Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697643468215.pdf (Australia)
Submission in response to Jobs for the Future in Regional Areas prepared by Environmental Justice Australia 06 September 2019 Environmental Justice Australia ABN 74052124375 PO Box 12123 A'Beckett Street PO Melbourne VIC 8006 L3, 60 Leicester St, Carlton T (03) 8341 3100 F (03) 8341 3111 E admin@envirojustice.org.au W www.envirojustice.org.au Jobs for the Future in Regional AreasSubmission 91 About Environmental Justice Australia Environmental Justice Australia (formerly the Environment Defenders Office, Victoria) is a not-for- profit public interest legal practice.
We are independent of government and corporate funding.

Our legal team combines technical expertise and a practical understanding of the legal system to protect our environment.

We act as advisers and legal representatives to community-based environment groups, regional and state environmental organisations, and larger environmental NGOs, representing them in court when needed.
We also provide strategic and legal support to their campaigns to address climate change, protect nature and defend the rights of communities to a healthy environment.

We also pursue new and innovative solutions to fill the gaps and fix the failures in our legal system to clear a path for a more just and sustainable world.

Submitted to: Committee Secretariat By email only: regionaljobs.sen@aph.gov.au 06 September 2019 Environmental Justice Australia 2 Jobs for the Future in Regional AreasSubmission 91 1.
Introduction Environmental Justice Australia welcomes the opportunity to provide a submission to the Select Committee on Jobs for the Future in Regional Areas (the inquiry).

This submission focusses on the environmental benefits and employment opportunities of comprehensive coal ash dump rehabilitation.

Communities, such as the Latrobe Valley in Victoria and the Upper Hunter Valley and Central Coast of New South Wales, face incredibly challenging times as coal fired power stations are decommissioned.
These communities are also left with an environmental injustice, that is, the enormous environmental impacts and rehabilitation challenges associated with toxic coal ash dumps.

To date, Australia generally has not comprehensively considered job opportunities in environmental rehabilitation to mitigate the toxic impacts of coal-fired power generation.
Fortunately, other jurisdictions have commenced this planning, including assessing the employment benefits for comprehensive rehabilitation and remediation of the environment where power stations and coal ash dumps are located.
Research undertaken by the Northern Plains Resource Council (NPRC) of Montana, United States, in collaboration with the International Brotherhood of Electrical Workers Local Union 1638, shows that there are huge benefits to both the environment and employment in regions where coal ash dumps exist.

Recommendations: 1.

Coal ash dumps must be comprehensively rehabilitated to benefit both the environmental and create job opportunities.

2.

Ash dumps must be excavated as part of rehabilitation.
This provides opportunities for the coal ash reuse market.

3.

Ash dump rehabilitation plans must be prepared well in advance of power stations being decommissioned.

2.

Thorough environmental remediation is a boon for regional employment.

Coal combustion produces millions of tonnes of toxic ash and post-combustion by-products.

This toxic waste is usually dumped very close to power stations and the communities who live near them.
Australian power stations produce an estimated 10–12 million tonnes of coal ash annually,1 and 1 Gupta, T., Miller, A., and Mohan, Y, Current Perspective, Challenges and Opportunities for Fly Ash Utilisation and Pond Reclamation in Australian Scenario, Submission made to the Senate Standing Committee on Environment and Communications inquiry into Rehabilitation of Mining and Resources Projects as it related to Commonwealth Responsibilities, Submission 74.2, 28 June 2018; Winn, Paul, Lynch, Joanna, and Woods, Georgina, Out of the Ashes: Water Pollution and Lake Macquarie’s aging coal-fired power stations, Hunter Community Environment Centre, 2019, p. 63.
<https://drive.google.com/file/d/1P3tIYeUe2ic7wGpQYszqLueW0DVxc-4s/view>.

Environmental Justice Australia 3 Jobs for the Future in Regional AreasSubmission 91 Australia has well over 400 million tonnes of ash currently stored in dump sites throughout the country.2 Our report, Unearthing Australia’s Toxic Coal Ash Legacy, provides detail on the toxic threat of coal ash dumps, and provides guidance on what comprehensive ash dump remediation includes, and is attached to this submission.
Despite the large volume and hazardous nature of coal ash, it is disposed of without adequate safeguards to protect communities and environmental health.

The standard treatment of this toxic waste in Australia is to mix it with water and then pipe it to nearby ‘ponds’ or ‘dams’ that haven’t been built to protect groundwater and surface water, and are not well managed to prevent ash blowing onto nearby communities.
Groundwater is contaminated underneath many Australian ash dumps, yet environmental regulators do not require that operators clean up this contamination at the source.

Because many coal-fired power stations sit near recreational lakes and reservoirs – such as near the Latrobe River in Victoria, the Calliope River and surrounding estuaries in Gladstone, Queensland, and Lake Macquarie on the New South Wales Central Coast – the potential for harm to aquatic life and human health is substantial.
Water pollution from coal ash can raise cancer and other health risks, make fish unsafe to eat, and can cause long-term damage to aquatic ecosystems.

The regulation of coal ash dumps throughout Australia differs from state to state, is inconsistent between dump sites, and does not adhere to best practice construction, management or rehabilitation standards as practised in other parts of the world.
For example:     conditions for ash dump management differ from state-to-state, and in each state, from power station to power station; there is no best-practice management standard for ash dumps in any State, or at a national level; there is no requirement that power station operators prepare ash dump rehabilitation and post-closure plans well before the power station closes; the only State that requires financial assurances be held for ash dumps is Victoria.
In order to protect community and environmental health well into the future, coal ash dumps need to be rehabilitated to very strict standards.
The Northern Plains Resource Council (NPRC) of Montana, United States, in collaboration with the International Brotherhood of Electrical Workers Local Union 1638 (the Colstrip power station’s union), has undertaken significant research into the employment opportunities presented by comprehensive rehabilitation of the Colstrip power station coal ash dump.3 2 http://www.adaa.asn.au/resource-utilisation/ccp-utilisation.
3 See: Northern Resource Plains Council and International Brotherhood of Electrical Workers Local Union 1638, Doing it Right: Colstrip’s Bright Future with Cleanup, 2018, available at: https://northernplains.org/wp- Environmental Justice Australia 4 Jobs for the Future in Regional AreasSubmission 91 This research is attached to our submission.
This rehabilitation includes excavating coal ash from its current location to thoroughly remediate contamination and prevent ongoing groundwater and surface water contamination, and building water treatment plants to clean up contaminated water.

These processes are much more comprehensive, job intensive, and have much greater environmental benefits than the current approaches taken at places like Vales Point and Eraring power stations who undertake “cap-in-place”, that is, covering the coal ash with fill.
This is especially problematic for ash dumps such as at Vales Point and Eraring that are unlined, as it leaves contaminated soil and water in place, ensuring a likelihood that contamination of waterways and land will continue well into the future putting the local environment and community health at risk.
As an example, there is very little information about the solar farm Sunset Power International intends to build on a section of the Vales Point power stations ash dump that it deems “rehabilitated”.4 There is little information about how Sunset intends to mitigate long-term environmental impacts from the site, which is a “cap-in-place” approach to ash dump rehabilitation.
The environment assessment for the solar farm contains very little information about the rehabilitation of the site before the solar panels are installed, and the long-term mitigation strategies for toxic waste leachate into Lake Macquarie and groundwater tables is not addressed.
If the coal ash was excavated first rather than covered, jobs would be created in the excavation, coal ash that adhered toxics levels for reuse under the NSW Coal Ash Order 2014 could be provided to the coal ash reuse market, and the site could be thoroughly rehabilitated before the solar panels were installed.

3.
3.

Thorough remediation of coal ash dump sites provides opportunities for the coal ash reuse market The jobs and environmental benefits of excavating and removing coal ash from current sites provides further potential gains in coal ash reuse, provided the coal ash waste is not so contaminated that it is dangerous for reuse.5 This has the benefit of providing other industries, such as the concrete industry, with material that will produce less carbon-intensive manufacturing processes.
The work undertaken by the Hunter Community Environment Center on the reuse potential of coal ash on the NSW Central Coast highlights the environmental and job gains in coal ash reuse.6 content/uploads/2018/07/DoingItRight FullStudy FNL WEB.pdf; Northern Resource Plains Council, Doing it Right II: Job creation through Colstrip cleanup, April 2019, available at: https://northernplains.org/wp- content/uploads/2019/04/DIRTII FINAL WEB.pdf/.
4 Thomas Muddle, ‘Vale Point Solar Project: Environmental Impact Statement’ (Jacobs Group, 31 January 2018), xi.

See: https://www.planningportal.nsw.gov.au/major-projects/project/5276/.

5 See: Lipski, B., Unearthing Australia’s Toxic coal Ash Legacy How the regulation of toxic coal ash waste is failing Australian communities, Environmental Justice Australia, 2019, pp.

38-39.

Available at: https://www.envirojustice.org.au/wp-content/uploads/2019/06/EJA CoalAshReport.final .pdf.
6 See: Winn, P., Woods, G., Lunch, J., Out of the Ashes: Water pollution and Lake Macquarie’s aging coal-fired power stations, Hunter Community Environment Centre, 2009, pp.

64-69.

Available at: https://drive.google.com/file/d/1-3qbiaitKC1rI7vFdkAQ8JQFsx22ybIL/view.

Environmental Justice Australia 5 Jobs for the Future in Regional AreasSubmission 91 4.

Comprehensive ash dump rehabilitation plans must be prepared well before power station decommissioning.
Thorough ash dump rehabilitation and on-going post-closure management has a three-fold benefit: job creation, environmental decontamination, and the potential use of coal ash as a resource for other industries.

In order to facilitate job opportunity and economic development in coal ash dump remediation, State Governments need to require that ash dump rehabilitation and closure plans are prepared well in advance of power station decommissions.
Comprehensive ash dump planning before power stations are decommissioned provides impacted communities and power station employees with certainty regarding job prospects and environmental benefits.
This includes identifying where local training and education providers can support transitioning workers to acquire the skills needed to work in ash dump remediation, as well as prepare new workers entering the workforce with necessary skills; future land use planning potential on thoroughly remediated sights; “flow-on” employment benefits to other businesses and services in regions; and regional pride in workers being involved in the comprehensive rehabilitation of their home areas.
Environmental Justice Australia 6 Jobs for the Future in Regional AreasSubmission 91