Submission from: Michael Kane on behalf of Clean Air Queensland 18thNovember, 2014 To the chairperson, with reference to the following: Select Committee into Certain Aspects of Queensland Government Administration related to Commonwealth Government Affairs. The Australian Clean Air Standard is being used by the Queensland State Government as a licence to pollute. The Queensland coal industry, the Queensland Resources Council and the Queensland State Government are cooperating to apply a dangerously lax regulatory frame work for the massive expansion of the coal industry which potentially has widespread and severe health implications for many heavily populated centres, towns and rural communities in Queensland. In this submission Clean Air Queensland will focus on the misuse of the Australian Clean Air Standard http://www.environment.gov.au/topics/environment-protection/air- quality/air-quality-standards which under the current and previous government in Queensland could potentially cause up to 800 additional deaths and 7400 extra hospitalisations from government sanctioned pollution regulations in Queensland. Clean Air Queensland believes the current regulatory framework for Queensland pollution standards, as they are applied to the mining and other industries, is a contravention of the International International Convention on Economic, Social and Cultural Rights. The failure to protect people from industrial pollution like coal dust is in breach of this convention and the misuse of the Australian Clean Air standards is tantamount to wilful and culpable negligence by the Queensland government and the coal industry. Compounding the problem in Queensland is the recent relaxation of political and electoral funding of political parties in Queensland by corporations, particularly mining and resource companies and the demonstrably close relationship of New Hope Coal and associated companies who have current applications for extremely polluting projects pending before the Queensland government. Clean Air Queensland Clean Air Queensland is an organisation concerned with the health impacts of particulate pollution on rural, residential and urban communities. Our particular focus is the impacts of the coal industry in Queensland. Currently health impacts from particulate pollution sources like coal dust are largely unregulated and governed by unenforced or unenforceable guidelines. We are concerned that the exponential growth of the coal industry in Queensland which is increasingly occurring close to established rural, urban and metropolitan communities. We believe that the present Australian Clean Air guidelines guidelines do not adequately address the serious health impacts posed to communities who are being increasingly exposed to industrial pollution as the coal industry moves into populated regions in Queensland. National Pollution Inventory – Queensland coal tops the chart. The nation’s air quality has declined dramatically in the past decade and coal mining has been identified as the biggest source of harmful respiratory particles in our air. Coal mining was identified as the leading source of particle pollution contributing 380,000 tonnes of the total 830,000 tonnes of tiny dust particles that can be breathed in, known as PM 10, emitted nationally in 2012-13. In 2014 The Australian Government National Pollutant Inventory report found Queensland is the most polluted state in terms of the levels of particulate matter with eight of the nation’s top ten particle emitting coal mines located in the state, the report should sound an urgent warning bell on the need for greater controls on air pollution. Particle pollution contributes to a range of cardiovascular and respiratory illnesses yet we have no national uniform legislation to protect the very air we breathe. Even getting coal trains covered to reduce particle pollution in Queensland has proved too difficult for our legislators and the dust from stockpiles of uncovered coal waiting for export blows freely over populated areas. For perspective, the report found that motor vehicles collectively contributed 12,000 tonnes of these particulates every year, a figure dwarfed by the emissions from the coal industry. Health Impacts Health impacts from particulate pollution like coal dust are now recognised to pose a severe health threat to the Australian community and particulate pollution is an acknowledged leading cause of death and disease in Australia. The Australian Medical Association, the World Health Organisation and leading academics in the fields of air pollution and health impacts of particulate pollution are increasingly warning community and governments about the deadly consequences of poor regulation. It is Clean Air Queensland’s firm belief that the present PM10 24-hour standard of 50ug/m3 is being used as a licence to pollute by the coal industry and the Queensland government rather than the standard acting as a regulatory tool to place downward pressure on particulate pollution. Clean Air Queensland has correspondence from Michael Roche (Queensland Minerals Council), Lawrence Springborg (Minister for Health) and Scott Emerson (Minister for Transport and Main Roads) where the relevant government minister and coal industry representatives cite the level of pollution from coal stockpiles, mines and uncovered trains as within the accepted limits of the Australian clean air standard. These assertions that coal dust pollution in heavily inhabited area’s is safe and not of concern ignores the fact that coal dust pollution from the operation of coal stockpiles, coal transport and coal mining is intermittent and that the health effects are cumulative. There is no safe threshold for exposure to particulate pollution like PM10, PM2.5 and PM1, Clean Air Queensland believes that the standard should also incorporate enforceable provisions for mitigating health impacts on people living close to coal mines and coal industry infrastructure pollution point sources. (See Appendix A.2 for detailed assessments of impacts on health of communities living near coal dust point sources such as Acland, Queensland. Authored by John Sheridan, Doctors for the Environment, Australia. 21/8/12) It is clear that the current standards of permissible particulate pollution allowed near population centres is already causing significant health and cost pressures on the community. For instance if pollution in our largest population centres was allowed to increase to the daily average or even close to the present Australian clean air guidelines of 50 micrograms of PM10 pollution per cubic meter averaged over 24hours then we could expect a substantial increase in premature deaths, increased disease and hospitalisations. A recent study in the Australian & New Zealand Journal of Public Health found that if average daily pollution levels were allowed to increase to just below the current Australian National Clean Air standards then we could expect an extra 6000 deaths and 20 000 emergency hospital admissions annually in Australia from preventable particulate pollution. Clearly the present Australian pollution standards are inadequate to prevent serious impacts on community health. I have attached paper by Professor Adrian Barnett from the Queensland University of Technology which was published in 2014 in the Australian & New Zealand Journal of Public Health. The tables below are based on data from Dr Barnett’s study. Table 1: Estimated number of additional annual deaths (all ages) by increasing current pollution levels to just below the national standards. Cities: Brisbane Melbourne Sydney Additional Deaths 800 2600 2600 Additional Hospitalisations 7400 5800 7500 (Graphs extracted from Australian & New Zealand Journal of Public Health, 1st of October 2014. Dr Adrian Barnett. Study printed in full at the end of this document) Table 2: Estimated number of additional annual emergency hospital admissions by increasing current pollution levels to just below the national standards. Estimates by cities, diseases, age groups and pollutants. Estimates rounded to the nearest 100. Cities: Brisbane Melbourne Sydney 7400 5800 7500 Diseases: Arrhythmia Cardiac Ischemic Respiratory failure heart disease 300 3500 1900 15100 Age groups (years): 0 1–4 5–14 15–64 65+ 4500 9000 500 1600 5200 Pollutants: CO NO2 PM10 PM2.5 SO2 4200 2900 1100 1500 11,100 CO = carbon monoxide; NO2 = nitrogen dioxide; PM10 = particulate matter with a diameter less than 10 micrometres; PM2.5 = particulate matter with a diameter less than 2.5 micrometres; SO2 = sulphur dioxide (Graphs extracted from Australian & New Zealand Journal of Public Health, 1st of October 2014. Dr Adrian Barnett. Study printed in full at the end of this document) Summary There is a substantial body of science-based evidence that using the Australian Clean Air standard to regulate health impacts of particulate pollution like coal dust is at best ineffective and at worst a deliberate misuse of the standard which is potentially causing the deaths and hospitalisations of thousands of Queenslanders. It is of deep concern to the membership groups of Clean Air Queensland that the current Federal government is considering handing over substantial legislative powers to assess mining development to the Queensland government. The Queensland government is wilfully ignoring the human and environmental impacts that the coal industry is causing in Queensland and is making every effort to further weaken an already ineffective and potentially corrupting approval’s process and regulatory framework.