HRL has re-submitted its application for environmental approval for its proposed power station, which would use new gasification technology to reduce greenhouse gas emissions from burning coal.

There is an Age report here.

Friends of the Earth calls on the Premier to reject the proposal, and rule out any new coal‐fired power stations in Victoria.

We have supported the Climate Change Bill which only recently passed through the Upper House. It sets a target to reduce the State’s greenhouse gas emissions by 20% by 2020 and aims to reduce emissions from coal energy. There is no way the state government will be able to meet this target if we keep building coal‐fired power stations in Victoria.

This is a perfect opportunity for the Premier to build on recent announcements on climate policy and confirm Victoria's leadership role in tackling climate change.

No new coal development in Victoria

HRL- Dual Gas have re submitted their Works Approval Application for the proposed 600 MW coal fired power power station which they want to build near Morwell in the Latrobe Valley. The EPA must now consider whether to approve the proposal. If built, this plant will increase Victoria’s greenhouse gas emissions by somewhere between 3 million and 4.2 million tonnes each year.

It will also mean that the government has missed a significant opportunity to ensure that Victoria finally draws a line under decades of investment in coal and starts to truly drive our energy sector towards low carbon energy options.

The works approval is open for public comment until October 6 2010.

We urge you to write a submission expressing your opposition to this development.

Please also write to the Premier, asking him to intervene in the issue by ruling out the HRL proposal.

TAKING ACTION

There are two simple actions you can take which will have a big impact – see the draft submission and letter to the Premier below.

This action is amplified if you can forward it on to your friends and networks.

Thanks for your efforts on this issue!

Further information on our climate campaign is available here: http://www.melbourne.foe.org.au/

regards
Cam Walker
Friends of the Earth
[email protected]

1/ Submission to EPA.
Please cut and paste and modify/ expand the letter below, add your contact details and email to: [email protected]

Please send us a copy so we know how many have gone in: [email protected]

Further information on the application and process can be found here: http://www.epa.vic.gov.au/bus/comments/dual-gas.asp

There is an EPA discussion board where you can post your comments:
http://epaapprovals.com.au/hrl

2/ Write to the Premier, urging him to intervene and rule out the HRL – Dual Gas proposal (and any further new coal power stations in Victoria).

A suggested letter is provided below – the more you personalise it, the greater the impact.

Please address your letter to:

Hon John Brumby
Premier of Victoria

Dear Mr Brumby,

I am writing to you to express my deep concern about the coal-fired power station that has been  proposed by HRL Dual Gas.

Your government has recently taken the step of committing to a 20% reduction in greenhouse emissions by the end of this decade. This is a good first step in moving to a low carbon future. The current proposal to build this plant will create millions of tonnes of new greenhouse pollution each year. It is both inconsistent with the governments commitment to reduce emissions and will also make it far harder, if not impossible, to actually reach the 20% target.

I am also writing to the EPA to call on them to reject this proposal for a new coal-fired power station. 

The time for new coal developments is over. We have the technology to shift to renewable energy now. This will create far more jobs than currently exist in the coal industry and this form of energy production will use much less water. Your government has taken a good step in setting our state towards a low carbon economy through the recent White Paper and Climate Change Bill. Please act now to rule out this polluting, un-necessary and un-popular project.

Yours sincerely,

Please add YOUR NAME/ CONTACT DETAILS

Please email to:
[email protected]

Please send us a copy: [email protected]

--
Submission to the EPA

Dual Gas Demonstration Project
EPA Works Approval Application

I write this submission to the EPA process regarding the HRL-Dual Gas proposal.

I strongly oppose this project and urge the EPA to refuse the application from HRL – Dual Gas.

I believe this project is at odds with the stated intent of the Victorian government as outlined in a number of recent documents, including the Victorian Climate Change White Paper.

In the document 'Victoria's Energy Future' produced by the Victorian government earlier this year, the Premier John Brumby said that the state needs to take action to “move Victoria away from its historic reliance on coal, oil and gas to generate energy” (P1). I fully support this intention and believe it is clear that a major investment in gas/ coal power plant will do exactly the opposite, by further locking Victoria into our existing reliance on these two non renewable energy sources.

To be approved by the EPA, the project must have an average greenhouse gas emission intensity below 0.8 tonnes CO2-e/MWh over the life of the project. Clearly previous proposals by HRL – Dual Gas did not meet this criteria because the most recent application was withdrawn after the announcement of the government's White Paper.

It is clear that the technology behind the project has not changed in the brief space of time since the last application was withdrawn, and that what the company intends to do is simply reduce the amount of syngas which is generated from brown coal that it burns, while increasing the use of natural gas. Even if the EPA can be somehow convinced that this makes the project acceptable, it raises the question of whether HRL would increase the natural gas – syngas/ coal balance later in the life of the project once it has been approved and is operational. HRL makes it clear that the actual mix of energy used in day-to-day operations will vary according to a range of factors. Emissions can be expected to vary as a result.

My understanding of the assessment process is that the EPA will consider the greenhouse intensity of the HRL plant against other brown coal energy production. This would have made sense up until the 1990s. Now, HRL is competing against renewable energy, not just traditional brown coal, and so must be judged against the emissions intensity of these technologies.

The state government has recently committed to achieving a 20% reduction in greenhouse gas emissions against 2000 levels by the end of this decade. The government has not yet identified all the sources of these emissions reductions. To approve a further 600MW of greenhouse intense energy will make it very unlikely, if not impossible, for Victoria to meet this target.

I note that because of the modular nature of the project there are relatively very few jobs that will be created in the construction process (estimated to be 350 jobs through this phase). The proposal from Dual Gas (p8) says that “the major components … will be manufactured off-site and transported to the site for assembling and erection”.

The project will only create 40 ongoing jobs, very little when compared with the number of jobs that would be created from a similar sized renewable energy development.

While I note that the DGDP technology which is proposed for this plant is less water intense than existing brown coal fired power stations in the Latrobe Valley, the impacts of this new plant will still be substantial. It will place a substantial drain on very limited water resources in the Latrobe Valley region and require around 2GL of water a year. This water will come from the mountains of Gippsland, via the Blue Rock Dam and be of very high quality. It must be remembered that the coal energy sector in Victoria already uses more than 20GL of water a year. The proposal from the proponent notes that there “may result in a small reduction in the flows currently available to the environment” (p11). As we are all keenly aware, the Latrobe River and Gippsland Lakes are already very stressed and in a deteriorating condition. It would be extremely unwise to allow further allocations of high quality water for energy production. In contrast the water consumption of renewable energy sources is negligible compared with water guzzling coal production.

With recent policy announcements, Victoria is on the verge of starting a significant shift in how it produces its energy. Greenhouse intensive operations like the proposed HRL plant are still far more damaging per MWH of production than renewable energy sources and will further lock Victoria into fossil fuel energy sources rather than facilitating a true transition to a low carbon future.

For these reasons I urge you to refuse this application from Dual Gas. Please consider this letter a formal objection to the proposal.

Yours sincerely

Name
Address