Mod 14 - Water Discharges + Coal Extraction

Dear Sir/Madam, I am writing to object To any increase of discharge from Moolarben Coal operations into the Goulburn river. The river is already stressed out to hell with the filth they are pumping into it. I can remember looking down through 10 feet of water at O'Briens Crossing in 1993 and seeing the Catfish nests that had been built on the bottom. One can't see below the surface now. I have seen the fish evacuating the river and dying in the billabongs when the mine released during a rain event and a wall of pure mud flowed down the riverbed... Whoever is in charge of giving these ruthless bastards licence to pollute at leisure should have to answer to the electorate... Yours, James A. Duffy

Objection
I am concerned about water quality especially since South Australian premier is calling for a royal commission into water use in NSW and Queensland. It seems premature to be using and contaminating water that may affect downstream users. I'm also concerned about the threat to species and surrounding habitat due to impact from this essentially outdated resource.

I live on the banks of the Goulburn River have done for over 30 yrs and have seen the many moods of the river. It is a major concern for me to see a continuous flow of water from the coal mines This is not the natural way of the river this water belongs to the underground system,it is not a surface flow.
Long term, it will be a major problem with an increase of an additional 30t0nnes of salt a day into the river systems.
I have lost my community of Wollar due to coal mining impacts Now it seems the Goulburn River is next on the hit list.
Additional trains mean more maintenance and track grinding this has the potential for more fires along the rail line.
The attitude the government and mining companys have is"lets fix the problem later" rather than trying to solve it now. Water is a valuable asset in this dry climate of Australia it should be treated so. With climate change showing more evidence burning another 22 million tonnes of coal is only accelerating the problem. burning coal must stop now.

Moolarben Coal 1 - MOD 14

I object and equally opposed this modification in it entirety.

Previous history is well documented with evidenced based facts with underground mining in upper catchments, this project is no different. An Independent Regional Water Survey and cumulative impact study to determine the full environmental impacts of all mining for groundwater and river systems of the Upper Goulburn River catchment required.

Increasing mine discharge from 10 million litres a day to 20 million litres a day as well as the equivalent of 30 tonnes of salt each day will alter the entire upper catchment systems capacity to remain a viable river system..

Wilpinjong Mine has a salt discharge limit of 500 EC. There needs to be consistency with MCO having the same limit, not 900 EC. Whilst Wilpinjong mine has a licence limit of 500 EC this also needs further investigation and independent report on the degradation and loss of aquatic habitat. It is well known fact that once electrical conductivity exceeds 300 micro Siemens the loss of habitat is imminent which then has a flow on event within entire river system habitats for the survival all of reliant species Flora and Fauna.

There are two critically endangered ecological communities that will be destroyed and habitat for 9 threatened bird species and 5 threatened micro-bat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby.

With the loss of water, degradation of water quality in the river systems, include the 2 EECs this will destroy the entire area for the survival of both land and water dependant species.

This area as with other areas with the same sandstone formation will increase the loss of Aboriginal Heritage due to cliff collapses. This is Australias' history laid in stone. We as a society will treasure ancient written books with great care and protection. This documented history of Australian Aboriginal Heritage requires the same values and protection.

Equally missing and has not been addressed with a Social Impact Policy by the company for this entire development application is the destruction of the social fabric of small communities. We are all aware of the documentation of employment opportunities and flow on effect but there needs to be inclusiveness of all . Recommendation with consultation from the community on a Social Impact Policy should be required.

With the transition to renewable energy and reduction in costs, no impacts to waterways, landscapes, air pollution, noise and dust pollution I encourage the Department on recommending current Coal Mining companies to increase their usage of renewable options with any part of their operations where applicable. This will also provide a transition to those existing employees in this industry to have a future direction when coal is longer the dominating provider for energy.

I thank you for your time.

Yours truly
Julie Favell

Re: 17_8711 MOD 14 - Moolarben Coal Operations Stage 1 Mod 14, Stage 2 Mod 3

DATE: 1 December, 2017

Dear Sir/Madam,

I write to object to the above proposal to expand the Moolarben Coal Complex. The increase in carbon emissions, including fugitive emissions caused by increased coal production to 22 million tonnes pa until 2038 poses significant environmental, social and economic threats to the people of NSW.

We object to the increase in coal production for the following reasons:
* Moolarben Coal Operators propose to increase the amount of licenced water discharge into the Goulburn River to
20 million litres per day. This will further degrade water quality and cause additional ecological stress to the river.

* The cumulative impact of approved mine water discharges from nearby mines such as Ulan and Wilpinjong will alter the natural flow regime and discharge up to 30 tonnes of salt per day into the river system. Increasing the total salt load of the Goulburn River threatens the Goulburn River National Park and downstream water users.

* There has been no independent study of the cumulative impact of coal mining on the headwaters of the Goulburn River.

* Areas of two critically endangered ecological communities will be destroyed along with habitat for nine threatened bird species and five threatened microbat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby.

* The Water Management Plan for previous approvals, required by October 2016, is still not available.
We urge that this extension be rejected outright.
Yours sincerely,

Annette Smith, Ryde. NSW. 2112.

With climate change a proven and demonstrable fact, and with the burning of coal the acknowledged primary cause of the increased level of CO2 in the atmosphere, any proposal to increase coal production must be opposed. The proposed increase in production by MCO to 22mtpa until 2038 is therefore unacceptable.

The proposed increase of licenced polluted water discharge into the Goulburn River to 20 million litres a day is also unacceptable.When the currently licenced discharge limit of 10ML per day has not been reached, what justification is there for an increase to 20. The cumulative impact of discharges from Moolarben, Wilpinjong and Ulan mines will further degrade water quality in the Goulburn River, will threaten the Goulburn River National Park, downstream water users, and the Hunter River Salinity Trading Scheme.

The long term negative effects on groundwater, particularly affecting the Great Dripping Wall have not been adequately considered.

Any mine expansion inevitably leads to loss of habitat for wildlife. The biodiversity offset strategy for the expansion has not been finalised.

The proposed expansion will not guarantee an increase in employment, or guarantee existing job security. The only guarantee will be an increase in the threat level to the local environment and the associated threat to the future of the planet from another increase in the atmospheric CO2 level.

Dear Sir / Madam,

I object to the proposed extension as there has not been adequate studies in the cumulative effects of mine water discharge into the Goulburn River.
The massive amount of salt that will be discharged is not acceptable.
It will not increase the number of jobs in the area, and the very small increase in possible royalties does not justify the damage that will be done to the environment, or to the health of local residents both close to the mine or on transport corridor.
The economic impacts of increased severe weather events as a result of the increased carbon emissions should also be considered.

The damage done

Re: 17_8711 MOD 14 - Moolarben Coal Operations Stage 1 Mod 14, Stage 2 Mod 3

DATE:

Lodge on line: http://majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=8711

Dear Sir/Madam,

We write to object to the above proposal to expand the Moolarben Coal Complex. The increase in carbon emissions, including fugitive emissions caused by increased coal production to 22 million tonnes pa until 2038 poses significant environmental, social and economic threats to the people of NSW.

We object to the increase in coal production for the following reasons:
* Moolarben Coal Operators propose to increase the amount of licenced water discharge into the Goulburn River to
20 million litres per day. This will further degrade water quality and cause additional ecological stress to the river.

* The cumulative impact of approved mine water discharges from nearby mines such as Ulan and Wilpinjong will alter the natural flow regime and discharge up to 30 tonnes of salt per day into the river system. Increasing the total salt load of the Goulburn River threatens the Goulburn River National Park and downstream water users.

* There has been no independent study of the cumulative impact of coal mining on the headwaters of the Goulburn River.

* Areas of two critically endangered ecological communities will be destroyed along with habitat for nine threatened bird species and five threatened microbat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby.

* The Water Management Plan for previous approvals, required by October 2016, is still not available.
We urge that this extension be rejected outright.
Yours sincerely,

John Boyle
__________________________________________________

Mddress___8_______________________________ Morvan Street____________
West Ryde 2114

Enough is enough, no more expansions of existing coal mines in the Mudgee region.

Hello,

I strongly object to this new modification to Moolarben Coal Mine, the 14th one on the original project.
The number of modifications shows how the project strongly departs from initial approval.
I would like to also point out that due to recent amendments to the EP&A Act 1979 past by NSW Parliament, part 3A modifications will cease to be an available pathway in the next few months.
Adding an extra part 3A modification just before they are repealed goes against the intention of recent amendments to the EP&A act. These new modifications to Moolarben Coal Mine should be assessed under the new legislation.
My objection to this development, in addition to the fact that it is based on an obsolete piece of planning legislation, is based on the following 5 distinct categories of grounds and 15 subsequent points:
A/ Groundwater and River system related impacts
1. MCO proposed increase of licenced water discharge into the Goulburn River to
20 million litres per day will further degrade water quality and cause additional ecological stress to the river. The dumping of large quantities of salt every day in the river system will alter the natural ecological state of this essential resource for current and future communities.
2. The current MCO discharge licence of 10 million litres per day was never used. This existing licence is more than adequate, and does not require to be doubled.
3. The Water Management Plan for previous approvals, required by October last year, is not available. This does not allow the community and planning authorities to make informed decisions about this development application.
4. Brine from water treatment plant used for dust suppression will drain into sediment dams that are designed to overflow into the river adding more salt that hasn't been accounted for
5. Groundwater model assumptions do not reflect potential impacts on springs and the upper groundwater system
6. Long term effects of dewatering and draining the landscape above the mine have not been properly assessed
7. Considering all previous points about increase to licenced water discharge, salt discharge increase, absence of long term studies on effects, it is highly likely that approval of this part 3A Mod will threaten the Goulburn River National Park, downstream water users, and the Hunter River Salinity Trading Scheme
B/ Impact on noise and dust levels
1. Compliance of the mine with existing requirements linked to noise and dust conditions is based on the ongoing purchase of neighbouring properties that were not afforded acquisition rights in previous approvals. This puts at risk the social sustainability of the local communities. It is highly unlikely that MCO would have complied with existing noise and dust requirements without these purchases.

C/ Impact on biodiversity
1. The agreement in The Drip Deed to protect additional areas of land as State Conservation Area has not been met under the agreed timeframe of March 2017
2. Areas of two critically endangered ecological communities will be destroyed and habitat for 9 threatened bird species and 5 threatened microbat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby
3. The biodiversity offset strategy has not been finalised
4. These dramatic impacts on the local biodiversity are contrary to the objects of the EP&A Act 1979. As reminded by Scot Mac Donald MLC during recent debates about amendments to the EP&A "the objects that are facilitating ecologically sustainable development and protecting the environment, including the conservation of threatened and other species of native animals and plants, ecological communities and their habitats". The proposed development goes against these objects due to points raised above in points 1.,2. And 3.
D/ Development negatively impacting local, state and national levels of carbon emissions
1. The proposal to increase coal production to 22 mtpa until 2038 is an unacceptable increase in carbon emissions, including fugitive emissions. Climate change is an imminent critical threat to the environment, society and the economy. These costs have not been assessed. As pointed out by Mr. David Shoebridge MLC during discussions in the Legislative Council about changes to the EP&A, "when it comes to mining, petroleum production and other extractive industries, that the current planning bill and current planning law have major flaws, in fact, climate-busting flaws, especially when it comes to the extraction of coal in New South Wales. The way that the planning Act operates is that if there is a large coalmine in the Hunter Valley, the planning Act will consider the greenhouse gas emissions in building a railway line out to the coalmine, putting in some trucks, using all the farmland, digging a ruddy great hole, digging up the coal, putting it on the rail line and sending it to the port, but that is it. For some reason the planning Act in New South Wales seems to pretend that the coal is not being burnt and ignores the 2½ tonnes of greenhouse gas emissions that are produced for every tonne of coal that is being burnt as though it is all going to be burnt on a different planet."
2. The NSW Climate Change Policy Framework establishes long-term objectives to achieve net zero emissions by 2050 and to make New South Wales more resilient to a changing climate. Increasing coal production to 22 millions of tonnes per annum goes directly against the NSW Climate Change Policy Framework. Reaching the targets agreed by Australia during the Paris Agreement with most other sovereign countries of the world necessarily implies to refuse approval to this development.

E/ Impact on local jobs and industries in the area
1. The increased coal production will not increase jobs nor guarantee job security.
2. The increased reliance on mines in the area for providing jobs is a threat to the economy, being given that diversification of sectors, industries and jobs is an economic asset. If the price of coal was to fall on transnational markets, and production was to be dramatically decreased, the socio-economic impacts in the Mudgee area would have a strong negative impact on the local communities. There are many international examples of the dangers of economic reliance on primary industries such as coal mining.

I urge you to consider my objection to this development. Impacts on water, noise and dust level, biodiversity, and greenhouse gases emissions are too important.
More in depth and long term studies are required before to statute on this development application.

Regards,
Thomas C.

Moolarben Coal Operations
Stage 1 Mod 14, Stage 2 Mod 3
Submission of Objection
1. First and foremost in my objections to these modifications is that of climate change from increased levels of carbon emissions, including fugitive emissions. Frequently we are seeing extreme weather events in Australia and worldwide; we are hearing the word "unprecedented" in increasing usage in reference to weather across the globe, and yet we continue to approve extensions to coal mines such as Moolarben as if all this was a fantasy. The science is in, the weather statistics are in, and it is time to accept the fact that coal is an industry leading the world we know to imminent danger from climate change.
The proposal to increase coal production to 22 mtpa until 2038 is a direct threat to our environment, society and the economy. These costs have not been assessed

2. It is unacceptable that there has NEVER been an independent study of the cumulative impact of mining on the headwaters of the Goulburn River. Moolarben, Ulan and Wilpinjong coalmines all operate in close proximity to the headwaters and to the Goulburn River itself, with every project, modification or variation of each of the mines being considered in isolation.
3. The Water Management Plan for the previous approval required by Oct 2016 is not available.
4. The groundwater monitoring program is inadequate to determine the background /baseline conditions and changes to the natural flow of the river. The request to increase licenced water discharge into the Goulburn River to 20 million litres per day will cause further deterioration of water quality and additional ecological stress to the river. The existing water discharge licence of 10ML per day has never been used, so doubling it seems inappropriate.
5. The cumulative impact of this increase means that 30 million tonnes of salt per day will now find its way into the Goulburn River. This ever increasing salt load cannot avoid ramifications for agriculture, vineyards, thoroughbred horse studs and the downstream communities of the Hunter region. The Goulburn River National Park too will be severely affected by salinity.
6. I notice too that Wilpinjong Mine has a salt discharge limit of 500 EC while Moolarben Coal Mine has the much higher figure of 900 EC. Surely there should be uniformity at the lower level.
7. There is another source of salt that remains basically unaccounted. This is the brine from the water treatment plant (used for dust suppression) which drains into sediment dams. These dams are designed to overflow into the river, carrying their own burden of salt.
Salinity is a major problem in Australia and discharging salt into rivers at this level must cease.
I wish to refer now to other water impacts of this proposal
8. The long-term effect of draining the landscape and dewatering above the mine has never been properly assessed. This is especially critical in regards to the Goulburn River National Park and The Great Dripping Wall (The Drip). Groundwater model conjectures do not reflect the possible impacts on the springs and the upper groundwater system.
9. Mine modelling did not predict the 5 million litres per day groundwater discharge into the Moolarben Underground 0ne mine. The dewatering of the upper groundwater aquifers occurred in the nearby Ulan Coal Mine, so discharge of the aquifers is a real problem.
"THE DRIP"
All of the concerns mentioned above are of course part and parcel of what endangers this beautiful area.
The Drip gorge and its environs are a much loved area of the Mudgee region and beyond. It is reminiscent of the Kakadu Wetlands, and in pre-white settlement days was and still is, an area of great sacredness and significance to our First Australians.
I am concerned at the delay in finalising The Deed of Agreement between Moolarben Coal and the State Government/ National Parks, to add land to the Goulburn River National Park, and to protect additional areas of land as a State Conservation Area. This was to be done by March 2017. These transfers are of utmost importance for the security, protection and public access to The Drip and its adjacent stretch of river.
The proposed State Conservation Area, while giving some protection to The Drip, does give rise to issues. Firstly it would allow tunnelling under the river, which is unacceptable.
I remember the Sugarloaf SCA in the Hunter which was permanently damaged by huge cracking of the river, and the relevant mining company filled the cracks with huge amounts of concrete which re-emerged in the river two kilometres away.
Stability of pagodas is at risk, and there are potential issues with easements and activities above ground.
A drilling program to set up an extensive dewatering borefield has started opposite The Drip in preparation for Underground 4. As this new mine is not due to start until 2022this seems a bit precipitous.
The Deed stipulated that monitoring bores be established to assess the water geology. This is still to happen.
BIODIVERSITY
Approval for Mod 3 and 14 should not be given until the biodiversity off-set strategy is finalised.
The loss of biodiversity gives me great concern. An area of two critically endangered ecological communities; habitat for 9 threatened bird species and 5 microbat species, have all been recorded in country to be mined under this new proposal. The destruction of these places along with the loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby is of great significance.
No biodiversity offset program can compensate for this.
I do not believe that granting Moolarben Coal these new modifications, increasing their output of coal to 22mtpa until 2038, will lead to more jobs or guarantee job security. After all, the mining industry is being rapidly automated.
On the contrary, I strongly believe that climate change will see the probable end of this industry before that date.

Submission regarding Moolarben Coal 1 - MOD 14

I oppose this application for a number of reasons as outlined below:

1. Loss of habitat

I am concerned about the 81 hectares of disturbance to the flora including 39 hectares of native vegetation. This includes 7 hectares of threatened ecological communities.

This will result in loss of habitat for the 10 threatened fauna species that were identified in the surveys.

I am not satisfied that the environmental offsets have been adequately calculated. Similarly, I am not satisfied that the effects are "short term", under the assumption that the area will be area will be rehabilitated after mining has ceased. Rehabilitation has rarely been shown to be successful.

2. Increased Train Movements

Increased train movements will result in increase emission along the entire route to Newcastle Port. Recent applications for coal loading ports in the USA have been rejected due to the increased health effects on the local community. Specifically it was estimated that there is a 30% increase risk of cancer for those along the railway line.

http://www.ecy.wa.gov/geographic/millennium/

3. Loss of Aboriginal Heritage Sites

There are 9 new Aboriginal heritage sites identified in the survey. 2 of these fall within the modification area. On is considered of moderate scientific significance. However, they are all identified as having high cultural significance to the Aboriginal community.

4. Increased Coal Production

The modification proposes an increase in coal production. It is well documented that anthropomorphic climate change is occurring and any increase in coal production and burning is detrimental to the future of our planet and subsequently our health. There is no excuse for further coal production.

5. Air Quality

Increase production of coal will result in an increase in emissions. There has been over 70 air quality alerts in the upper Hunter in 2017. Consequently any increase in local emissions will cause a deterioration in air quality.

It should also be noted that there is not adequate baseline PM2.5 air quality records in the local area. Consequently, the estimates for Pm2.5 are likely to be inaccurate. Before any expansion of the mining occurs there needs to be adequate baseline PM2.5 data. As outlined in the application, there is "no readily available ambient PM2.5 monitoring data collected near the Moolarben Coal Complex".

Similarly, the data for PM10 ambient levels are based on measurements from 2011-2012. There has been further mining since that time as well as a deterioration in air quality. Consequently, the PM10 data is also unreliable.

There has been a failure of mitigation methods for deterioration in air quality in the Upper Hunter. Consequently, I have no confidence that the mitigation methods that our outlined in the application will be effective in mitigation against a deterioration in air quality.

6. Increased Greenhouse Gas Emissions

Increase in the production of coal will increase total global emissions. Australia is already struggling to fulfil its commitments to the Paris Agreement. Any increase in mining will make this harder to achieve.

Summary

I oppose this modification due to the increase health risks related to worsening of air quality and an increase in global emissions relate to the production of the coal as well as the subsequent burning of the coal.

Furthermore, I oppose this modification due to the damage to flora and fauna as well as Aboriginal heritage sites.

I object to yet another expansion.

The additional release of mine effluent water into the Goulburn river will further impact the unseasonal flows. Since mining began in this area and flows have increased weeds from upstream have invaded areas people once enjoyed and fish species have declined.
More regular flooding across a low level bridge at Obriens crossing will cause even more hardship for those living on the north side and employed on the other, including mine workers.
The additional increased salt levels into the Goulburn river from Moolarben joined with Wilpinjong and ulan is totally unexceptable
Trains are currently a huge issue of concern. The line is already congested with a train waiting at every loop between the mines and Newcastle spewing diesel fumes into the air of those living close by. The noise from these trains is already disturbing.
Local VOLUNTARY fire fighters are also expected to take unpaid time off work to control fires along railway corridors and into mine owned land of which there have been three this season so far because protocols are not followed and DIDO mine workers do not want to fight fires.
Once again locals will be impacted those downstream and along the railway corridor will be impacted the environment will never be regenerated ( that is just a hideous joke) for yet another greedy expansion with ridiculously low royalties from a foreign company.
I would expect you educated people don't have your head in the sand as far as climate change is concerned and will see the light for this our 'lucky country' in global greenhouse effect disaster.
Merry Christmas .

I object to the expansion for the following reasons

. Rising Salinity levels in the Goulburn river

. Likelihood of increased flooding over low level crossings

. More trains, more congestion on railway line, more train noise, more railway maintenance increased fires along railway corridor
.
. Another 22million tonnes of unnecessary coal production added to our environment by a foreign company.

. Increased traffic on local roads

. Cumulative impacts on locals

I am writing to object to the modifications to the Moolarben Coal Complex - Moolarben Coal 1 - MOD 14.

Key Issues for objection:

1. MCO proposed increase of licenced water discharge into the Goulburn River to 
20 million litres per day will further degrade water quality and cause additional ecological stress to the river. The cumulative impact with Ulan Coal and Wilpinjong Coal Mines already approved mine water discharges will alter the natural flow regime and dump up to 30 tonnes of salt per day into the river system.
2. There has been no independent study of the cumulative impact of mining on the headwaters of the Goulburn River
The agreement in The Drip Deed to protect additional areas of land as State Conservation Area has not been met under the agreed timeframe of March 2017
3. Areas of two critically endangered ecological communities will be destroyed and habitat for 9 threatened bird species and 5 threatened microbat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby
4. The biodiversity offset strategy has not been finalised
5. The proposal to increase coal production to 22 mtpa until 2038 is an unacceptable increase in carbon emissions, including fugitive emissions. Climate change is an imminent critical threat to the environment, society and the economy. These costs have not been assessed
6. The increased coal production will not increase jobs nor guarantee job security
7. Compliance with noise and dust conditions is based on ongoing purchase of properties that were not afforded acquisition rights in previous approvals. This has caused cumulative social impacts that have not been assessed.

Additional information on water impacts:
1. The current MCO discharge licence of 10 ML/day has never been used. They are now applying to double it to 20ML/day. The existing licence of 10ML/day should be more than adequate.
2. The Water Management Plan for previous approvals, required by October 2016, is not available
3. Brine from water treatment plant used for dust suppression will drain into sediment dams that are designed to overflow into the river adding more salt that hasn't been accounted for
Groundwater model assumptions do not reflect potential impacts on springs and the upper groundwater system
4. Mine modelling failed to predict the 5 million litres per day groundwater make into Underground One. The long term effect of dewatering and draining the landscape above the mine has not been adequately assessed.
5. The increasing total salt load of the Goulburn River will threaten the Goulburn River National Park, downstream water users and the Hunter River Salinity Trading Scheme
Wilpinjong Mine has a salt discharge limit of 500 EC. There needs to be consistency with MCO having the same limit, not 900 EC.

Submission of Objection
Moolarben Coal Operations Stage 1 Mod 14
I am lodging this submission of objection due to my concerns about its adverse effects on The Drip. The MCO proposed increase of water discharge into the Goulburn River will further degrade water quality and cause additional ecological stress to the river.
Concerns re the conservation of The Drip:
In 2014 the NSW State Government publically declared its commitment to preserving this special place for future generations.
This promise to the people of NSW has again been reiterated in the document "Deed for the protection of the Drip".
1. In the Deed document - Background point "d" it states: "Modification 3 approved in January 2015 provides a water management performance measure of Nil impact on the Drip".
2. Section F (1) goes on to say "The Moolarben Parties giving immediate commitment in respect of the conservation of The Drip and its water sources.
Moolarben Coal Operations has not yet demonstrated that they will abide by these commitments: The agreement in The Drip Deed to protect additional areas of land as State Conservation Area by March 2017 has not been met.
No more approvals should occur until the negotiations progressing actions between OEH and Moolarben Coal that impact on the Drip are completed and are open to the public for comment.

The local community and visitors to the Drip are increasingly expressing concern about the impacts of mining on the long term preservation of the Drip.

Water Quality concerns
* The increase in mine water carrying salt and other waste materials will degrade the quality of the water; upset the natural flows and the ecology of the river corridor.
* Generations of local and visiting children have played safely in the waters on warm summer days. Visitors from far and wide have appreciated the amazing beauty of this special place and compare it favourably to other iconic places in their travels. Bird watchers gather in the early mornings at the river. Animal lovers enjoy catching glimpses of the native fauna. An overload of salt in the water will put at risk all these activities.
* Other potentially dangerous substances would be released in the mine water discharge. These may make the river unfit for recreational purposes and are still to be fully identified.
* This application and the EIS reveal that Moolarben Coal Operations have no real commitment to "respecting the water sources to the Drip". This modification, if approved, will contribute to the destruction of the health of the river at its headwaters. This in turn will impact on the Goulburn River at the picnic area, the delightful river walk and the Great Dripping Wall.
* To double the current MCO discharge licence of 10 ML/day to 20ML/day and thereby further increasing the salt in the waters of the Goulburn River is completely unacceptable for the long term preservation of the Drip. The existing licence of 10ML/day should be more than adequate.
* Moolarben Coal has not acknowledged the combined cumulative impact of Ulan Coal and their own discharge and how that will impact on the water at the Drip.
* Also brine from water treatment plants, used for dust suppression, will drain into sediment dams. These are designed to overflow into the river thereby adding more salt. This extra salt and possible toxic waste has not been accounted for by MCO.
* Wilpinjong Mine has a salt discharge limit of 500 EC. There needs to be consistency with MCO having the same limit, not 900 EC.
Concerns Re Monitoring and Management Plans:
* There is little or no evidence that a comprehensive Water Management Plan and adequate water monitoring is being conducted.
* The Water Management Plan for previous approvals, required by October 2016, is not available
* Groundwater model assumptions do not reflect potential impacts on springs and the upper groundwater system
* Mine modelling failed to predict the 5 million litres per day groundwater in Underground One.
* The long term effect of dewatering and draining the landscape above the mine has not been adequately assessed.
* There has been no independent study of the cumulative impact of mining on the headwaters of the Goulburn River
Conclusion:
In response to concerns raised about the preventing of irreversible impacts on The Drip
Todd Duffy Senior Team Leader, Reserve Establishment NPWS wrote:
1. "The consent for Moolarben Coal (05_0117 Modification 3) requires the monitoring of groundwater flows and any other measures to ensure "nil impact or environmental consequences" on The Drip." Considering all the previous issues raised I have no confidence that MCO will take proper measures to ensure the water impacts at the Drip will be Nil. For these reasons I believe that modification 14 should not be approved.

2. "The enforcement of these conditions is a matter for the consent authority, the Department of Planning and Environment."

It will be impossible to unwind the damage once it is done. For the sake of future generations please don't approve this latest modification.

Yours sincerely

Phyllis Setchell
16 Grant St
Mudgee 2850
0427920887
7.12.2017

Thank you for this opportunity to make a submission about modifications to the Moolarton Coal Complex. These involve the increased production of coal from open cuts and combined open cut and underground mines as well as an increase in coal limits and increased daily coal movements.

This increased production of coal for burning is not compatible with Australia's Paris commitments to reduce greenhouse gas emissions.

Increased GHGE and increased particulates from burning coal threaten human health both here in Australia and globally.

It is appalling that further modifications are still even being considered before a thorough regional water study has been done. The community has been calling for this for over a decade. Given that mine modelling failed to predict the 5 million litres per day groundwater make into Underground One it is obvious that there is no understanding of the regional hydrology. The long term effect of dewatering and draining the landscape above the mine has not been adequately assessed. This must be done before anything more is approved.

Moolarben has still not met at least two of its commitments under previous approvals:
* The Water Management Plan for previous approvals, required by October 2016, is not available. Surely this should be available before anything further is even considered!
* The agreement in The Drip Deed to protect additional areas of land as State Conservation Area has not been met under the agreed timeframe of March 2017.

Surely all commitments should be met before any further approvals are even considered! No wonder the community believes the whole planning approval process is a farce and meaningless.


The total salinity issue is not being addressed:
* The increasing total salt load of the Goulburn River will threaten the Goulburn River National Park, downstream water users and the Hunter River Salinity Trading Scheme.
* There should be consistency in the salt discharge limits for all mines in the region: Wilpinjong Mine has a salt discharge limit of 500 EC. MCO should have the same limit, not one 80% higher!
* MCO proposed increase of licenced water discharge into the Goulburn River to 20 million litres per day will further degrade water quality and cause additional ecological stress to the river. The cumulative impact with Ulan Coal and Wilpinjong Coal Mines already approved mine water discharges will alter the natural flow regime and dump up to 30 tonnes of salt per day into the river system.
* Brine from water treatment plant used for dust suppression will drain into sediment dams that are designed to overflow into the river adding more salt that hasn't been accounted for.
Why are cumulative impacts never assessed? Compliance with noise and dust conditions is based on ongoing purchase of properties that were not afforded acquisition rights in previous approvals. This has caused cumulative social impacts that have not been assessed.

The biodiversity offset strategy has not been finalized yet there is significant biodiversity impact: Areas of two critically endangered ecological communities will be destroyed and habitat for 9 threatened bird species and 5 threatened microbat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby.

Claims the increased coal production will increase jobs and guarantee job security are totally unbelievable given the world trend against coal and Moolarben's history of cutting jobs with downturn in prices.

This modification should not be approved.

It is appalling that further modifications are still even being considered before a thorough regional water study has been done. The community has been calling for this for over a decade. Given that mine modelling failed to predict the 5 million litres per day groundwater make into Underground One it is obvious that there is no understanding of the regional hydrology. The long term effect of dewatering and draining the landscape above the mine has not been adequately assessed. This must be done before anything more is approved.

Moolarben has still not met at least two of its commitments under previous approvals:
* The Water Management Plan for previous approvals, required by October 2016, is not available. Surely this should be available before anything further is even considered!
* The agreement in The Drip Deed to protect additional areas of land as State Conservation Area has not been met under the agreed timeframe of March 2017.

Surely all commitments should be met before any further approvals are even considered! No wonder the community believes the whole planning approval process is a farce and meaningless.


The total salinity issue is not being addressed:
* The increasing total salt load of the Goulburn River will threaten the Goulburn River National Park, downstream water users and the Hunter River Salinity Trading Scheme.
* There should be consistency in the salt discharge limits for all mines in the region: Wilpinjong Mine has a salt discharge limit of 500 EC. MCO should have the same limit, not one 80% higher!
* MCO proposed increase of licenced water discharge into the Goulburn River to 20 million litres per day will further degrade water quality and cause additional ecological stress to the river. The cumulative impact with Ulan Coal and Wilpinjong Coal Mines already approved mine water discharges will alter the natural flow regime and dump up to 30 tonnes of salt per day into the river system.
* Brine from water treatment plant used for dust suppression will drain into sediment dams that are designed to overflow into the river adding more salt that hasn't been accounted for.
Why are cumulative impacts never assessed? Compliance with noise and dust conditions is based on ongoing purchase of properties that were not afforded acquisition rights in previous approvals. This has caused cumulative social impacts that have not been assessed.

The biodiversity offset strategy has not been finalized yet there is significant biodiversity impact: Areas of two critically endangered ecological communities will be destroyed and habitat for 9 threatened bird species and 5 threatened microbat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby.

Claims the increased coal production will increase jobs and guarantee job security are totally unbelievable given the world trend against coal and Moolarben's history of cutting jobs with downturn in prices.

This modification should not be approved.

Moolarben Coal Operations Stage 1 Mod 14, Stage 2 Mod 3


While I have little faith in the planning approval process, I continue to participate. Approvals are given but conditions are not met and yet further approvals are given. How does this happen? Two examples with Moolarben:
* The Water Management Plan for previous approvals, required by October 2016, is not available. Surely this should be available before anything further is even considered!
* The agreement in The Drip Deed to protect additional areas of land as State Conservation Area has not been met under the agreed timeframe of March 2017.
Water is a vital resource for life and yet coal mines are given open slather here. The community has been calling for a thorough regional water study to be done so the cumulative impact of three mines in the area can be adequately evaluated. But two decades on it still has not been done and yet it is obvious there is no understanding of the regional hydrology. For example: mine modelling failed to predict the 5 million litres per day groundwater make into Underground One. The long term effect of dewatering and draining the landscape above the mine has not been adequately assessed. This must be done before anything more is approved.

The total salinity issue is not being addressed:
* The increasing total salt load of the Goulburn River will threaten the Goulburn River National Park, downstream water users and the Hunter River Salinity Trading Scheme.
* There should be consistency in the salt discharge limits for all mines in the region: Wilpinjong Mine has a salt discharge limit of 500 EC. MCO should have the same limit, not one 80% higher!
* MCO proposed increase of licenced water discharge into the Goulburn River to 20 million litres per day will further degrade water quality and cause additional ecological stress to the river. The cumulative impact with Ulan Coal and Wilpinjong Coal Mines already approved mine water discharges will alter the natural flow regime and dump up to 30 tonnes of salt per day into the river system.
* Brine from water treatment plant used for dust suppression will drain into sediment dams that are designed to overflow into the river adding more salt that hasn't been accounted for.

Protection of biodiversity is a moral obligation we have towards future generations, but again coal mines are expempt. The biodiversity offset strategy has not been finalized yet there is significant biodiversity impact: Areas of two critically endangered ecological communities will be destroyed and habitat for 9 threatened bird species and 5 threatened microbat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby.

Why are cumulative impacts never assessed? Compliance with noise and dust conditions is based on ongoing purchase of properties that were not afforded acquisition rights in previous approvals. This has caused cumulative social impacts that have not been assessed.

Claims the increased coal production will increase jobs and guarantee job security are totally unbelievable given the world trend against coal and Moolarben's history of cutting jobs with downturn in prices.

This modification should not be approved.