SUBMISSION GUIDE

Help shape new rules for coal-fired power stations in New South Wales

For the first time in five years, all four coal-fired power stations in New South Wales are under review.

The NSW EPA is currently reviewing the environment protection licences for all four power stations.

Until 5pm Monday, 27 November, you can have your say and help make sure the EPA requires these power-stations to adopt best available pollution technologies to better protect community health, release more information publicly to improve transparency and accountability, and to listen to the people most impacted by toxic coal pollution.

Check out our submission guide and make an impactful submission in 15 minutes.

How to make an impactful submission

The NSW EPA is taking submissions from the public until 5pm Monday, 27 November.

You can use our submission guide to draft your submission.

WHY THIS MATTERS

Everyone deserves clean air and water.

Vales Point, Eraring, Bayswater and Mount Piper coal-fired power stations are pumping out some of the most toxic chemicals for our health – leading to serious health problems like cancer, respiratory illnesses and severe asthma.

These licence reviews only happen every five years. They are a critical opportunity to win stronger pollution limits and better transparency and accountability in reporting by demonstrating community support for these measures.

Further information

The NSW EPA is currently undertaking a review of each of the environment protection licences that apply to NSW’s four operating coal fired power stations: Vales Point, Eraring, Bayswater and Mount Piper.

As part of reviewing each coal fired power station licence, the EPA will be looking at whether the conditions of the licences are fit for purpose or need improvement. We now have an opportunity to tell the EPA how the licence conditions for each power station must be improved.

The review is scheduled to be completed by the end of 2023. It is a ‘statutory review’, which means by law, the EPA is required to undertake this kind of review every 5 years.

The next opportunity for the community to have input into a substantial licence review like this will be in 2028 – so it’s crucial to have your say now.

An ‘environment protection licence’ sets out the conditions that Delta Electricity, AGL, EnergyAustralia and Origin must adhere to when operating their coal fired power stations.

Each power station licence sets out conditions for its operations, including:

  • limits on pollution
  • frequency of monitoring and reporting of pollution
  • reports and information to be provided to the EPA and the public
  • other conditions aimed at improving performance.

The current limits for air pollutants are too high. The current licence limits for toxic pollutants known to harm health such as nitrogen oxides, sulphur dioxide, particulates and mercury remain too high and are much higher than limits placed on coal fired power stations in many other countries where technology is used to significantly reduce these pollutants. The EPA must lower air pollution limits.

Operators are not required to publish all information and data. Currently, despite certain licence conditions requiring operators to monitor and report on pollution levels or undertake detailed reporting on site operations, this information is not readily available to the public. This creates barriers to accessing vital information that could inform communities about how operators are meeting their obligations to minimise pollution and impacts on the environment. The EPA must require operators to publish more information and data.

Community engagement by operators is not the status quo, but should be. At the moment, only Eraring and Mount Piper power stations have a formal Community Consultative Committee or ‘CCC’. Vales Point and Bayswater don’t have one – but we think they should and that this should be a requirement of each licence. CCCs are important for ensuring that big business, like Origin, EnergyAustralia, AGL and Delta Electricity, engage with communities and stakeholder groups on the environmental, social and economic impacts of their operations. They allow for community concerns to be raised directly with operators, detailed minutes of meetings to be published for public perusal and are an important tool for engagement, accountability and transparency. The EPA must require a CCC for Vales Point and Bayswater.

Climate plans should be added to the licences. Despite the EPA planning to regulate CO2 emissions like any other pollutant, there are no licence conditions for limiting climate pollution yet. These four power stations are among the biggest CO2 emitters in NSW, so this can’t wait another five years. Conditions should include an end-date for CO2 emissions, a maximum limit and a pathway to transition from polluting operations to clean energy production while maintaining energy security.

Everyone deserves clean air and water. We must fight to protect it. Communities also have a right to know about the pollution they’re exposed to.

These licence reviews only happen every five years. They are a critical opportunity to win stronger pollution limits and better transparency and accountability in reporting by demonstrating community support for these measures.

We know that coal fired power stations are the biggest source of controllable air pollution in NSW and that their toxic emissions have serious health impacts communities. We also know that getting information from operators on pollution levels and other operational matters is crucial to improve transparency and accountability. Communities deserve to know about what polluters are doing in their backyard.

The licence review consultation process is an opportunity for you to have your say on the unacceptable levels of pollution currently permitted by licences and to provide your feedback on how they can be strengthened to protect public health, improve access to information and public participation and deliver on NSW’s climate change commitments.

It is important for decision makers to get this feedback before they review and finalise the licences.

Firstly, start with the basics and think about:

  • why you care about pollution from coal fired power stations
  • how air, water, and land pollution impacts you
  • what evidence you want to use to back up your statements
  • what recommendations would you make to the EPA.

We’ve outlined a number key things you might want to address in your submission in more detail on page 3 of the submission guide. These include:

  1. Air pollution limits in the licences don’t protect human health and must be lowered
  2. Licence conditions should better address the significant risks that unlined coal ash dumps and hot water discharges have for water and ecosystem contamination and impacts
  3. Licence conditions should require operators to publish more information
  4. Licence conditions should require better community engagement
  5. Climate change mitigation and adaption plans (CCMAPs) should be added to the licences.

There are two ways that you can lodge a submission with the EPA.

You can email a written submission to the EPA at: [email protected]. We encourage you to make a written submission if you can because that way, you can tailor it to suit your concerns.

Alternatively, you can lodge a submission by completing the ‘Have your say’ section on the EPA’s website here: https://yoursay.epa.nsw.gov.au/review-of-power-station-licences. The ‘Have your say’ survey will ask you a series of questions. You do not need to engage with every question and can click ‘next’ if you do not want make a comment on a specific aspect of the licence review.

Importantly, you must make your submission by 5.00pm Monday 27 November 2023.