Wambo export condition - EDO NSW Hunter Environment Lobby

Response to IPC condition linking coal export to Paris Agreement

On behalf of the Hunter Environment Lobby, EDO NSW has provided a full response to the Independent Planning Commission on its proposed condition linking coal export with the Paris Agreement.

13 August 2019

The IPC had called for public comment on a condition it is considering in relation to the proposed United Wambo open-cut coal mine at Singleton in the Hunter Valley. The condition would require the mine’s proponent to prepare an export management plan limiting the sale of coal from the mine to countries with policies to reduce greenhouse gas emissions in line with the Paris Agreement.

In summary, the EDO NSW submission on behalf of the Hunter Environment Lobby: 

- Confirms opposition to the Project in toto and submits that consent should be refused because of the Project’s poor environmental performance and outcomes in both absolute and relative terms, including its failure to overcome the “wrong time” basis for refusal as set out in the Rocky Hill decision;
- Submits that, if the IPC determines that consent to the Project should be granted:
i. The proposed condition is inappropriate because it is based on the fundamentally flawed assumption that export of the Project’s coal to Paris Agreement signatory countries will comprise “all practicable measures” to minimise Scope 3 greenhouse (GHG) emissions, and therefore it will fail to achieve its stated purpose;
and
ii. The only appropriate condition in relation to the Project’s GHG emissions would be to require the Project’s total GHG emissions to be permanently offset so that the Project is carbon neutral.