Strategic planning for coal mining is largely left to the free market and multinational business plans.
The proponents have to justify how they will operate a mine to minimise impacts, but the timing and location of proposals being lodged is largely left to mining corporations and international markets.
Exploration Licences and Planning Approvals for coal mines currently don't make for good planning.
Unlike base metal resources, coal is often region-wide so potential mines cover a large portion of the exploration area with relatively simpler geological sequences and structures.
Leaving the market to decide when and where proposals will be submitted for assessment has resulted in the vast areas of disturbed or poorly rehabilitated land and troublesome voids in the Hunter Region.
There are currently more than 40 coal mines approved to operate in NSW. Seventeen mines are in the intensively disturbed area of the Hunter Region.
Project proposals and assessment processes make many assumptions.
Assumed benefits, including local jobs, economic multipliers and royalty returns to government are usually based on maximum potential, or approved production.
Benefits are only realised with actual production which, year-on-year, depends on international markets and corporate business plans.
Taken together, existing mines are approved to produce hundreds of million tonnes of coal each year.
Public health and regional environmental values need to be prioritised in planning.
The level of 'under production' is not readily tracked in the public domain but, when totalled, can amount to many tens of millions of tonnes less than the potential production on which costs and benefits were estimated at the time of approval.
The gap is particularly relevant when a new proposal is for a relatively small amount of coal that could arguably be supplied by existing mines and gives rise to significant environmental concerns and/or a significant expansion of the regional disturbance footprint.
In the case of the Bylong Valley, I find it hard to imagine a compelling public interest justification for an extension of the already vast regional footprint of mining impacts given Kepco's modest level of proposed production if there is a large gap between approved production and actual production at the region's existing mines.
If there is a significant gap between approved production levels and actual output, set against the projected life of existing mines and their available reserves, new mine proposals should be considered only in exceptional circumstances.
To manage the industry in this way, government would need to take back a level of control on the timing of any proposal being accepted for assessment and demonstrate a commitment to prioritise the public interest through credible strategic planning.
Public health and regional environmental values need to be prioritised in planning.
Adoption of a more strategic role for government might be usefully employed if health concerns about deteriorating air quality in the Upper Hunter continue to grow.
A strong argument might be made that no new open cut mines should be approved in the Muswellbrook airshed until one or more of the existing mines are closed and adequately rehabilitated to suppress dust.
Poor air quality incidents often give rise to community expectations that a mine should be penalised.
In reality, all mines may be individually applying best practice controls but under adverse weather conditions, with so many mines in one area and so much disturbed land, significant cumulative impact may be unavoidable.
There seems to be an implicit assumption that the public interest is a beneficiary of a healthy NSW Treasury balance sheet and mining companies' business plans.
The wider regional community may have accepted the demise of villages such as Camberwell and Warkworth as unavoidable; collateral local damage for benefits delivered to the state or region.
However, a growing number of the 13,000 odd residents of Muswellbrook seem to be expressing alarm at deteriorating air quality.
Shift-change peak hour traffic on the New England Highway and Hunter Expressway suggest a disproportionate amount of touted employment and contractor income are delivering benefits largely beyond their local community and economy.
Credible strategic planning more clearly focused on the public interest at all levels would enhance community confidence in the planning system.
