Greed trumps nature': Leaked report points to big offset savings for developers. Retrieved from https://www.smh.com.au/environment/greed-trumps-nature-leaked-report-points-to-big-offset-savings-for-developers-20171109-gzhnln.html
Hannam, P. (2018, October 29) 'Scam': Developer to use parkland to offset koala habitat destruction. Retrieved from https://www.smh.com.au/environment/conservation/scam-developer-to-use-parkland-to-offset-koala-habitat-destruction-20181028-p50cfz.html
Additional Sources (not included in submission):
Wildlife Preservation Society of Queensland (n.d.) Extension to submissions for EPBC Act review. Retrieved from https://wildlife.org.au/extension-to-submissions-for-epbc-act-review/
Australian Conservation Foundation (n.d.) How to write a great a submission to strengthen our national environment laws. Retrieved from https://docs.google.com/document/d/1lTIX62hfOOEp1kZVibVPHg7_axJoZuzt7GR7M1IUxbI/edit
WWF Australia (n.d.) Now is our chance to end animal extinction: Here is the message we are sending: Submission in response to the EPBC Act Review. Retrieved from https://www.wwf.org.au/get-involved/stop-australias-extinction-crisis
Hunter Bird Observers Club (n.d.) Submission to the 2019 Review of the Environment Protection and Biodiversity Conservation Act 1999. Retrieved from https://www.hboc.org.au/wp-content/uploads/EPBC-Act-Review-2020.pdf
Environmental Defenders Office (n.d.) EDO Submission to the EPBC Act Review Discussion Paper. Retrieved from https://www.edo.org.au/publication/submission-10-year-review-epbc-act/
Environmental Defenders Office (2020, April 3) Guide for making a submission to the EPBC Review. Retrieved from https://www.edo.org.au/publication/guide-for-submissions-to-epbc-review/
Samuel, G. (2019, November 21) Independent review of the EPBC Act: Discussion Paper. Retrieved from https://epbcactreview.environment.gov.au/resources/discussion-paper
Wilderness Society (n.d.) EPBC submission guide. Retrieved from https://www.wilderness.org.au/make-your-voice-heard
To submit your submission
Submissions close May 1st 2020.
To submit your submission complete questions 1 & 8, and attach your submission in question 7 in the link below
https://environment.au.citizenspace.com/epbc-review/epbc-act-review-submission-discussion-paper/consultation/
Submission to the Draft Koala Habitat Protection Guideline
by Alec Roberts
To whom it may concern,
Please accept this letter as my submission to the Draft Koala Habitat Protection Guideline. I consent to the Department making this submission and my name public.
Following the recent catastrophic bushfires, koala populations are at a crisis point and it is imperative that urgent action is taken to ensure the survival of this iconic species within NSW.
Koalas are currently listed as a vulnerable threatened species in NSW, and therefore have a high risk of local extinction in the medium term. In 2016 it was estimated that there remained approximately 36,000 koalas in NSW (representing a decline of 26% over 2 decades). However, other studies suggest much lower numbers. Furthermore, compounding this, more than 24% of koala habitats were within fire-affected areas in eastern NSW with the recent bushfires.
In my area of the Lower Hunter, areas of know Koala Habitat have had an estimated 75% reduction in habitat since European Settlement with commensurate declines in koala population due to habitat clearing. Furthermore, areas of high priority koala habitat are often unprotected, with just over 20 percent within existing formal conservation reserves.
The main threats to Koala populations across the Lower Hunter include:
Changes in habitat in the Lower Hunter can be attributed to high development pressure and piecemeal planning resulting in isolated fragments of habitat remaining between urban areas. The long-term conservation of koalas is reliant on understanding habitat requirements and population dynamics and incorporating this into urban planning. The Koala SEPP 2019 and the Guideline should provide consistent requirements for development assessment on core koala habitat across the State.
NSW laws do not prohibit the clearing of koala habitat. Despite declining koala numbers and the devastation caused by this summer’s catastrophic bushfires, NSW laws still allow koala habitat to be cleared with approval. Decision makers just need to ensure development approvals are consistent with koala plans of management (if they exist) or these guidelines are considered. For our laws to protect koalas and their habitats, the approval process should not allow important koala habitat to be offset or cleared in exchange for money (as NSW Biodiversity Assessment Method does).
Comprehensive koala plans of management should be mandatory for all councils wherever there is koala habitat with a set completion timeframe. With only 5 LGAs adopting comprehensive koala plans of management since 1995 (including only one from the Lower Hunter) a mandatory approach is required. These plans should be monitored, reviewed and reported publicly on a set and regular timeframe. To assist local councils with these obligations the NSW government should provide incentive and support for councils to develop and maintain these plans. Furthermore, for consistency, the Koala SEPP 2019 should be applicable across the state wherever there is koala habitat.
The Koala SEPP 2019 and the Guideline need to apply to a wider range of developments and activities that can impact on koala habitat that are outside of the domain of local councils including: complying development, major projects (State significant development and State significant infrastructure), Part 5 activities (e.g. activities undertaken by public authorities) and land clearing activities requiring approval under the LLS Act. The NSW planning system, public and private forestry, and land management (land clearing) laws fail to protect koala habitat. The limited application of the Koala SEPP 2019 is unlikely to lead to improved outcomes for koalas.
The threshold of 1 hectare for triggering the Koala SEPP 2019 where a plan is not in place is arbitrary and leaves small koala habitat areas, particularly koala habitat in urban areas, without adequate protection. The one-hectare requirement also contributes to cumulative impacts and can reduce connectivity across the landscape by allowing small patches to be cleared. The threshold should be removed.
Climate change considerations need to be included in the Koala SEPP 2019 and the Guideline to identify and protect habitat and corridors that will support koalas’ resilience to more extreme heat and natural disasters, even if there is no koala population in those areas now.
Climate change is predicted to affect koala habitat condition and cause more severe weather conditions (such as the recent severe drought and catastrophic bushfires) which will impact koala survival rates. Climate change is predicted to affect koala habitat by altering the structure and chemical composition of koala food trees, changing the composition of plant communities, and changing the range of important habitat species.
Changing sea levels as a result of climate change will impact on low lying priority habitat area with Port Stephens area and Stockton Bight affected, further fragmenting habitat stands.
The ability of Koalas to migrate due to the effects of climate change are impacted by the connectivity across the landscape. Particular attention is required to remove or mitigate the barriers to connectivity and to preserve and enhance existing connectivity, such as undertaken in the Hunter with the Great Eastern Ranges initiative. For example, regional and local conservation planning should consider protecting existing connectivity and enhancing connectivity of koala habitat patches that are within 100m of another patch.
Koala research findings, and potential application of mitigation measures, should feed back into the Koala SEPP 2019 and the Guideline, as part of a regular review process. In particular, new information should be added to Koala Development Application Maps and Site Investigation Area for Koala Plans of Management Maps to ensure they are current and accurate. The processes for the development and application of these maps needs to be transparent to allow for effective ground-truthing to ensure accuracy.
Regular monitoring and compliance are required to ensure the success of the Koala SEPP and Guideline. Monitoring, review, public reporting and compliance need to be established with a defined and regular timeframe.
To protect koalas, koala habitat must be protected from destruction. The Koala SEPP 2019 at present does not increase the protection for koala habitat. Until our laws are strengthened to truly limit or prohibit the destruction of koala habitat, koala populations and their habitat will continue to be at risk and koala numbers will continue to decline in NSW, possibly to the point of local extinction.
I urge the Department and relevant Ministers to strengthen the Koala SEPP 2019, the Koala Habitat Protection Guideline and provide incentive and support for councils.
Yours sincerely,
Alec Roberts
Gateshead 2290
I have read the Department's Privacy Statement and agree to the Department using my submission in the ways it describes. I understand this includes full publication on the Department's website of my submission, any attachments, and any of my personal information in those documents and possible supply to third parties such as state agencies, local government and the proponent.
References:
Adams-Hosking, C., McAlpine, C., Rhodes, J. R., Grantham, H. S. and Moss, P. T. (2012). "Modelling changes in the distribution of the critical food resources of a specialist folivore in response to climate change." Journal of Conservation Biogeography Diversity and Distributions: 1-14.
Biodiversity Conservation Act 2016, s 4.4(3)
Department of Planning, Industry and Environment, Understanding the impact of the 2019-20 fires, https://www.environment.nsw.gov.au/topics/parks-reserves-and-protected-areas/fire/park-recovery-and-rehabilitation/recovering-from-2019-20-fires/understanding-the-impact-of-the-2019-20-fires
Department of Planning, Industry and Environment, Koala conservation, https://www.environment.nsw.gov.au/topics/animals-and-plants/native-animals/native-animal-facts/koala/koala-conservation
‘Eco Logical Australia 2013. Lower Hunter Koala Study. Prepared for Dept Sustainability, Environment, Water, Population and Communities’.
Local Land Services, Threatened Fauna of the Hunter & Mid Coast: Koala,2019, https://www.lls.nsw.gov.au/__data/assets/pdf_file/0007/1118563/koala.pdf
NSW Chief Scientist & Engineer, Report of the Independent Review into the Decline of Koala Populations in Key Areas of NSW, December 2016 above no 6, citing Adams-Hosking, C, McBride, M.F, Baxter, G, Burgman, M, de Villiers, D, Kavanagh, R, Lawler, I, Lunney, D, Melzer, A, Menkhorst, P, Molsher, R, et al. (2016). Use of expert knowledge to elicit population trends for the koala (Phascolarctos cinereus). Diversity and Distributions, 22(3), 249-262. doi: 10.1111/ddi.12400
Paull, D., Pugh, D., Sweeney, O., Taylor, M, Woosnam, O. and Hawes, W. Koala habitat conservation plan. An action plan for legislative change and the identification of priority koala habitat necessary to protect and enhance koala habitat and populations in New South Wales and Queensland (2019), published by WWF-Australia, Sydney, which estimates koala numbers to be in the range of 15,000 to 25,000 animals. In 2018, the Australian Koala Foundations estimates koala numbers in NSW to be between 11,555 and 16,130 animals, see www.savethekoala.com/our-work/bobs-map-%E2%80%93-koala-populations-then-and-now
Additional Sources (not referenced in submission):
Environmental Defenders Office, Analysis: Koalas: new laws – old tricks, February 20, 2020,
https://www.edo.org.au/2020/02/20/koalas-nsw-new-laws-old-tricks/#_edn1
Nature Conservation Council, Submission Guide: Koala Habitat Protection Guideline, 2020, https://www.nature.org.au/news-and-resources/submission-guides/koala-habitat-protection-guideline/
Nature Conservation Council, 2020, Defend koala protection laws, https://www.nature.org.au/get-involved/take-action/koala-sepp-guidelines-review/
by Alec Roberts
To whom it may concern,
Please accept this letter as my submission to the Draft Koala Habitat Protection Guideline. I consent to the Department making this submission and my name public.
Following the recent catastrophic bushfires, koala populations are at a crisis point and it is imperative that urgent action is taken to ensure the survival of this iconic species within NSW.
Koalas are currently listed as a vulnerable threatened species in NSW, and therefore have a high risk of local extinction in the medium term. In 2016 it was estimated that there remained approximately 36,000 koalas in NSW (representing a decline of 26% over 2 decades). However, other studies suggest much lower numbers. Furthermore, compounding this, more than 24% of koala habitats were within fire-affected areas in eastern NSW with the recent bushfires.
In my area of the Lower Hunter, areas of know Koala Habitat have had an estimated 75% reduction in habitat since European Settlement with commensurate declines in koala population due to habitat clearing. Furthermore, areas of high priority koala habitat are often unprotected, with just over 20 percent within existing formal conservation reserves.
The main threats to Koala populations across the Lower Hunter include:
- Fragmentation, degradation and loss of habitat (at both macro and micro scale);
- Barriers to habitat connectivity (both natural and manmade);
- Road fatalities;
- Predation by dogs;
- Disease (e.g. Chlamydia);
- Fire (bushfires and control burns); and
- Climate Change.
Changes in habitat in the Lower Hunter can be attributed to high development pressure and piecemeal planning resulting in isolated fragments of habitat remaining between urban areas. The long-term conservation of koalas is reliant on understanding habitat requirements and population dynamics and incorporating this into urban planning. The Koala SEPP 2019 and the Guideline should provide consistent requirements for development assessment on core koala habitat across the State.
NSW laws do not prohibit the clearing of koala habitat. Despite declining koala numbers and the devastation caused by this summer’s catastrophic bushfires, NSW laws still allow koala habitat to be cleared with approval. Decision makers just need to ensure development approvals are consistent with koala plans of management (if they exist) or these guidelines are considered. For our laws to protect koalas and their habitats, the approval process should not allow important koala habitat to be offset or cleared in exchange for money (as NSW Biodiversity Assessment Method does).
Comprehensive koala plans of management should be mandatory for all councils wherever there is koala habitat with a set completion timeframe. With only 5 LGAs adopting comprehensive koala plans of management since 1995 (including only one from the Lower Hunter) a mandatory approach is required. These plans should be monitored, reviewed and reported publicly on a set and regular timeframe. To assist local councils with these obligations the NSW government should provide incentive and support for councils to develop and maintain these plans. Furthermore, for consistency, the Koala SEPP 2019 should be applicable across the state wherever there is koala habitat.
The Koala SEPP 2019 and the Guideline need to apply to a wider range of developments and activities that can impact on koala habitat that are outside of the domain of local councils including: complying development, major projects (State significant development and State significant infrastructure), Part 5 activities (e.g. activities undertaken by public authorities) and land clearing activities requiring approval under the LLS Act. The NSW planning system, public and private forestry, and land management (land clearing) laws fail to protect koala habitat. The limited application of the Koala SEPP 2019 is unlikely to lead to improved outcomes for koalas.
The threshold of 1 hectare for triggering the Koala SEPP 2019 where a plan is not in place is arbitrary and leaves small koala habitat areas, particularly koala habitat in urban areas, without adequate protection. The one-hectare requirement also contributes to cumulative impacts and can reduce connectivity across the landscape by allowing small patches to be cleared. The threshold should be removed.
Climate change considerations need to be included in the Koala SEPP 2019 and the Guideline to identify and protect habitat and corridors that will support koalas’ resilience to more extreme heat and natural disasters, even if there is no koala population in those areas now.
Climate change is predicted to affect koala habitat condition and cause more severe weather conditions (such as the recent severe drought and catastrophic bushfires) which will impact koala survival rates. Climate change is predicted to affect koala habitat by altering the structure and chemical composition of koala food trees, changing the composition of plant communities, and changing the range of important habitat species.
Changing sea levels as a result of climate change will impact on low lying priority habitat area with Port Stephens area and Stockton Bight affected, further fragmenting habitat stands.
The ability of Koalas to migrate due to the effects of climate change are impacted by the connectivity across the landscape. Particular attention is required to remove or mitigate the barriers to connectivity and to preserve and enhance existing connectivity, such as undertaken in the Hunter with the Great Eastern Ranges initiative. For example, regional and local conservation planning should consider protecting existing connectivity and enhancing connectivity of koala habitat patches that are within 100m of another patch.
Koala research findings, and potential application of mitigation measures, should feed back into the Koala SEPP 2019 and the Guideline, as part of a regular review process. In particular, new information should be added to Koala Development Application Maps and Site Investigation Area for Koala Plans of Management Maps to ensure they are current and accurate. The processes for the development and application of these maps needs to be transparent to allow for effective ground-truthing to ensure accuracy.
Regular monitoring and compliance are required to ensure the success of the Koala SEPP and Guideline. Monitoring, review, public reporting and compliance need to be established with a defined and regular timeframe.
To protect koalas, koala habitat must be protected from destruction. The Koala SEPP 2019 at present does not increase the protection for koala habitat. Until our laws are strengthened to truly limit or prohibit the destruction of koala habitat, koala populations and their habitat will continue to be at risk and koala numbers will continue to decline in NSW, possibly to the point of local extinction.
I urge the Department and relevant Ministers to strengthen the Koala SEPP 2019, the Koala Habitat Protection Guideline and provide incentive and support for councils.
Yours sincerely,
Alec Roberts
Gateshead 2290
I have read the Department's Privacy Statement and agree to the Department using my submission in the ways it describes. I understand this includes full publication on the Department's website of my submission, any attachments, and any of my personal information in those documents and possible supply to third parties such as state agencies, local government and the proponent.
References:
Adams-Hosking, C., McAlpine, C., Rhodes, J. R., Grantham, H. S. and Moss, P. T. (2012). "Modelling changes in the distribution of the critical food resources of a specialist folivore in response to climate change." Journal of Conservation Biogeography Diversity and Distributions: 1-14.
Biodiversity Conservation Act 2016, s 4.4(3)
Department of Planning, Industry and Environment, Understanding the impact of the 2019-20 fires, https://www.environment.nsw.gov.au/topics/parks-reserves-and-protected-areas/fire/park-recovery-and-rehabilitation/recovering-from-2019-20-fires/understanding-the-impact-of-the-2019-20-fires
Department of Planning, Industry and Environment, Koala conservation, https://www.environment.nsw.gov.au/topics/animals-and-plants/native-animals/native-animal-facts/koala/koala-conservation
‘Eco Logical Australia 2013. Lower Hunter Koala Study. Prepared for Dept Sustainability, Environment, Water, Population and Communities’.
Local Land Services, Threatened Fauna of the Hunter & Mid Coast: Koala,2019, https://www.lls.nsw.gov.au/__data/assets/pdf_file/0007/1118563/koala.pdf
NSW Chief Scientist & Engineer, Report of the Independent Review into the Decline of Koala Populations in Key Areas of NSW, December 2016 above no 6, citing Adams-Hosking, C, McBride, M.F, Baxter, G, Burgman, M, de Villiers, D, Kavanagh, R, Lawler, I, Lunney, D, Melzer, A, Menkhorst, P, Molsher, R, et al. (2016). Use of expert knowledge to elicit population trends for the koala (Phascolarctos cinereus). Diversity and Distributions, 22(3), 249-262. doi: 10.1111/ddi.12400
Paull, D., Pugh, D., Sweeney, O., Taylor, M, Woosnam, O. and Hawes, W. Koala habitat conservation plan. An action plan for legislative change and the identification of priority koala habitat necessary to protect and enhance koala habitat and populations in New South Wales and Queensland (2019), published by WWF-Australia, Sydney, which estimates koala numbers to be in the range of 15,000 to 25,000 animals. In 2018, the Australian Koala Foundations estimates koala numbers in NSW to be between 11,555 and 16,130 animals, see www.savethekoala.com/our-work/bobs-map-%E2%80%93-koala-populations-then-and-now
Additional Sources (not referenced in submission):
Environmental Defenders Office, Analysis: Koalas: new laws – old tricks, February 20, 2020,
https://www.edo.org.au/2020/02/20/koalas-nsw-new-laws-old-tricks/#_edn1
Nature Conservation Council, Submission Guide: Koala Habitat Protection Guideline, 2020, https://www.nature.org.au/news-and-resources/submission-guides/koala-habitat-protection-guideline/
Nature Conservation Council, 2020, Defend koala protection laws, https://www.nature.org.au/get-involved/take-action/koala-sepp-guidelines-review/
Independent member for Warringah , Zalli Steggall has launched her intention to introduce a private members bill to parliament on climate action. If you live in the Shortland electorate and you'd like to let Pat Conroy know that you would like him to support this bill click on the following link https://climateactnow.com.au/, select your electorate, and enter your name and email address. With a little extra energy you could contact Pat directly by email or mail if you would like to make your preferences known to him prior to the bill (Personal emails work the best). Thanks for your support.
For those outside the Shortland electorate please contact your local Federal member:
Hunter - Joel Fitzgibbon ALP
Newcastle - Sharon Claydon ALP
Paterson - Meryl Swanson ALP
#ClimateActNow
This letter was written requesting support for the Climate Change Bill by Pat Conroy my local Federal member of Parliament:
Pat,
Support for Climate Change Bill
The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the health and wellbeing of its citizens and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australians and the wealth of the nation as noted by the recent catastrophic bushfires and devastating drought.
As one of your constituents, I’m writing to urge you to support the Climate Change Bill that will be introduced into parliament on Monday March 23rd by way of a conscience vote.
I support the proposed Climate Change legislation because I believe it’s vital that we have a national climate change framework that ensures Australia has:
There are 20 other countries already with Climate Change framework legislation such as the UK and New Zealand that we could learn and adapt from.
This bill gives Australia the ability to respond as a nation to the risks, challenges and opportunities of climate change and provides a proven legislative framework to lead a transition to a zero-carbon economy.
It will provide the business sector with certainty and position Australia to take advantage of the world demand for low emissions technology.
The cost of inaction far outweighs the cost of action as shown by natural disasters such as the recent bushfires, droughts, and floods. As the costs will increase of these more prevalent and severe disasters as warming increases.
The Climate Change Bill aims to protect the Australian economy against these impacts.
I implore you to support the Climate Change Bill.
Thank you for taking the time to read my letter.
Yours Sincerely
Alec Roberts
Gateshead, NSW
Project Manager | Chair CLEANaS
For those outside the Shortland electorate please contact your local Federal member:
Hunter - Joel Fitzgibbon ALP
Newcastle - Sharon Claydon ALP
Paterson - Meryl Swanson ALP
#ClimateActNow
This letter was written requesting support for the Climate Change Bill by Pat Conroy my local Federal member of Parliament:
Pat,
Support for Climate Change Bill
The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the health and wellbeing of its citizens and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australians and the wealth of the nation as noted by the recent catastrophic bushfires and devastating drought.
As one of your constituents, I’m writing to urge you to support the Climate Change Bill that will be introduced into parliament on Monday March 23rd by way of a conscience vote.
I support the proposed Climate Change legislation because I believe it’s vital that we have a national climate change framework that ensures Australia has:
- Long-term plans for reducing greenhouse gas emissions to meet emissions reduction statutory targets which align with the science and international commitments (Net-zero emissions by 2050);
- A positive response to the challenges of climate change that looks to new opportunities, just transitions from legacy industries and addresses generational equity;
- Plans for adapting to the effects of climate change, whether that be responding to changing physical conditions or developing progressive international policies; and
- Transparent and accountable adaptation and mitigation planning through an independent Climate Change Commission to advise the Government.
There are 20 other countries already with Climate Change framework legislation such as the UK and New Zealand that we could learn and adapt from.
This bill gives Australia the ability to respond as a nation to the risks, challenges and opportunities of climate change and provides a proven legislative framework to lead a transition to a zero-carbon economy.
It will provide the business sector with certainty and position Australia to take advantage of the world demand for low emissions technology.
The cost of inaction far outweighs the cost of action as shown by natural disasters such as the recent bushfires, droughts, and floods. As the costs will increase of these more prevalent and severe disasters as warming increases.
The Climate Change Bill aims to protect the Australian economy against these impacts.
I implore you to support the Climate Change Bill.
Thank you for taking the time to read my letter.
Yours Sincerely
Alec Roberts
Gateshead, NSW
Project Manager | Chair CLEANaS
Submission on Glendell Continuation Project (part of Mt Owen Complex)
by Alec Roberts (thanks to George Woods for the great info supporting this submission)
Objection to Project
Climate Change
The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the health and wellbeing of its citizens and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australians and the wealth of the nation.
NSW Climate Change Policy Framework details NSW Government’s objective to achieve net-zero emissions by 2050. This long-term objective “sets a clear statement of government’s intent, commitment and level of ambition and sets expectations about future emissions constraints that will help the private sector to plan and act.” The Policy Framework states that the NSW Government will investigate how to embed consideration of climate change mitigation and adaptation across government operations including service delivery, infrastructure, purchasing decisions and regulatory frameworks. Furthermore, it states that Agencies will undertake additional policy investigation for sectors with significant opportunities and risks, including primary industries emissions and adaptation (Department of Primary Industries).
The Glendell Continuation Project will result in 230.8 million tonnes of greenhouse gases over the life of the project. This is in addition to the greenhouse pollution from the rest of the Mount Owen complex.
The assessment admits that the project is consistent with the IPCC’s “high emissions A2 emission trajectory scenario.” This is a shocking admission and all the more shocking that it did not prompt the company to withdraw the proposal. The A2 scenario is projected to result in warming by approximately 3.4C by 2100. As the greenhouse assessment outlines, this scenario is associated with increased maximum temperatures, hot days and severe fire danger days.
This project is not consistent with NSW’s climate change policy, the principle of inter-generational equity nor the public interest, as it clearly assumes failure to meet the Paris Agreement temperature goals and worsening climate change impacts for New South Wales.
Air quality
There is a cumulative issue relating to air quality in the Upper Hunter that needs attention. Average levels of coarse particle pollution in the Hunter Valley have increased at a rate higher than the rest of NSW
Air quality in the local area has been deteriorating over time, reaching 470 air quality alerts in 2019 prior to the bushfires.
The top three for PM10 particulate levels of air pollution in NSW are in the local area.
This air pollution contributes to heart disease, stroke, deaths, diabetes, low birth weight for babies, restricted lung growth in children, lung cancer in non-smokers, asthma and emphysema.
The expansion will exacerbate an already dire set of circumstances with respect to air quality and health issues in the local area.
The mine assessment admits that most air quality monitoring sites in the vicinity of Glendell Mine have experienced at least one day above the national standards for PM10 particulate pollution in the past seven years and some exceeded annual average thresholds in the last two years. Camberwell and Singleton also exceeded the PM2.5 criterion last year.
But the EIS uses a low pollution year, 2014, as its base year, setting background air pollution levels at less than half of the pollution concentrations experienced in the vicinity more recently. Nevertheless, the assessment shows intensification of PM2.5 and PM10 air pollution in Camberwell and surrounding areas.
Water Loss
This project further extends mining in a heavily-mined area, exacerbating water loss.
Baseline monitoring has identified water level drawdown within the coal seams due to the cumulative impact of approved activities that surround the proposed Glendell Pit Extension. The Environmental assessment noted
“The proposed Glendell Pit Extension will further depressurise the geological strata directly intersected by the mining activities. The Project will create a zone of drawdown around the mining activity where groundwater levels will decline during the mine life. The depressurisation will also create an area of low pressure within the groundwater system centred on the Glendell Pit Extension that will encourage groundwater to flow through coal seams towards the mining area drawing groundwater from the adjacent water sources.”
The mine’s groundwater assessment shows that dramatic drawdown of the coal seam under the Bowman’s Creek alluvium propagates upward into the alluvium and causes drawdown and loss of surface water.
This adds to stress already being experienced in the area from other mines, and the groundwater assessment also shows cumulative draw down of over 2 metres in the alluvium during the proposed mining operations.
by Alec Roberts (thanks to George Woods for the great info supporting this submission)
Objection to Project
Climate Change
The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the health and wellbeing of its citizens and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australians and the wealth of the nation.
NSW Climate Change Policy Framework details NSW Government’s objective to achieve net-zero emissions by 2050. This long-term objective “sets a clear statement of government’s intent, commitment and level of ambition and sets expectations about future emissions constraints that will help the private sector to plan and act.” The Policy Framework states that the NSW Government will investigate how to embed consideration of climate change mitigation and adaptation across government operations including service delivery, infrastructure, purchasing decisions and regulatory frameworks. Furthermore, it states that Agencies will undertake additional policy investigation for sectors with significant opportunities and risks, including primary industries emissions and adaptation (Department of Primary Industries).
The Glendell Continuation Project will result in 230.8 million tonnes of greenhouse gases over the life of the project. This is in addition to the greenhouse pollution from the rest of the Mount Owen complex.
The assessment admits that the project is consistent with the IPCC’s “high emissions A2 emission trajectory scenario.” This is a shocking admission and all the more shocking that it did not prompt the company to withdraw the proposal. The A2 scenario is projected to result in warming by approximately 3.4C by 2100. As the greenhouse assessment outlines, this scenario is associated with increased maximum temperatures, hot days and severe fire danger days.
This project is not consistent with NSW’s climate change policy, the principle of inter-generational equity nor the public interest, as it clearly assumes failure to meet the Paris Agreement temperature goals and worsening climate change impacts for New South Wales.
Air quality
There is a cumulative issue relating to air quality in the Upper Hunter that needs attention. Average levels of coarse particle pollution in the Hunter Valley have increased at a rate higher than the rest of NSW
Air quality in the local area has been deteriorating over time, reaching 470 air quality alerts in 2019 prior to the bushfires.
The top three for PM10 particulate levels of air pollution in NSW are in the local area.
This air pollution contributes to heart disease, stroke, deaths, diabetes, low birth weight for babies, restricted lung growth in children, lung cancer in non-smokers, asthma and emphysema.
The expansion will exacerbate an already dire set of circumstances with respect to air quality and health issues in the local area.
The mine assessment admits that most air quality monitoring sites in the vicinity of Glendell Mine have experienced at least one day above the national standards for PM10 particulate pollution in the past seven years and some exceeded annual average thresholds in the last two years. Camberwell and Singleton also exceeded the PM2.5 criterion last year.
But the EIS uses a low pollution year, 2014, as its base year, setting background air pollution levels at less than half of the pollution concentrations experienced in the vicinity more recently. Nevertheless, the assessment shows intensification of PM2.5 and PM10 air pollution in Camberwell and surrounding areas.
Water Loss
This project further extends mining in a heavily-mined area, exacerbating water loss.
Baseline monitoring has identified water level drawdown within the coal seams due to the cumulative impact of approved activities that surround the proposed Glendell Pit Extension. The Environmental assessment noted
“The proposed Glendell Pit Extension will further depressurise the geological strata directly intersected by the mining activities. The Project will create a zone of drawdown around the mining activity where groundwater levels will decline during the mine life. The depressurisation will also create an area of low pressure within the groundwater system centred on the Glendell Pit Extension that will encourage groundwater to flow through coal seams towards the mining area drawing groundwater from the adjacent water sources.”
The mine’s groundwater assessment shows that dramatic drawdown of the coal seam under the Bowman’s Creek alluvium propagates upward into the alluvium and causes drawdown and loss of surface water.
This adds to stress already being experienced in the area from other mines, and the groundwater assessment also shows cumulative draw down of over 2 metres in the alluvium during the proposed mining operations.
Author
Write something about yourself. No need to be fancy, just an overview.
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