The period for public comment on the T3 coal terminal expansion under the EPBC act has just closed and Economists at Large made a brief submission.  In our submission we discuss that the project has not been subject to adequate economic assessment.

There has been no cost benefit analysis of the T3 project or any of its related projects, including Kevin’s Corner.  Only Input-Output modelling has been used, which is an inappropriate approach.

Impacts on matters of national environmental significance should be incorporated into full cost-benefit analysis of the project, including:

• Climate change impacts at a global level
• Impacts of the T3 project on the GBR at a national or state level

We urge the commonwealth to commission a thorough review of the economic assessment of the component parts of these projects and incorporate their impacts on matters of environmental significance into the economic assessment.  The nature of these existing assessments recalls the “piecemeal” economic assessment of the Traveston Crossing Dam project.  That project’s economic assessment was found to be inadequate and misleading by the Commonwealth commissioned review.