Dendrobium Mine Extension Project

This is my submission of objection to the DENDROBIUM MINE EXTENSION PROJECT (SSI-33143123)

I understand that this is the first time a cold mine has ever received STATE SIGNIFICANT INFRASTRUCTURE (SSI) STATUS. In my view the reasons for this are totally flawed.
The NSW government has declared the reason for this project being awarded SSI status is that the coal is essential for the continued operation of Bluescopes Port Kembla Steel Works. Bluescopes has however already made arrangements with other coal suppliers and also it has secured significant funding from the Federal and NSW governments to establish the transition to low or zero carbon steel.

There are many reasons I am against this project but the issues around green house gas emissions and water are my major concerns.

The IPCC has made it abundantly clear we must not open any new fossil fuel mines and we must close down as quickly as possible all existing mines if we are to prevent catastrophic climate change. The international energy agency has called for the urgent elimination of all technically avoidable Methane Gas emissions by 2030. Based on my research of the proposed Mine Extension the scope 1, 2 and 3 GHG Emisions means this mine extension will be a carbon and methane bomb and will make a complete joke of Australia's plan for net zero by 2050. It's approval will also be at total odds with Australia's commitment to the PARIS CLIMATE ACCORD. The Minister must show some courage and put the future of our children, their children and that of future generations at the forefront of his decision.

Sydney is the only major world city that has allowed Longwall coal mining in its public owned water catchment. Mine induced subsidence and the damage it causes to water corses and reservoirs is well recorded. The proposed mine extension is planned in the protected Special Area of the Sydney Catchment which supplies drinking water for 5 million people. Water NSW has stated there should be no mining in the Special Areas in the Sydney water catchment. If the proposed extension goes ahead it will leave the water catchment area worse off as it will negatively impact both water quality and quantity. There are also significant risk of pollution as water enters and exit mines, it picks up toxins and contaminants and this polluted water is discharged long after mining has ceased. Who will pay for and manage this situation long into the foreseeable future? The Sydney drinking water catchment is the absolute and essential infrastructure and must be prioritised and protected. This privately owned mine proposal must be rejected on this point alone.

Another area of deep concern is the impact on recently declared endangered Koalas and their habitat. In the EIS South 32 include no current survey of Koala numbers or locations, it contains no management plan for Koala Ecosystems destroyed for the establishment of mine infrastructure . The current EIS is too narrow. Koalas must be surveyed by experts not miners. Independent scientists must be allowed access into the Special Areas so as to independently assess Koala populations and their habitat.

In closing, the mines owners Illawarra Coal Holdings Pty Limited previous SSD extension proposal was rejected by NSW IPC. The new SSI proposal will mean that the NSW Minister for planning will be the sole decision maker. The fact that a single politician can arbitrarily decide the outcome of this proposal, potentially sidelining or even ignoring the advice of his department and many other experts is a very worrying situation. The message it sends is a complete lack of openness and that the applicant could have undue influence in the outcome. The Minister must seek out the advice from the IPC, his Department and all the other experts involved. That advice must be made public before any decision is announced.

see attachment

I strongly object to this project, not least for the following reasons which relate to my personal welfare as a resident of Wollongong.

Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. The proposed mining is in the protected Special Areas of the water catchment upon which 5 million people rely for drinking water. There should be no mining in the Special Areas of Greater Sydney Water Catchment; this is the stated position of WaterNSW and the legislated purpose of Special Area protection.

The impact of this mine expansion will not be neutral or positive, it will leave the water catchment worse off in terms of both quantity and quality of water. Offsets in the form of the payment of money cannot replace a drinking water catchment. No matter how much water is recycled, or how many desalination plants we build before the next drought, our drinking water catchment is essential infrastructure, and should be prioritised over a privately-owned coal mine.

The cracking and dewatering of watercourses, swamps and aquifers is expected to add the loss of many more millions of litres of water each day to the 10 million litres daily water loss from Dendrobium’s current and past mining. WaterNSW has been clear that mining in the Special Areas causes loss of yield to the reservoirs and the swamps and water courses that charge them.

This mine expansion impacts on the ability of the water catchment to collect, clean, and store water and negatively impacts on the sustainability and resilience of the supply of drinking water for Sydney and Wollongong, in terms of both water quality and quantity. Water that enters and then flows out of mines picks up contaminants along the way. Current measures for managing this problem have been shown to be insufficient to prevent impacts on waterways.

The risk of pollution events in the catchment is real, and is not adequately addressed in the Environmental Impact Statement.

Should this proposal be approved, the mine will still come within 1000m of the Avon Reservoir. It will result in water losses from Avon, which is the only source of water supply to over 310,000 residents and businesses in the Illawarra region. In dry years, the watercourses in the mined area that flow into Avon Reservoir are expected to totally dry up.

The southern catchment is vital to the sustainability and resilience of the supply of drinking water to Sydney and Wollongong. It supplies up to 30% of Greater Sydney’s water in normal times, and in times when Warragamba is compromised by water quality (for example the 1998 cryptosporidium and giardia water crisis, or the 2019/20 black summer bushfires which burned the Warragamba catchment) they may supply even more.

I strongly object to this project.

I’m lodging an objection to the Dendrobium expansion proposal because of the grave social and environmental impact of the project. The longwall expansion proposal is clearly not needed for the ongoing viability of the Bluescope steelworks.

Steel production at Port Kembla, and in Australia, is not reliant on the expansion of the Dendrobium coal mine. On 28th October 2021 I attended an online presentation by Bluescope about their proposal to reline the #6 blastfurnance. During this presentation Dave Bell the General Manager of Manufacturing for Bluescope stated they are upgrading their berths with faster ship unloaders so they can create gaps on the berth to get more raw materials in faster, so that they can continue operations if there are “difficulties with the (local coal) supply due the Dendrobium next domain not being approved”. Mr Bell concluded saying “we’ve got a bright future for the region and for steelmaking in Australia.” Bluescope can keep making steel by sourcing coking coal from elsewhere – be in Queensland, or further afield.
Please view the video here - slide 27 in which Dave Bell describes the berth upgrade. https://services.choruscall.com/mediaframe/webcast.html?webcastid=7AjLhNKm&securityString=I5w7eCBwormYJvEtgs4KtY8j

Furthermore in the Blast Furnance 6 Reline SSI application Bluescope highlighted that
"Recent and emerging disruptions to key commodity supply chains have highlighted the importance of the upgrade to three of the five berths operated by BlueScope, which is proposed as a key component of the No.6 Blast Furnace Reline Project. In particular, without the proposed upgrade, the berths will not be able to accommodate the increase in capacity which BlueScope will require to import the additional quantities of premium hard coking coal needed to replace 3-seam coal from South32’s Dendrobium mine, located in the Illawarra and currently transported by rail, once local supply ceases as early as November 2024. The current ship unloading infrastructure located at the berths is approximately 50 years old. By investing in state-of-the-art commodity handling facilities on these berths, BlueScope is ensuring its blast furnace operations will have security of raw material supply now and well into the future."
(Ref: “Commodity Logistics and Import Project Scoping Report by BlueScope Steel (AIS) Pty Ltd, produced by GHD on 3 February 2022 https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=PDA-36073707%2120220204T005757.754%20GMT)

Further comments are included in the attached PDF.

Having taken an interest in the proposal to mine areas 5 & 6, I supported the reasons given by the Independent Planning Commission (IPC) in refusing the project. My concern now is that there is essentially nothing changed in the nature of the new project but the IPC has been sidelined.

My understanding is the PIC was established to provide transparency for planning decisions made in an area that saw much corruption in the past.

I urge the minister to consider the loss of public faith in this case; a coal mine basically dictating the course of the planning approval process.

The following reasons as set out by the IPC still resonate with me:
• Damage to the water catchment resulting in permanent water losses impacting quality and quantity;
• Increased bushfire risk; my husband is in the volunteer rural fire service, I’d hate to think his job was made harder and his life put more at risk along with all of the other volunteers;
• Drier conditions in landscape that is established as important koala habitat;
• Damage to threatened ecological communities impacting biodiversity;
• Aboriginal cultural sites and connection to country.

I attach a letter from the Lane Cove Coal and Gas Watch objecting to this project.

I support the project

To the Honourable Anthony Roberts, NSW Minister for Planning,

I object to the Dendrobium Mine Extension Project (Sub-44830083) on numerous environmental grounds.
I am surprised we are even considering allowing Long Wall Mining in our catchment area when we know it will cause ground subsidence, hence loss of water and loss of water quality. No amount of money from Royalties or jobs created by this mine extension could justify risking our water supply permanently. When it boils down to it, our drinking water is a non-negotiable commodity, so please treat it as such.

Unless we act quickly to reduce our Greenhouse Gas Emissions, our food supply will also be at risk. Food is another non-negotiable commodity. It is difficult to grow food when the weather is unpredictable and we jump from one environmental catastrophe to another. In total, the Dendrobium Extension Project would result in about 88 million tonnes C O2-e of GHGs. NSW and federal governments are doing the right thing and have pledged millions of dollars to Bluescope Steelworks in Port Kembla to support transition to low or zero carbon steel. While that transition is happening, Bluescope Steel can and should source the metallurgical coal it requires from other coal mines that don't risk our water supply.

We need to protect remaining biodiversity. Damaging and drying out the upland swamps in the water catchment will risk biodiversity in this Endangered Ecological Community. Can we risk losing more Koala habitat for example? We have already cleared 80% of Koala habitat so they are now classified as Endangered. Where do we draw the line?

It is time to turn the tide of our self destructive tendencies. Rejecting this mine extension would show we are taking our responsibility for future generations of humans and other species seriously.

Thanks you
Yours Sincerely
Elena Martinez

See attached submission.

- I support this project because not only does it support me directly (through working at the mine) but it also indirectly supports my family whom all work at companies that rely on this project going ahead.

I object to the Dendrobium Extension Project (SSI-33143123) for the following reasons:
* The removal of 3.3 billion litres of water per year from Sydney’s drinking water catchment;
* Potential for mining induced subsidence causing cracking of the land on the surface – including rivers, creeks, smaller watercourses and swamps that feed our drinking water reservoirs – and subsequent water loss to the catchment, losing many millions of litres of water per year, more than doubling the water loss from our catchment due to mining operations;
* Future repeated incidents of coal waste sludge washing into creeks after heavy rain events, as occurred in August (reportedly 10 megalitres), killing frogs, fish and other wildlife, and posing an unacceptable risk to human health;
* Damage to critical infrastructure, including reservoir dam walls, the Lower Cordeaux Dam Project and WaterNSW’s Deep Water Access Project, and possible ground movement at the dam walls;
* Metal contamination including arsenic dissolving and leaching into the water;
* Expected damage to 25 of the 46 swamps in the mining area, allowing dry land species to take over, destroying Endangered Ecological Communities leading to localised extinction of the specialised flora and fauna contained within them;
* Increased sedimentation in waterways and increased likelihood of bushfire and erosion associated with the clearing of vegetation;
* Increased risk of bushfire through water loss;
* Intergenerational theft by burdening our descendants with a legacy of water loss and contamination in more unstable climactic conditions;
* Greenhouse gas emissions;
* Further possible damage to Aboriginal cultural heritage sites;
* Poor economic planning - responsible economic planning would seek to decarbonise our economy.
The IEPMC reports that the cumulative impacts of this proposal have not been reliably estimated and quantified. It is, under these circumstances, a potentially dangerous proposal and it should be rejected. The Government should also commence plans to phase out existing mining in the Metropolitan and Woronora Special Areas.

OBJECTION TO DENDROBIUM MINE JUNE 2022

I wish to object to the proposed extension of the Dendrobium Mine on the Woronora Plateau of NSW.

Dendrobium’s current and proposed future mining activities are located on the Woronora Plateau in the catchment areas of Cordeaux and Avon Dams. These dams are important contributors to Sydney’s water supply. Apart from the contribution of normal run-off, a major source of water inflow to these dams is the slow release of water from perched headwater swamps on the Woronora Plateau. These swamps are characteristically of shallow depth with a peat base. Longwall mining inevitably always leads to subsidence caused by tilting and cracking of overlying rock, and this will clearly result in drying out of these swamps. Thus, water inflow into these dams will be reduced. There is already well-documented evidence of this effect on the Woronora Plateau swamps above the Dendrobium Mine. In 2019, water restrictions had to be enacted in much of Sydney due to drought conditions as well as cracking from longwall mining (in the Lithgow area as well as the Woronora Plateau) in Sydney’s water catchment areas. Current climate research predicts that global climate change processes will lead to more intense and more frequent drought and flood events worldwide. It is very short-sighted to add completely unnecessary destruction of water supply to these stresses on Sydney’s population.

On a purely local scale, approval of this mine extension will also increase threats to the biodiversity and survival of some of Australia’s endangered species and ecosystems on the Woronora Plateau, for example the iconic and much-loved Koala population.

Global greenhouse gas emissions are increasing worldwide and the effects on the world’s climate are already obvious. Significantly more frequent and more intense occurrence of droughts, floods, cyclones (hurricanes and tornadoes) and bushfires are happening. World scientists predict that Australia and the northern hemisphere tundra areas will be the first and worst affected. It is claimed by many that Australia’s contribution to world greenhouse emissions is relatively small. This claim is patently false, when Australia sells enormous quantities of coal to China and India (two of the world’s large emitters). Therefore, a significant part of Australia’s real contribution to greenhouse gas emissions is directly attributed to these two countries instead of to Australia. However, whether Australia takes responsibility for its total emission contribution or not, the emissions are still happening and increasing.

With the well-documented effects of greenhouse gas emissions on global climate change, many countries and many private companies are working as fast as possible towards phasing out of fossil fuels in favour of renewable energy sources. There are two main reasons for this transition. One is economic, and this is one of the reasons for so many private companies making this transition. Another is the survival of world ecosystems, including both environments and species. This is critical to the survival of humans as a species, because humans depend on the availability of clean air, water and agriculture. For Australia to deliberately exacerbate their own problems of climate change in the short term, as well as risk the long-term survival of the world’s environment systems as we know them, is unbelievably stupid. Australia (or in this case the NSW Planning Commission) should not approve any future or extensions to current coal mining activities.

I am a member of the public, a retired Registered Nurse, and I am concerned particularly for the future of my grandchildren.

I want them to have the same kind of access to water that we have enjoyed. This will be a huge issue in the context of climate change. We should preserve our water catchments. This proposed expansion is not consistent with current land use of the area as a water catchment.

The impact of this expansion will be negative.The quantity and quality of water will be affected. Financial offsets won't replace drinking water. Our drinking water catchment is essential infrastructure; it should be given priority over a privately-owned coal mine.

This mine expansion will affect the ability of the water catchment to collect, clean, and store water and will have a negative impact on the sustainability of the supply of drinking water for Sydney and Wollongong, in terms of both water quality and quantity.

Water that enters and then flows out of mines picks up contaminants along the way. Current measures for managing this problem have been shown to be insufficient to prevent impacts on waterways.

The risk of pollution events in the catchment is real, and is not adequately addressed in the Environmental Impact Statement.

Should this proposal be approved, the mine will still come within 1000m of the Avon Reservoir. It will result in water losses from Avon, which is the only source of water supply to over 310,000 residents and businesses in the Illawarra region. In dry years, the watercourses in the mined area that flow into Avon Reservoir are expected to totally dry up.

The southern catchment is vital to the sustainability and resilience of the supply of drinking water to Sydney and Wollongong. It supplies up to 30% of Greater Sydney’s water in normal times, and in times when Warragamba is compromised by water quality (for example the 1998 cryptosporidium and giardia water crisis, or the 2019/20 black summer bushfires which burned the Warragamba catchment) they may supply even more.

The discharge water from the mining will also need to be managed and treated, perhaps in perpetuity, and this is another burden that we leave for future generations.South 32 acknowledges that the mine will continue to discharge water long after that mine has closed. Their own estimate is that the mine will discharge 13 to 15 litres PER SECOND, for the foreseeable future, and certainly long after the mine has closed.

South 32 have said that the size and location of longwalls in Area 5 is necessary for the economic viability of the mine. They provide no evidence or explanation as to why the profits of a private company should be prioritised over the drinking water supply of people living in Sydney and Wollongong.

Dear Sir/ madam,
I have lived on the side of Mount Kembla for the past 25 years and this mine concerns me greatly.

I am concerned about the effects on the land, the waterways, the community and the Indigenous cultural sites that this mine would affect.

- Water catchment: The mine is in the water catchment and inevitable subsidence could damage the watercourses and swamps that feed into the catchment- the risk of pollution (sediment/ metals) and water loss is unacceptable for the environment and human health.

- Proximity to Aboriginal sites: There are 31 nearby cultural significant sites. These have been identified in the EIS and by the local Indigenous community. The mining will affect the songlines and storylines of the area and further destruction and abuse of the land by colonial influences.

- Natural ecosystems and animals: The mine will definitely impact water systems and swamps, as well as land due to outfalls and run off to the ocean. Further, Koalas were once abundant in the Illawarra and we should be encouraging their return, not destroying / contaminating more of their habitat. There are so many examples in the Illawarra of disused mines that have never been rehabilitated and the community and ecosystems have to put up with those effects forever.

- Coal-fired power is outdated: Australia needs to phase out coal-fired power and other fossil fuels embrace renewable energy (not gas-fired). We need to be moving towards zero carbon ways of creating power and energy. Opening / expanding mines is a step backwards and away from the crucial targets for carbon reduction.

- State significance development: This development is not state significant – Bluescope has other options for coal and is moving towards zero-carbon steel manufacture anyway. Its very suspicious that this mine, for the first time ever, a mine has been named as State Significant.

Why should the financial greed of a mining company be considered more important than the Indigenous people, local community’s health and the natural environment? This is 2022, we know mining is destructive, needs to be phased out and climate change is a very real and imminent problem.

The state government needs to be responsible for their actions in approving development such as this which will definitely be destructive to the community and environment in many ways.

Regards
Professor Justin Yerbury AM

The Independent Planning Commission in 2021 released findings that the Dendrobium Mine Extension Project would result in permanent and irreversible damage to both Avon and Cordeaux heights water catchments. Both Sydney and the Illawarra have previously had water restrictions in recent years and this proposed project risks reducing the capacity of our catchments further. The extension of the mine will only provide a boost of 50 extra employees to the company and extends the current 650 workforce up to 2041. Saving 700 jobs does not equate to permanent impacts that could affect water security for both the Illawarra and Sydney.

- The project will produce metallurgical coal, a critical ingredient to steel making
- The project will create 100 project construction jobs and 50 new operational roles
- The project will secure employment of 650 people
- The project will continue South32 IMC's $240 million annual spend with local businesses
- Compared to the previous application, the project has a 60% reduction in the longwall mine area preserving the water catchment.

I am writing to oppose the Dendrobium Mine Extension Project.

After recent revelations that South32 was 'coached' by the Planning Dept over Dendrobium application to gain status as State Significant Infrastructure (SSI) the whole premise for this application fails.

It showed that Bluescope Steel had already made provision for purchasing and transporting coal from other mines as well as having secured considerable Federal and NSW Government funds to investigate transition to low- or zero-carbon steel production.

This means the Port Kembla steelworks are NOT reliant on this expansion for their longevity.

So the reasons the IPC rejected this application in February 2021 are still valid and important despite the smaller expansion proposal of this project.

I am concerned about:

- the risk of damage/pollution/long term loss to Sydney and Wollongong’s drinking water catchment. Water is much more important to many many more people and families and generations than the jobs of the small number who may get them if this proposal was to go ahead.

- the mining of more coal – it goes against the NSW governments own net-zero aspirations, it could make the mine one of the four worst emitting mines in the country. The transition to green hydrogen will make this expensive, destructive and needless. We could do this without more coal mining.

It is short term thinking that does not serve the community of wollongong, sydney and definitely not the global citizens who have to live with the climate change effects generated by these unnecessary emissions.

PLEASE REJECT THIS!!

Please see attached our WAG submission with our detailed case for not approving this revised Dendrobium extension project SSI-33143123
Brian Williams
President
Wilton Action Group (WAG)

Please find the attached

Dear Minister Roberts,
Please don’t approve the expansion of the Dendrobium mine because it will destroy vital natural infrastructure that is necessary for the supply of our clean drinking water.
The area in question has vital wetlands that are imperative to protect to help
• mitigate the risks of climate change
• reduce a greater bush fire risk
• mitigate flood by helping to soak up excess rainfall predicted with climate change
• release water in times of drought to help the biodiversity and ecosystem survival
• protect Wollongong from the devastating impacts of changing weather patterns causing fire and flood
• protect endangered koala populations by helping to maintain their ecosystem
• filter and provide clean drinking water for our Illawarra community

Please consider the future for our children and grandchildren and not just lining your pockets for the immediate future or the next 20 years. Our children and grandchildren will need water beyond the next 20 years.

Most importantly, the fact that your department coached South 32 to have the original decision overturned reveals a severe bias and lack of judgement. I therefore request that no new documentation from South 32 be used in making your decision. To use this coached information would establish an impropriety exemplar and demonstrate a lack of impartiality.

Please reject the Dendrobium mine expansion proposal.