Nearly 18 months ago we made a submission to the China First Coal Project’s environmental impact assessment. The economic appendix, written by AEC Group, was an economic impact assessment based on general equilibrium modelling, which estimated some positive and negative impacts of the project, but completely failed to ask “Is the project in the interests of Queensland?”.
AEC Group agree with us that the analysis prepared by AEC group “is an economic impact assessment, not an economic welfare assessment” and that the EIS does not therefore “identify whether the project provides a net benefit to the state”. Presumably they would also agree that this contradicts the Queensland guidelines for economic assessment:
The primary method of economic evaluation of public sector policies and projects is cost- benefit analysis. (Qld DIP 2011,p18)
I dare say that if they had been asked to do a cost benefit analysis, AEC Group would agree with us that they would need to evaluate some serious environmental costs, accruing at local, national and global levels:
- Destruction of the Bimblebox Nature Refuge
- Increased shipping in the Great Barrier Reef Marine Park
- Marginal increase in global carbon emissions
Here’s our full submission.