EPA Victoria, we need pollution controls to protect health

Healthcare workers call on EPA Victoria to mandate best practice pollution controls for coal fired power stations to protect health

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Letter Text (signatures updated daily)


Dear EPA Victoria,

Levels of air pollution recorded in the Latrobe Valley have been associated with increased risk of death, acute asthma, preterm birth and low birthweight [1-7]. The majority of toxic pollution in the airshed comes from coal-fired power generation [8]. Recent modelling has estimated that every year pollution from the power stations causes 37 premature deaths among adults, 33 low weight births and 580 person-days of asthma symptoms among children in Gippsland [9]. The same modelling estimated that out of these, 17 deaths among adults, 11 low weight births and 217 person-days of asthma symptoms among children occur in the Latrobe Valley [9].

Latrobe Valley power stations are currently permitted to emit pollution at levels far greater than those permitted overseas. For example each Latrobe Valley power station is currently permitted to emit well over 100 milligrams of particulate matter per cubic metre of air, whereas by 2021 each European coal-fired power station of similar size will only be permitted to emit up to 12 milligrams of particulate matter per cubic metre of air [10, 11]. In 2016 The Board of the Hazelwood Mine Fire Inquiry recommended that “Latrobe Valley mine operators should lead the way in implementing the best available technology to reduce emissions”[12] but this has not been done because the power stations have not been required to reduce their pollution.

We therefore request that you now require Latrobe Valley power stations to:

(a) limit their toxic pollution emissions to the same levels, or less, than will be required by 2021 for coal-fired power stations of similar size in the European Union - 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 [11] - and,

(b) install best practice pollution controls to reduce toxic emissions including fabric bag filters, flue-gas desulfurisation, selective catalytic reduction and activated carbon injection technology

We consider this crucial for protecting Latrobe Valley residents and other Gippslanders from further harm.

We look forward to your response.

Sincerely,

Miss Ebonie Andrew
Mrs Tracey Anton
Ms Carol Brooks
Mr Brendan Chessum
Mr Connor Fisher
Mr Michael Gibbons
Mr Brad Gibson
Mr Patrick Hamilton
Mrs Veronique Hamilton
Ms Emma Handley
Ms Belinda Haydon
Ms Roxane Ingleton
Dr Harry Jennens
Ms Margaret Jones
Mrs Libby Matchett
Ms Kate Meadows
Mr Guy Meall
Ms Angela Merriam
Miss Geraldine McClure
Dr Coralie Millet
Ms Emma Morris
Ms J Murphy
Mr Phillip Nadvesnik
Mrs Audrey Naismith
Mr Ian Norwood
Ms Michelle Swiety
Mrs Suzanne Tennant
Ms Rosalie Thomas
Miss Ainsley Verhagen
Ms Heike Weber

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. Farrow A, Anhäuser A & Myllyvirta L (2020). Lethal power: how burning coal is killing people in Australia, unpublished dataset viewable at www.healthyfutures.net.au/gippslandpollution, broader report including methodology available at https://www.greenpeace.org.au/wp/wp-content/uploads/2020/08/GPAP-Lethal-Power-full-report.pdf

10. Environmental Justice Australia (2017). Toxic & terminal: how the regulation of coal-fired power stations fails Australian communities p24 & Appendix 1. Retrieved from https://www.envirojustice.org.au/sites/default/files/files/EJA_CoalHealth_final.pdf

11. Commission Implementing Decision (EU) 2017/1442 of 31 July 2017 establishing best available techniques (BAT) conclusions, under Directive 2010/75/EU of the European Parliament and of the Council, for large combustion plants. (2017). Official Journal of the European Union, L212/1. Retrieved from https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017D1442&from=EN

12. 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

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    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...