Bylong Coal Mine

Bylong Coal Project: SSD 14_6367

I strongly object to the opening of a greenfield coal mine in the pristine and highly fertile Bylong Valley.

It makes no sense to start coal mining in this new region at a time when world demand for coal is declining (despite contrary claims made by the International Energy Agency). Kepco can more easily (and probably at less cost) meet its coal security needs by purchasing one of the established mines in the nearby Hunter Valley that have recently been closed or put into care and maintenance. There is no need to extend the pollution associated with coal mines into this highly productive and highly scenic area.

I have worked in tourism around all of Australia for over 30 years and confirm the Sydney Morning Herald's judgement that the Bylong Valley is one of Australia's top ten scenic drives. It is a stunningly beautiful valley. The EIS does not even mention the negative impact of the mine on the tourism, actual and potential, of the Bylong Valley.

I clearly remember a state election where Barry O'Farrell promised to protect high value agriculture. The Bylong Valley is a prime example of where (yet again) an election promise has not been upheld. The Gateway Process demonstrated this project only met one of twelve criteria for an acceptable mine, but that did not stop the project. I now understand that this EIS has failed to address some of the issues raised in the Gateway process, viz: cease to pump levels and issues re agricultural land. How come the EIS was allowed to go on exhibition without at least addressing all the issues raised in the Gateway process? This is just another demonstration to the general community that all these so called safeguards and conditions placed on mines are basically meaningless.

I understand there are a number of experts giving detailed submissions on the many flaws of the EiS. I can only give a personal perspective from my own observations of the negative impacts that already this project has had on the community and lives of people in the Bylong Valley.

The EiS makes light of the social impact of the mine. The project already has had negative impacts. Kepco land buyouts mean the community is no longer large enough to continue to run its highly successful and much loved annual Mouse Races, a unique rural Australian event that over its 25 years has managed to raise over $500,000 for its community.

Where previously there were about 8 agricultural enterprises, some quite large and employing a number of people, there is now only one land manager. Where in the EIS is there an adequate accounting of the loss of this rural employment? Fewer people working/managing the land has resulted in a substantial increase in feral animals, wild dogs in particular. I know of one land owner who has had to change the stocking of his land from sheep to cattle because of this.

Depopulation has caused the school to close, so there is the loss of another job. Depopulation has had negative impact on the local rural fire brigade - another negative impact not mentioned in the EIS.

Early buyout of land by Kepco has resulted in inadequate mapping of BSAL land. Bylong Station has historically (over 120 years) been an important horse breeding property but was not included in the mapping because of Kepco's purchase. I find it amazing that simple ownership immediately changes the agricultural potential of the land!

Tarwyn Park is of major significance in terms of landscape management. Natural Sequence Farming has revolutionised water management within the landscape, yet this showpiece and home of NSF will be negatively impacted by an open cut coal mine 300m from the boundary. The mine will result in 1-1.5m drawdown of groundwater levels. NSF is all about raising the level of the groundwater so claims that Tarwyn Park will be unaffected are totally unbelievable.

I question the all the figures presented in the economic section, given the one about the expected corporate taxes that will flow is so unbelievable. Recent press has highlighted how well international corporations manage to dodge their tax liabilities to Australia. Why would Kepco be any different? especially given it is selling to the coal to itself - an accountant's dream situation! Nor could I see any real accounting of the loss of jobs and social (including mental health) and environmental costs - and , oh, what about health costs? The health cost of coal is now well documented, and most recently in the nearby Hunter Valley.

I will not go into details abut points that others will be making:
* Long-term impacts on prime agricultural land and water systems in the Bylong Valley are unacceptable and will not be mitigated through proposed offsets and rehabilitation
* A significant area of prime agricultural land will be destroyed and it is difficult to believe BSAL land can easily be reproduced. Farmers would have done that themselves if it was so easy!
* The river system is over allocated and local farmers will lose important water supply as impacts on groundwater and surface water will be significant.
* The biodiversity impacts are unacceptable. I do not understand why the mining industry can continually decrease the already minute percentage of remaining critically endangered Grassy Box Gum Woodland. This is unacceptable. Why is there no cumulative accounting of the yearly decimation of this ecological community? For years now, once or more a year I write a submission objecting to further clearing of this EEC, but is still goes on.
* Over half the identified Aboriginal cultural heritage sites will be negatively impacted.
* Important European heritage, including the Catholic Church Cemetery, Upper Bylong Public School and a number of historic homesteads and farm buildings will be destroyed in the open cut.

The Bylong Coal Project should not go ahead.

I wish to express my concerns re the Bylong Coal Project
Water issues are a major concern... The volume of water required for the mine is not sustainable... The Bylong river catchment is already stressed by present allocations and the mine proposes to use 1942 ml/yr
The loss of prime agricultural land is unacceptable..mine footprint being 2,875 hect NSW should be protecting the prime agricultural land
Tarwyn Park has been extremely important in demonstrating to land owners how the land can be managed more effectively
Grassy box gum woodland will be destroyed Large stands of grassy box woodland has been destroyed by mining in close geographical areas ,

Well here we go again ! How can we repetitiously put mining projects before farming, environment and community devastation. After all, surely this mining project should be shelved after the notorious Eddie Obeids' initial involvement
How can we in our right minds support an overseas company to come in and destroy good farming land for quick immediate gain, royalties to our government , at the expense of what has to be something far more sustainable and important in the long run.

It is disgraceful that we continue along this path, without having done the necessary scientific studies to negate any negative impacts to the underground water resources in particular, never mind the long term impacts to the immediate community.
Instead of continuing with this quick gain at any expense drive...it is definitely time to consider backing our agricultural industries, something China is happy to support and something which in the long term is essential to Asia & world food production and an industry which obviously is totally reliant on water...something we have been negligent to protect and respect as one of the most valuable commodities of all times.
In such an arid country as ours, to completely disregard the significant and revealing and enlightening work such as that endured and painstakingly carried out by Peter Andrews in the Bylong Valley, work which has been acknowledged far and wide as being ground breaking, is ignorant and at best negligent. For his work indicates the vital role of water and how it can transform & sustain a landscape instead of undermining it !
Again this is a valley of extreme beauty and it has become evident again that what is happening is negating the opportunities for tourism and destroying the lives of another community and the lives of hard working and committed farmers to pursue any agricultural endeavours.
Okay big royalties, but at what cost ultimately !!

1. The predicted long-term impacts on prime agricultural land and water systems in the Bylong Valley are unacceptable and will not be mitigated through proposed offsets and rehabilitation. The renowned Tarwyn Park natural sequence farming processes will be destroyed.

2. A significant area of prime agricultural land will be destroyed: the mine footprint will disturb 2,875 hectares (ha) of land including 440 ha of Bioregional Significant Agricultural Land (BSAL), 260 ha being destroyed in open cut, plus 700 ha of mapped Critical Equine Industry Cluster land. The proposal to replace BSAL at another location is untested and high risk.

3. Impacts on groundwater and surface water will be significant. The highly connected alluvial aquifer system within the stressed Bylong River catchment will have predicted peak losses of up to 295 million litres per year (ML/yr). Loss of base flows to the Bylong River is predicted to be 918 ML/yr. The mine proposes to use up to 1,942 ML/yr which is over 75% of the annual rainfall recharge. The river system is over allocated and local farmers will lose important water supply.

4. The mine disturbance area has very high biodiversity values that will not be mitigated through the proposed offset arrangements. Nationally endangered species recorded in the area include the Brush-tailed Rock Wallaby, New Holland Mouse, Regent Honeyeater and Spotted-tailed Quoll. Three entirely new plant species were recorded. A significant area of critically endangered Grassy Box Gum Woodland will be destroyed along with habitat for 17 threatened birds and 7 threatened plants.

5. The area has Aboriginal cultural heritage significance: 239 sites were recorded in the study area with 25 regarded as being of high local or regional significance (including an ochre quarry, grinding grooves and rock shelters); 144 sites have been identified at risk from mine impacts with 102 within the open cut area.

6. Important European heritage, including the Catholic Church Cemetery, Upper Bylong Public School and a number of historic homesteads and farm buildings will be destroyed in the open-cut. The social impacts on the Bylong community have already been devastating.

The coal industry is in terminal decline. Coal kills. Coal mining is responsible for causing irreparable damage to landscapes, human health and the whole environment. The development of any new coal mines must be stopped. To consider mining for coal in an area like the Bylong Valley is doubly outrageous.
This application must be disallowed.

the corrupt practices surrounding a lot of the granting of licences alarms me
- we have plenty of capacity for coal already
- our reliable farming land is limited

I cannot believe our government will allow this beautiful place to be destroyed to make another country rich. Shame on you all for destroying what does not belong to you

We need farmland and agriculture more than we need any more coal mines or csg industries. We have cleaner, greener alternatives that do not necessitate the destruction of farmland but the only alternative we have for our farmland is to import what the land can no longer produce. This is unsustainable and threatens our food security.

This project is not in the best interests of the people of NSW. The small number of jobs and the royalties the government receives are short sighted benefits.

The longer term benefits of ending mining here are instead farming, bushland and authentic Australian local communities. Where better to raise children? Protect our wildlife? Age with dignity?

I'm protesting about the mining and fracking in upper bylong valley because of the pristine nature of the area and am not happy about the removable of the remains from the bylong Catholic cemetry lncluding my grandparents (Hugh France's and Susan Cobrey)

I am not against progress but Coal Mining???? Is this not the opposite to progress. Investing the same amount of money in solar; wind; etc types of power would have a longer lifetime benefit to all. I believe that coal is a waning industry throughout the world. So......??? Destroying even one tenth of this area to mine coal resulting in loss of valuable agricultural land and habitat for our wildlife is backward thinking on the part of our government. Please listen to all the objections and do not allow this project to continue. Yet another sell out to foreign company.

The formal submissions on behalf of Timnath Pty Limited are provided as an attachment, below. In addition, the submission includes Annexure A being a DVD movie which could not be attached and have been sent with a hard copy of the submission by Express Post.

4 November 2015

Bylong Coal Project: SSD 14_6367

Running Stream Water Users Association objects to the proposed coal mine in the Bylong Valley.

We question why a coal project that met only one of 12 criteria under the Gateway Process was even allowed to progress to submission of EIS stage. We note that at least two of the Gateway issues are not addressed in the EIS:

* there is no assessment of cease to pump limits
* there is inadequate assessment of agricultural land issues.

How was this EIS passed as suitable for exhibition? This just confirms the widely held view among the community that the Gateway Process is a meaningless farce.

This project, even in its proposal stage, has already had major negative impacts:

* Inadequate mapping of Bioregional Significant Agricultural Land (BSAL) from the start. One of the historical horse breeding properties of the Bylong Valley was not included in the mapped BSAL, simply because it had already been sold to Kepco. Just before the mapping was done, the owner decided it was too risky to carry out his planned expansion of operations and chose to do so elsewhere. The quality of the land had not changed. The subsequent loss of investment and jobs in the valley directly caused by this coal project does not rate a mention in the EIS.
* Decimation of a once vibrant community. The most graphic proof of this is the cessation of the iconic rural event, the Bylong Mouse Races. Over 25 years, the Bylong Mouse Races raised over half a million dollars for the local and wider community. However, two years ago, due to property buyouts by Kepco, there was no longer sufficient community members left to run the event. Where is this impact mentioned in the EIS?

There will be significant impacts on surface and groundwater. The river system is over-allocated and, as mentioned above, the EIS fails to address the issue of cease to pump limits. The predicted peak losses of up to 295 million litres per year (ML/yr) in the highly connected alluvial aquifer system within the stressed Bylong River catchment is unacceptable, as is the predicted 919 ML/yr loss of base flows to the Bylong River. Local farmers will lose vitally important water supplies.

The predicted drawdown of groundwater levels caused by the open cut immediately adjacent to the renowned `Tarwyn Park' property will destroy the groundbreaking work done there. Natural Sequence Farming is about raising the level of groundwater in the landscape. This mine project does the opposite, so we fail to see how `Tarwyn Park' will be protected.

The mine proposes to use up to 1942 ML/yr, which is over 75% of the annual rainfall recharge. This is not sustainable. In addition, the EIS fails to address how adequate water will be available for the mine during the inevitable `prolonged dry periods', as we now call droughts. We would expect at least two, if not three droughts during the proposed life of the project.

A significant area of prime agricultural land will be destroyed: the mine footprint will disturb 2875 ha of land, including 440 ha of Bioregional Significant Agricultural Land (BSAL), 260 ha being destroyed in open cut, plus 700 ha of mapped Critical Equine Industry Cluster Land. To present this as a small percentage of the state's overall high-quality land is disingenuous. For all its vast size, Australia has very little high-quality agricultural land and 200 years of European settlement has resulted in the degradation of large swathes of it. We cannot afford to lose any more. Food production must be given priority over mining, especially when the proposed resource can be sourced elsewhere and in areas already degraded. It makes no sense to add further to degraded land. The proposal to replace BSAL at another location is untested and high risk.

The touted economic benefits of the proposed mine are of dubious value. We question the assumption that there will be some $302 million benefit to the state from corporate taxes. We are not so naïve to think that an overseas corporation, selling to itself, will in fact be paying corporate tax at the full rate - if at all.

When quoting economic figures, the EIS does not compare like with like: it compares the annual value of agricultural production against the total economic value of life of the mine. Given that agriculture has been producing economic benefits in Bylong Valley for nearly 200 years and, if left undisturbed by a coal mine, can continue to produce for hundreds more years, such a comparison is invalid. We reject such short-term comparisons. Food production for the centuries to come is more important than a few years of royalty income.

Jobs are touted as a reason for this project to go ahead. However, there is no tally given of jobs lost due to agricultural land being taken out of action, nor the jobs lost in relation to the loss of the local school. These are all long-term (decades and decades) jobs as opposed to short-term construction jobs and slightly longer-term, but equally impermanent mining jobs. Viewed over a longer time frame, the economic benefit is not so great. Furthermore, the full economic costs of the social dislocation, loss of biodiversity and cultural heritage, both European and Indigenous, have not been accounted for.

Grassy Box Gum Woodland has been declared a critically endangered ecological community but every year more of it is destroyed with impunity by mining operations. Approval of this mine makes such declarations meaningless. Why is it permissible to destroy yet more Grassy Box Gum Woodland, along with habitat for 17 threatened species of bird and seven threatened plant species? Ecological systems are not readily rebuilt and we fail to see how conserving another area of what already is supposedly a protected community is a valid offset.

The proposed offset arrangements do not adequately compensate for the loss of the high biodiversity values of the mine disturbance area. Nationally endangered species recorded in the area include the Brush-tailed Rock Wallaby, New Holland Mouse, Regent Honeyeater and Spotted-tailed Quoll. Three entirely new plant species have also been recorded.

The EIS fails to address the devastating social impacts on the Bylong Community. We have already mentioned the loss of the Bylong Mouse Races due to depopulation caused by Kepco buyouts. A once vibrant rural community has now been decimated. The depopulation has ongoing impacts - lack of feral animal control and inadequate numbers to run the local fire brigade are just two of the most obvious negative impacts.

This is a highly flawed EIS and we understand there will be a number of in-depth critiques given by experts that will prove this.

This mine should not go ahead. The predicted long-term impacts on prime agricultural land and water systems in the Bylong Valley are unacceptable and will not be mitigated through proposed offsets and rehabilitation. The renowned Tarwyn Park Natural Sequence Farming processes will also be destroyed.

We suggest that Kepco can fulfil its coal security needs by purchasing one of the nearby coal mines in the Hunter Valley that have been recently closed or been placed into care and maintenance. This will save Kepco significant infrastructure costs and save Australia the significant costs of loss of prime agricultural land and significant biodiversity and of major social dislocation.

Mining in the beautiful Bylong Valley will have long-term effects on prime agricultural land and water systems. Impacts on ground & surface water will affect local farms and production and cause long-term problems with the alluvial aquifer system. Nationally threatened species live in this area including the Brush-tailed Rock Wallaby and the Spotted tailed Quoll. 17 threatened species of bird and 7 threatened plants grow in this area. This proposal by KEPCO should not go forward.

I 100% support this community to reject this coal mine. Coal mining is not sustainable and we as the people must protect land and water and makes renewable choices for jobs and power. People wishing to protect there land that they love and look after are not protesters they are protectors. Stand strong. I reject this coal mine because it dose not serve our future generations.

There should be a ban on ALL new coal mines worldwide. What do the politicians not understand australians and people across the globe DONT want to continue using coal!

The predicted long-term impacts on prime agricultural land and water systems in the Bylong Valley are unacceptable and it is nonsense to suggest that mitigation is possible through proposed offsets and rehabilitation. It is impossible. And the renowned and invaluable Tarwyn Park natural sequence farming processes will be destroyed.

Bylong valley is a crucial part of the Hunter Valley, to put in a mine and kill off the balance that is in place there will have untold effects on the local populace and tourism industry.

Dear Manager, Planning and Environment

Proposed KEPCO Bylong Valley thermal coal project

I submit that approval of this thermal coal project would either be a dereliction of duty or an abysmal failure of the current planning processes in New South Wales.

The world is awash with thermal coal and the steady and now several year long decline in prices has shown. China, the major consumer, has been reducing imports and usage, India is ramping up its internal production and major long term international coal miners are reviewing and reducing their production and investment levels.

Climate change is with us now and the important countries of the world and the major commercial interests are planning to take action. (Australia seems to have taken itself off the list of responsible international citizens).

China itself is a leader in renewable energy technologies and inexorably and inevitably, the cost of renewable energy is becoming more than competitive, even ignoring the subsidies to mining and the external disbenefits not taken into account in the costs of carbon-based energy.

Yet the Kepco proposal would have us believe that the price of thermal coal over the long term will produce a viable mine life of 23 years, with associated economic benefits for the state, profits for the company and sufficient resources for on-going environmental protection, emergency mitigation and ultimate mine site rehabilitation.

Your Secretary's requirements ask that the company application take into account the economic considerations from the point of view of New South Wales.

I submit that it is not sufficient for you to place faith on the so-called discipline of the market, in either its financing operations or in investment decisions in your consideration of economic benefits. The GFC was largely caused by supposedly professional investment companies making hugely risky loans, using not their own capital, but the investments of others. Short term profit and outrageous bonuses was the prevailing force and very little if any has changed today.

Companies in both the private and public sectors are also hardly without major blemish when it comes to ill-advised investments. BHP, NAB, ANZ, Woolworths, Leighton are just a few examples of companies that have managed to waste billions in the interests of others than shareholders. The assumptions on coal price and mining efficiency pertaining to the proposed Adani coal mine in the Galilee Basin in Queensland are laughable.

The economic benefits, in terms of employment and royalties, is also a challenge for you. Unless overall demand for NSW thermal coal rises, then any alleged greater efficiency in this mine will result in lower demand from existing mines with attendant loss of employment and royalties in those places.. And if the mine is likely to be less efficient than existing NSW operations, its chances of viability are even more questionable.

So, any governmental consideration of either economic benefits or of environmental protection and or/mitigation must weigh up the likelihood of those undertakings being delivered or the benefits realised, as well as the downside risks.

In my view, the 25 year price outlook for thermal coal makes the delivery of overall net economic benefits to NSW and the capacity of the company to earn a profit as well provide all the resources to protect the environment, manage the inevitable environmental breaches and deliver ultimate rehabilitation is at best a small chance. Far more likely is economic collapse and environmental vandalism.

If the processes result in approval of this mine, then fair and reasonable accountability to the residents of NSW is that you publish your independent assessment, not KEPCOs, of the prospects of an economically viable mine, taking into account the global prospects for thermal coal, and importantly, the likely efficiency of this mine compared to all the existing thermal coal capacity in NSW. If you cannot do that, and make the results public, then your process is fatally flawed.

If you want to place faith in market discipline, then a perfectly reasonable approach would be to require KEPCO to pay, upfront, the cost of the resources to perform all of its environmental promises. Otherwise, the public of NSW is being sold a scam, intentional or otherwise.

And even if you assess the likelihood apply even some of the above tests of likelihood and nature of the benefits, there are still all the disbenefits to the Bylong Valley and its residents and catchments areas to be taken into account. I do not know the valley or of the inevitable damage caused, so will leave that issue to others.

But you must be sure, if you are to give approval, that the likelihood and the quantum of net benefits to NSW very substantially outweighs the inevitable costs to the community.

I find this absolutely gutwrenching to have to think KEPCO could even think to go ahead with this. This area was my home and those buried are my direct family (grandfather and grandmother) seriously have a look at the impact you will have on our family history