Letter to EPA Victoria

Background Information


In November 2017 the Environment Protection Authority Victoria (EPAV) commenced a review of the licences of Victoria's coal-fired power stations: Yallourn (owned by Energy Australia), Loy Yang A (owned by AGL) and Loy Yang B (now owned by Chow Tai Fook Enterprises Limited)

The EPA reviews the licences of the power stations periodically (at their discretion) taking into account updates in science, environmental conditions and community standards to prevent adverse effects of the power stations on the environment.

This particular review was unique in that this time the EPA called for the community to give input into the review process and outcomes. There were three parts to this community engagement: 

Part 1: invitation for written submissions from community and environment groups

Part 2: a survey asking three questions: 

  1. Do you have any comments on this list of pollutants, including any additional pollutants that should require monitoring?
  2. How do you think monitoring information should be made available to the public?
  3. What other licensing issues do you think EPA should consider, and ask the power stations to respond to as part of this review process?

This survey received 477 responses from community and environment groups 

Part 3: a "section 20B conference" (referring to section 20B of the 1970 Environment Protection Act) in August 2018: this involved community groups attending a day length seminar to discuss their desired outcomes from the power station licence review. Power station representatives from the three respective power stations were present to talk with the community groups. This conference was facilitated by the EPA. Community groups were told at the conference that they would be made aware of the licence review outcomes in approximately three months. We are still awaiting results of this today...

Enter your details below to ask EPA Victoria to set pollution limits for Latrobe Valley power stations in line with international standards to protect health




Letter Text


Dear EPA Victoria,

Levels of air pollution recorded in the Latrobe Valley have been associated with increased risk of death in international studies [1-4] and increased risk of acute asthma, preterm birth and low birth weight in Australian studies [1,5,6,7]. We are concerned that air pollution in the Valley is placing residents’ health at risk.

The vast majority of toxic pollutants in the Latrobe Valley airshed come from coal-fired electricity generation [8]. Latrobe Valley power stations are emitting toxic pollutants at levels far greater than those considered acceptable overseas [9]. The Board of the Hazelwood Mine Fire Inquiry recommended in 2016 that “Latrobe Valley mine operators should lead the way in implementing the best available technology to reduce emissions”[10].

Accordingly we request that you require Latrobe Valley power stations to limit their annual toxic emissions to levels no greater than those required of coal-fired power stations of similar size in the European Union (for both brown and black coal) - specifically, 175 mg/Nm3 of NOX, 100 mg/Nm3 of carbon monoxide, 130 mg/Nm3 of sulfur dioxide, 5 mg/Nm3 of hydrochloric acid, 3 mg/Nm3 of hydrofluoric acid, 8 mg/Nm3 of particulate matter and 7 µg/Nm3 of mercury [10].

We look forward to hearing your response.

Sincerely,

[signatories]

References:

1. Environment Protection Authority Victoria (2019). Air monitoring report 2018 - compliance with the National Environment Protection (Ambient Air Quality) Measure. Retrieved from https://www.epa.vic.gov.au/-/media/epa/files/publications/1749.pdf

2. Pinault L, Tjepkema M, Crous DL, Weichenthal S, van Donkelaar A, Martin RV, Brauer M, Chen H & Burnett RT (2016). ‘Risk estimates of mortality attributed to low concentrations of ambient fine particulate matter in the Canadian community health survey cohort’, Environmental Health 15:18

3. Shi L, Zanobetti A, Kloog I, Coull BA, Koutrakis P, Melly SJ & Schwartz JD (2016). ‘Low-concentration PM2.5 and mortality: estimating acute and chronic effects in a population-based study’ Environmental Health Perspectives 124(1) pp46-52

4. Di Q, Wang Y, Zanobetti A, Wang Y, Koutrakis P, Choirat C, Dominici F & Schwartz JD (2017). ‘Air pollution and mortality in the Medicare population’, New England Journal of Medicine 376 pp2513-22

5. Periera G, Cook A, De Vos AJBM & Holman CDJ (2010). ‘A case-crossover analysis of traffic-related air pollution and emergency department presentations for asthma in Perth, Western Australia’, Medical Journal of Australia 193(9) pp511-514

6. Jalaludin B, Khalaj B, Sheppeard V & Morgan G (2007). ‘Air pollution and ED visits for asthma in Australian children: a case-crossover analysis’, Int Arch Occup Environ health 81 pp967-974

7. Chen G, Guo Y, Abramson MJ, Williams G & Li S (2017). ‘Exposure to low concentrations of air pollutants and adverse birth outcomes in Brisbane, Australia, 2003-2013’, Science of the Total Environment 622-623 pp721-726

8. Teague B, Catford J & Roper A (2016). Hazelwood Mine Fire Inquiry report 2015/2016 volume III - health improvement p71. Retrieved from http://hazelwoodinquiry.vic.gov.au/wp-content/uploads/2016/02/Hazelwood-Mine-Fire -Inquiry-2015-2016-Report-Volume-III-Health-Improvement.pdf

9. Environmental Justice Australia (2017). Toxic & terminal: how the regulation of coal-fired power stations fails Australian communities p24. Retrieved from https://www.envirojustice.org.au/sites/default/files/files/EJA_CoalHealth_final.pdf

10. Teague B, Catford J & Roper A (2016). Hazelwood Mine Fire Inquiry report 2015/2016 volume III - health improvement p76. Retrieved from http://hazelwoodinquiry.vic.gov.au/wp-content/uploads/2016/02/Hazelwood-Mine-Fire -Inquiry-2015-2016-Report-Volume-III-Health-Improvement.pdf

11. Lecomte T, de la Fuente JFF, Neuwahl F, Canova M, Pinasseau A, Jankov I, Brinkmann T, Roudler S & Delgado Sancho L (2017). Best Available Techniques (BAT) reference document for large combustion plants pp. 757-63. Retrieved from http://publications.jrc.ec.europa.eu/repository/bitstream/JRC107769/jrc107769_lcp_br ef2017(1).pdf

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