Endnotes

  1. Exhibit 32 – Statement of John Merritt, para. 18
  2. Environment Protection Act 1970 (Vic), s. 5
  3. Exhibit 32 – Statement of John Merritt, para. 18
  4. Exhibit 32 – Statement of John Merritt, para. 21
  5. Exhibit 32 – Statement of John Merritt, para. 21
  6. Environment Protection Act 1970 (Vic), s. 13(1)(k)
  7. Exhibit 32 – Statement of John Merritt, para. 58
  8. Exhibit 32 – Statement of John Merritt, para. 19
  9. Environment Protection Authority 2014, EPA Ambient Air Monitoring Stations, EPA, Melbourne, viewed 9 July 2014, http://www.epa.vic.gov.au/our-work/monitoring-the-environment/air-quality-bulletins/epa-ambient-air-monitoring-stations
  10. Exhibit 40 – Supplementary expert report of Claire Richardson, paras 29 & 30
  11. Exhibit 32 – Statement of John Merritt, para. 73
  12. Exhibit 32 – Statement of John Merritt, para. 73
  13. Torre T989:28 – T990:14
  14. Exhibit 32 – Statement of John Merritt, paras 84-88
  15. Exhibit 55 – Statement of John Mitchell, paras 128-133; Written submission of the Latrobe City Council, attachments 2 & 3
  16. Exhibit 55 – Statement of John Mitchell, paras 128-133; Written submission of the Latrobe City Council, attachments 2 & 3
  17. Exhibit 32 – Statement of John Merritt, para. 89
  18. Exhibit 32 – Statement of John Merritt, para. 9
  19. Exhibit 32 – Statement of John Merritt, para. 24
  20. Exhibit 32 – Statement of John Merritt, paras 17 & 113
  21. Exhibit 32 – Statement of John Merritt, para. 9
  22. Exhibit 32 – Statement of John Merritt, para. 203
  23. Adapted from Exhibit 85 – Material provided by the EPA, environmental sampling around Morwell, p. 2
  24. Adapted from Exhibit 85 – Material provided by the EPA, environmental sampling around Morwell, pp. 1-2
  25. Adapted from Exhibit 85 – Material provided by the EPA, environmental sampling around Morwell, p. 3
  26. Adapted from Exhibit 85 – Material provided by the EPA, environmental sampling around Morwell, p. 4
  27. Exhibit 32 – Statement of John Merritt, Appendix Two
  28. Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft)
  29. Exhibit 32 – Statement of John Merritt, para. 114; Appendix Two
  30. Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft)
  31. Exhibit 32 – Statement of John Merritt, Appendix Two
  32. Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft)
  33. Exhibit 32 – Statement of John Merritt, Appendix Two
  34. Torre T958:22-28
  35. Exhibit 32 – Statement of John Merritt, Appendix Two
  36. Adapted from Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p.5
  37. Exhibit 36 – Expert report of Claire Richardson, pp.10 & 11
  38. Torre T974:24-30
  39. Exhibit 37 – California Guide for Public Health Officials, p. 24
  40. Adapted from Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 5
  41. Exhibit 41 – Joint report of Claire Richardson and Paul Torre, para. (d)
  42. Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 5
  43. Exhibit 41 – Joint report of Claire Richardson and Paul Torre, para. (d)
  44. Adapted from Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 4
  45. Exhibit 41 – Joint report of Claire Richardson and Paul Torre, para. (c)
  46. Torre T973:6-28
  47. Adapted from Exhibit 85 – Material provided by the EPA, hourly average PM2.5 levels at Morwell (South) (February – March 2014) produced by the EPA
  48. Victorian Government Documents, 22 May 2014, Explanation of TRAVELBLANkET results of sampling 22 February 2014 (EPA.0010.004.0332)
  49. Exhibit 86 – Maps provided by John Merritt in a meeting with Latrobe City Council on 28 February 2014
  50. Victorian Government Documents, 22 May 2014, Explanation of travel blanket results of sampling on the 22nd February (EPA.0010.004.0332)
  51. Adapted from Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 4
  52. Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 1
  53. Adapted from Exhibit 85 – Material provided by the EPA, Hazelwood Coal Mine Fire – Air Quality Monitoring Report (draft), p. 6
  54. Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 6
  55. Adapted from Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 6
  56. Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 6
  57. Exhibit 32 – Statement of John Merritt, para. 138
  58. Adapted from Exhibit 85 – Material provided by the EPA, Hazelwood coal mine fire – air quality monitoring report (draft), p. 6
  59. Exhibit 85 – Material provided by the EPA, Hazelwood Coal Mine Fire – Air Quality Monitoring Report (draft), p. 6
  60. Exhibit 40 – Supplementary expert report of Claire Richardson, para. 13
  61. Exhibit 40 – Supplementary expert report of Claire Richardson, para. 14
  62. Exhibit 40 – Supplementary expert report of Claire Richardson, para. 11
  63. Exhibit 41 – Joint report of Claire Richardson and Paul Torre, para. (b)
  64. Exhibit 41 – Joint report of Claire Richardson and Paul Torre, para. (b)
  65. Exhibit 38 – Second statement of Paul Torre, para. 4
  66. Exhibit 38 – Second statement of Paul Torre, para. 5
  67. Exhibit 38 – Second statement of Paul Torre, paras 16-17
  68. Torre T967:31 – T968:2
  69. Exhibit 32 – Statement of John Merritt, para. 174
  70. Exhibit 41 – Joint report of Claire Richardson and Paul Torre, para. (e)
  71. Exhibit 32 – Statement of John Merritt, para. 154(a)
  72. Exhibit 32 – Statement of John Merritt, para. 154(g)
  73. Exhibit 32 – Statement of John Merritt, para. 154(h)
  74. Exhibit 32 – Statement of John Merritt, para. 154(b)
  75. Exhibit 32 – Statement of John Merritt, para. 154(c)
  76. Exhibit 32 – Statement of John Merritt, para. 154(d)
  77. Exhibit 32 – Statement of John Merritt, para. 154(e)
  78. Exhibit 32 – Statement of John Merritt, para. 154(f)
  79. Exhibit 32 – Statement of John Merritt, para. 160
  80. Torre T1000:17-27
  81. Exhibit 32 – Statement of John Merritt, para. 55.5
  82. Exhibit 32 – Statement of John Merritt, para. 42
  83. Exhibit 39 – Expert report of Claire Richardson, para. 36; Richardson T1026:25 – T1027:6
  84. Exhibit 40 – Supplementary expert report of Claire Richardson, para. 11
  85. Exhibit 41 – Joint report of Claire Richardson and Paul Torre, para. (e)
  86. Exhibit 32 – Statement of John Merritt, para. 163
  87. Exhibit 38 – Statement of Paul Torre, para. 40; Torre T974:24-30
  88. Burke T1372:19-22
  89. Torre T951:24-26
  90. Adapted from Exhibit 32 – Statement of John Merritt, paras 124 & 125
  91. Exhibit 32 – Statement of John Merritt, paras 96 & 97
  92. Burke T1370:14 – T1371:30
  93. Exhibit 32 – Statement of John Merritt, para. 139
  94. Exhibit 32 – Statement of John Merritt, para. 147; Detailed soil samples can be found at Exhibit 32 – Statement of John Merritt, para. 151 attachment,
    Soil and Ash Results and Graphs (EPA.007.002.0183)
  95. Exhibit 32 – Statement of John Merritt, para. 156
  96. Exhibit 32 – Statement of John Merritt, para. 139
  97. Exhibit 32 – Statement of John Merritt, para. 149
  98. Exhibit 32 – Statement of John Merritt, paras 158 & 159
  99. Exhibit 32 – Statement of John Merritt, para. 150; Detailed ash results can be found at Exhibit 32 – Statement of John Merritt, para. 151 attachment,
    Soil and Ash Results and Graphs (EPA.007.002.0183)
  100. Adapted from Exhibit 32 – Statement of John Merritt, para. 150
  101. Exhibit 85 – Material provided by the EPA, environmental sampling around Morwell, p. 4
  102. Exhibit 32 – Statement of John Merritt, para. 142
  103. Exhibit 32 – Statement of John Merritt, para. 145
  104. Exhibit 32 – Statement of John Merritt para. 139
  105. Exhibit 32 – Statement of John Merritt, para. 155
  106. Detailed results of water testing can be found at Exhibit 32 – Statement of John Merritt, para. 151 attachment, Soil and Ash Results and Graphs (EPA.007.002.0183)
  107. Exhibit 32 – Statement of John Merritt, para. 144
  108. Detailed results of water testing can be found at Exhibit 32 – Statement of John Merritt, para. 151 attachment, Soil and Ash Results and Graphs (EPA.007.002.0183)
  109. Exhibit 32 – Statement of John Merritt, para. 146
  110. Adapted from Exhibit 85 – Material provided by the EPA, environmental sampling around Morwell, p. 3
  111. Exhibit 32 – Statement of John Merritt, para. 109
  112. Exhibit 32 – Statement of John Merritt, Appendix Three, Peer Reviews (EPA.0001.007.0010)
  113. Exhibit 32 – Statement of John Merritt, Appendix Three, Peer Reviews (EPA.0001.007.0014)
  114. Exhibit 32 – Statement of John Merritt, Appendix Three, Peer Reviews (EPA.0001.007.0016)
  115. Exhibit 87 – Statement of Lisa Wilson, para. 30
  116. Exhibit 40 – Supplementary expert report of Claire Richardson, para. 22
  117. Exhibit 40 – Supplementary expert report of Claire Richardson, para. 22
  118. Torre T949:24-28; T974:2-9
  119. Second written submission of the Victorian Government, 18 June 2014, paras 6.3 & 6.12
  120. Exhibit 32 – Statement of John Merritt, paras 41 & 47
  121. Third written submission of the Victorian Government, 23 June 2014, para. 139
  122. Second written submission of the Victorian Government, 18 June 2014, para. 6.25