Berrima Coal Mine

Introduction

The Southern Highlands Coal Action Group is a 3,000 strong alliance of residents of the Southern Highlands (in the seat of Goulburn) whose members do not want coal or coal seam gas mining damaging their environment, health, livelihoods and way of life.

The SHCAG acknowledges that NSW needs coal and gas development for energy, jobs and for export. These needs, however, need to be counter balanced by the longer term imperative to protect the environment.

Our Concern

The concern of the SHCAG is that, in our view, the existing use provisions for the cement works can only be interpreted to allow coal to be held at the cement works to ensure a regular supply of fuel to the Cement Work's boilers and no more.

The stock piling of up to two hundred thousand tons of coal each year at the cement works where the stated intention is that this coal is for export is a clear and evident change to the existing use provisions. This change is so significant that the SHCAG believes this proposed change should be subject to a full Development Approval so that all sides of the question can be considered. We also want to see a full Environmental Impact Statement (EIS) also made available to the public at large and with a 90 day period in which to comment not the present 30 days as this period of time is manifestly inadequate.

Our concerns about any coal stock pile particularly a large one exposed to the wind and weather include the following:

The undesirable increase in truck traffic from the Medway mine to the cement works.
The addition of coal dust to the cement dust with which local residents are already struggling.
The problem of rain water leaching through the coal stockpile and how this waste water is to be managed so that it does not ever pollute the environment.
We also have concerns about more noise from the coal conveyors needed to load and unload the stockpile.


The SHCAG argues that existing use provisions are precisely that. Existing uses only! Any significant change to the existing use of the cement works requires a DA. Unilateral action by Boral in pursuit of the export of coal simply cannot be accepted

Council should also have a major say in this development


Lease renewal.
Associated with the cement works is the expansion at the Berrima Mine/Medway Colliery. We wish the Minister in any approval to regularise the exisitng use provisions ban the use of Long Wall Coal MIning in the Southern Highlands.

We note that alteration to habitat following subsidence due to long wall mining has been listed as a key threatening process under the Threatened Species Conservation Act.

Threat Abatement Plans are required to be prepared that
must be taken into account in any development assessment. It is clear that the precautionary principle should be invoked at this time as it is clear that it is not possible to guarantee that there would not be negative impacts from either long wall mining.

The conditions under which the present licences were issued were decided many years ago and land usage and demography has changed markedly in the life of the present licences. The lease conditions need in our view to be reviewed and tightened to prohibit long wall mining and to protect the Sydney aquifer.

Thank you for the opportunity to comment.

Tim Frost
Coordinator SHCAG

My comments:
1. The wording refers to "continued mining", which, if I understand things, is misleading. The reality is that the application is for "increased mining" and this should be stated. I note that the department simply copies the applicant's words into the online cover sheet and in doing so perpetuating the misrepresentation.
2. The application states that there will be 65 full time equivalent jobs. I understand this is the approximate total FTE positions at the entire cement works. Not for the incremental investment/application. The application should only attribute the new jobs arising directly from the incremental investment. It is misleading to do otherwise.
Overall, I object to this application and request it not be approved. It will provide marginal increased benefit to the community but lead to significant incremental damaging impact on us.

This is my personal objection to Berrima Colliery Project MP10_0172.
I oppose any extension of production by Boral under existing use rights.
Boral have given stated their current production is 220,000tpa. To more than double this cannot be considered existing use.
Boral want to export coal, they have never exported from Berrima Colliery before, as written in a letter to Pru Goward MP from Mr Ross Harper (Boral executive)
Boral did not consult with residents before lodging their EA as is required by the Director General.
Boral wish to increase their stockpile at Loch Catherine by 15%, the runoff from this stockpile goes into the Wingecarribee River which is part of the major water source for Sydney water. Who is monitoring this?
Medway Rd, the only route to the Colliery is a local road and has been assessed by engineers as not being suitable for heavy vehicles as required by AUSTROADS. Boral wants to increase truck movements from 66 per day to 132. This endangers all who use the road and as far as I am concerned trucks should be halted until the road is up to standard to handle heavy vehicles. Medway Rd is only 6.5m wide, AUSTROADS requirements state it should be 10m wide. This is a local country road through a small village, lives will be at risk.
Medway Rd ends at the Colliery gates which are only 100mt from homes.
Boral also wants to increase production days from 210 per year to 340 per year. This is not existing use and I query the figures Boral has given.
(66 trucks x 27tonne load) x 340 days per annum = 605,880 tonnes per annum.......no where near their current production use or the output that Boral requests of 460,000tpa.
Residents have to put up with noise from trucks , loading of
coal and pit operations up to 9pm most nights.We find this excessive. Any added production will seriously impact residents.
Dust and air quality are a huge concern. Medway does not have town water and all the coal and road dust (the road to the stockpile is dirt) settles on our roofs and gets washed into our drinking water tanks. Doubling production doubles coal dust, road dust, runoff from stockpile, noise, traffic numbers and the risk of harm to anyone who uses Medway Rd.
For these reasons Boral should not be granted any increase in production in the formalisation of their existing use rights.

This submission is made in respect of Boral Cement Works DA No. 401-11-2002-i MOD 6 - Coal stockpiling and Berrima Coal Project Application number 10_0172