Labor's election platform about coal industry "complexities" mirrors a 2016 NSW Minerals Council submission that argued individual mines would be unfairly impacted if coal was included in the NSW Load-Based Licensing Scheme for the first time since its inception in 1999.

The Minerals Council said "complexities" included the proximity of mines to population centres and impact of prevailing winds, so that one mine would pay significantly more for air pollution than another. It objected to higher fees for mines with more air pollution from larger overburden mounds, and pollution fees for mine water discharges.

A Labor election platform released last week to "protect our environment and address climate change" committed to completing the stalled Load-Based Licensing Scheme review, but included an acknowledgment "there are complexities with applying the scheme to coal mining".

Singleton general practitioner and Doctors for the Environment member Bob Vickers said the concession to coal was "disappointing" because coal mining should not be exempted from a scheme that links industry with the impacts of the pollution it produces.

"It's disappointing the Labor Party doesn't see the Load-Based Licensing Scheme as a tool to reduce pollution when in reality it is the best solution we have available to reduce harmful emissions," Dr Vickers said.

"We are well aware of the health impacts of air pollution. It's not just about coal dust in the Hunter, but a large percentage of air emissions comes from coal mining and coal-fired power generation," he said.

"The best way of reducing emissions is by putting a price on those emissions which is what the load-based licensing scheme aims to do."

Lock the Gate Alliance spokesperson Georgina Woods said Hunter air quality standards were being breached while coal was excluded from the only mechanism that priced pollution.

"The Labor Party has given the coal industry a get-out clause pre-emptively, even before the stalled review is completed," Ms Woods said.

"The only conclusion I can reach about why that has happened is that the coal industry has specifically lobbied the party on this."

In November, 2016 the NSW Environment Protection Authority released a report proposing expanding the load-based licensing scheme to include mining and PM2.5 fine particle pollution for the first time, after Commonwealth and state environment ministers set a PM2.5 standard in December, 2015.

In 2017 the EPA said all man-made particulate emissions in the Upper Hunter areas needed to be reduced by 50 per cent to meet the new standard.