Whitehaven coal Mod 4 Response to Submissions – dodgy, dodgy

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Rather than fix their noise problems, Whitehaven coal are seeking to delete sound power controls from s12(a) of the noise approval conditions for its opencut coal mine at Maules Creek. The relevant clause says;

“(The proponent shall) ensure that all equipment and noise control measures deliver sound power levels that are equal to or better than the sound power levels identified in the EA, and correspond to best practice or the application of the best available technology economically achievable;”

The community reacted strongly to this push to water down noise conditions. In all there were 116 submissions, 16 NGO, 97 public submissions and 3 government agency. All NGO and public submissions objected to the proposed sound power modification. The agency submissions made comment.

Still the company is not listening to the community. You can see its Response to Submissions (RTS) here.

This process follows the findings of the Mandatory Noise Audit ordered by the EPA. The audit found that the Train Load Out and Train Load Out Transfer Station are noisy, exceeding Environmental Assessment limits by +12DBa, +11DBa. It is very likely that the exceedences of these noise limits have triggered the company to seek changes to its approval conditions – basically because it can’t comply.

Whitehaven disagree – saying it has a strong record of compliance and it’s merely the removal of duplicate wording that they are spending our time and their money on (LOL).

“The intent of removing this wording is to reduce duplication as similar wording already exists elsewhere in Project Approval 10_0138″

Coal Preparation Plan (CPP) – with noise minimising screen

Despite it’s protests the company commissioned a new, and presumably expensive report from Global Acoustics (GA), 40 days after submissions closed. In doing so the company ignored due process by not giving the community opportunity to comment. The report by GA confirmed the companies non-compliance in relation to equipment sound power and control measures;

“Five fixed plant items exceeded relevant NMP sound power targets, including:

  • secondary sizer
  • raw coal transfer station

    Train Loadout – with noise minimising screens
  • CHPP product transfer stationary
  • train load out transfer station and conveyor drives
  • train load out”

Despite this, the GA report made no recommendations as which effective noise control measures the company could employ (as required by s12a) to meet its sound power obligations.

Whitehaven continues to ask the wrong question. i.e. How can it remove the noise controls, not how can it comply.