Dear EPA Victoria,

Levels of air pollution recorded in the Latrobe Valley and in Melbourne have been associated with increased risk of death, acute asthma, preterm birth and low birthweight [1-8]. The majority of toxic pollution in the Latrobe Valley airshed comes from coal-fired power generation [9]. Recent modelling has estimated that every year pollution from the power stations causes 17 deaths among adults, 11 low weight births and 217 person-days of asthma symptoms among children in the Latrobe Valley [10]. The same modelling estimated that the pollution can travel hundreds of kilometres and that every year in Victoria it causes 190 deaths among adults, 238 low weight births and 4,024 person-days of asthma symptoms among children [10].

Latrobe Valley power stations are currently permitted to emit pollution at levels far greater than those permitted overseas. For example each Latrobe Valley power station is currently permitted to emit well over 100 milligrams of particulate matter per cubic metre of air, whereas by 2021 each European coal-fired power station of similar size will only be permitted to emit up to 12 milligrams of particulate matter per cubic metre of air [11,12]. In 2016 The Board of the Hazelwood Mine Fire Inquiry recommended that “Latrobe Valley mine operators should lead the way in implementing the best available technology to reduce emissions”[13] but this has not been done because the power stations have not been required to reduce their pollution.

We therefore request that you now require Latrobe Valley power stations to:

(a) limit their toxic pollution emissions to the same levels, or less, than will be required by 2021 for coal-fired power stations of similar size in the European Union - specifically, 175 mg/Nm3 of NOX, 100 mg/Nm3 of carbon monoxide, 130 mg/Nm3 of sulfur dioxide, 5 mg/Nm3 of hydrochloric acid, 3 mg/Nm3 of hydrofluoric acid, 8 mg/Nm3 of particulate matter and 7 µg/Nm3 of mercury [12] - and,

(b) install best practice pollution controls to reduce toxic emissions including fabric bag filters, flue-gas desulfurisation, selective catalytic reduction and activated carbon injection technology [14]

We assume that the above pollution limits are achievable for Latrobe Valley power stations based on independent expert review concluding that there are no technological barriers to designing pollution control systems for the power stations [14] and because many coal fired power stations in Europe are of a similar age or older than Latrobe Valley power stations.

We consider these interventions crucial for protecting Latrobe Valley residents and other Victorians from further harm.

We look forward to your response.

Sincerely,