Dendrobium Mine Extension Project

Available as required

It continues historical significance of coal mining in the region

I would like a job

Future job prospects for the community

Please see attached letter.

Job security for future

Supporting the project

My objection is based on the known damage to the water catchment that is anticipated as a result of this project. Even though some reductions have been made, the remaining damage is extreme and not acceptable. The arguments made in favour of the expansion are flawed, in that the steelworks is well prepared to function without this coal, and economic gains can be made in any industry - there is no need for coal to be supported just on that basis.

This proposal is shameful. Think of our children and reject it. It should not be considered State Significant infrastructure. Bluescope Steel had already made provision for purchasing and transporting coal from other mines, and has also secured considerable Federal and NSW Government funds to investigate transition to low- or zero-carbon steel production. 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. According to DPIE’s report on South 32’s previous unsuccessful application to expand Dendrobium Mine, as water courses fracture due to mining induced subsidence, metals will be dissolved and leach into the water. This will lead to an increase in metals in the water courses and reservoirs. I am also deeply concerned about the damage to Aboriginal Cultural Heritage, threats to the Koalas, impact on other vulnerable ecosystems, increase risk to bushfire, unsustainable jobs, and of course the massive and long lasting threat to the climate. Say no to this proposal.

To whom it may concern,

I strongly oppose the Dendrobium Mine Expansion as scientific research, the reports provided by South 32 for the proposed expansion, and South 32’s previous actions have demonstrated that this project would result in unavoidable and irreversible environmental and socioeconomic consequences. South 32 seek to mine in the Special Areas of the Greater Sydney Water Catchment. Special Areas are established to restrict activities that threaten the protection of water quality. Long wall mining is widely known to contaminate water sources where South 32 already has a history of threatening local water quality. For example, cracking from South 32’s long wall mining activities resulted in the contamination of the Waratah Rivulet in 2011, near Helensburgh, and the Eastern Tributary Stream in 2019 which flows into Woronora Dam. More recently, South 32 was fined $15K for water pollution by the Environment Protection Authority in April 2021. The proposed actions of South 32’s mine expansion would result in further pollution events that would threaten the viability of our drinking water supply and the safety of over 5 million people who rely on the Greater Sydney Water Catchment. Mining activities should not occur within these Special Areas. This is in agreement with WaterNSW’s position.

Long wall mining activities result in subsidence which fundamentally disrupt surface flow and groundwater hydrology. The impairment of these hydrological processes directly threatens the health of endangered and ecologically significant upland swamp communities. These ecosystems host significant biodiversity, capture carbon and store and filter water. When long wall mining damages these habitats, they cannot be restored. These ecosystems which stand as a natural solution to climate change are lost. It is critical that the degradation of these swamps does not continue.

South 32 also fails to address the notable cultural desecration they propose to undertake as there are 31 Aboriginal Heritage sites in close vicinity to the proposed works where 6 of these are directly above the longwalls. These Aboriginal Heritage sites include irreplaceable shelters with rock art and axe grinding grooves which inform First Nations' identity, Dreaming and wellbeing. It should also be stressed that this cultural desecration is not just about the specific sites recognised by the state. This entire area is of significant cultural value to the local Aboriginal community.

The local community and scientific experts have fiercely opposed the Dendrobium Mine Expansion from the start. Despite this clear opposition founded on valid concerns, the project was undemocratically declared State Significant Infrastructure where the NSW Minister for Planning now has the final word on the proposed expansion. It is the first time in the history of NSW that a mine has been declared as SSI. It is incredibly dispiriting and distressing to learn that the NSW Planning Department coached South 32 to overstate their relationship with BlueScope Steel when applying for SSI approval. I hope this clear conflict of interest is appropriately and transparently addressed when the department provides recommendation to the Minister. I implore the department and the Minister to keep the future of younger generations at the forefront of their minds. It is significant to the state of NSW, the state of a safe water supply, the state of the environment, and the state of future generations that the mine expansion is rejected.

Thank you for your time.

Kara Tuck

Please find attached some preliminary comments on behalf of NPA NSW, in anticipation of further comments as soon as possible.
Thanks, Peter.

The Dendrobium Mine extension is not essential to the continued operations of the steelworks at Port Kembla. It puts our water catchment at risk, and dewaters bushland, resulting in a risk of worse bushfires. The Environmental Impact Statement does not discuss the impact of the dewatering of the bush on bushfire risk, or the climate impacts of bushfire risk, as required by the SEARS. The Environmental Impact Statement does not detail what the mining company plans to do to prevent problems with sediment dams that may occur as a result of extreme rainfall events. This mine extension will result in the loss of millions and millions of litres of our drinking water. For considerably less than a thousand jobs, at a time when many industries don't have enough workers, and there are some very exciting opportunities to transition workers from this mine to jobs in low or zero carbon steel, offshore wind farms, improved public transport, community renewable energy infrastructure, the construction of affordable housing, and many other urgently needed projects, we don't need to risk our catchment for this mine.

Please see attached file

Protect Our Water Alliance recommends that the proposal to mine Area 5 be rejected, as the project offers no benefit to the people of NSW that cannot be achieved by existing concepts such as offshore wind farms, green hydrogen, low or zero carbon steel and recycling projects. The mining company itself has shown that its mine extension will impact the catchment in such a way that it will reduce both water quantity and water quality. This reality must be at the heart of the decision making process. This project will cause irreversible damage. And it offers no benefits that cannot be achieved by other means.

SUBMISSION RE: DENDROBIUM MINE EXTENSION PROJECT (SSI-33143123)

Thank you for the opportunity to make this submission.

I oppose the revised proosal by mining corporation Illawarra Coal Holdings (ICH) for expansion of the Dendrobium mine in Sydney and Wollongong’s water catchment for the reasons that the previous proposal was rejected by the Independant Planning Commission and more.
- Coal mining is inevitably accompanied by the leakage of methane into the atmosphere. This greenhouse gas is 28 times more potent than CO2 and when it does break down it converts to CO2. As both NSW and the Australian Government, in line with most developed nations, have committed to net zero emissions by 2050, how can it be sensible to allow expansion of mining into a coal seam that based on the average Scope 1 emissions coud become the fourth highest greenhouse gas emitter in NSW with those emissions being mostly methane? Methane will continue to be emitted long after the proposed closure of the mine in 2041
- Not only is the expansion of the mine into the water catchment (a situation apparently unique to NSW) but into special protected areas of the catchment where its operations are the most likely to cause harm free from public scrutiny.
- ICH admits that its long wall mining operation will cause ground level subsidence of two and a half to three metres. Given the size of the tunnels and the track record of the company which was fined by the EPA in 2021 for subsidence, and the near impossibility of filling deep cracks or restoring original water flows or habitat at ground level it’s logical to assume that subsidence will be a major problem. Subsidence will damage water courses and drain some of soaks which feed other water courses which in itself should be sufficient reason not to approve this mine expansion let alone the increased risk of wildfire. Minister for Planning and Homes, The Honourable Anthony Roberts and staff of the Planning Department please remember the impact of the millennium drought on Sydney’s water supply and expect that even worse droughts will follow this current period of higher than average rainfall. Payment by the company for lost water harvesting doesn’t create more water for Sydney and Wollongong’s rapidly growing population.
- Subsidence not only reduces water availability for harvesting but damages and often destroys habitat. Habitat is further destroyed by land clearing associated with mining infrastructure such as a new adit, coal dust pile and new access roads. The latter also introduce weeds, fungal diseases and kill wildlife.
- Such vulnerable wildlife includes koalas which are now on the endangered species list. 90 hours of spotlighting mentioned in the application is grossly inadequate to assess the number of koalas in Area 5.
- The recently released IPCC report titled Climate Change 2022: Impacts, Adaptations and Vulnerability, Summary for Policymakers Section SPM.D.4.2 states “Protecting and restoring ecosystems is essential for maintaining and enhancing the resilience of the biosphere (very high confidence). Approval of the ICH proposal is not consistent with protecting ecosystems, rather it is seriously endangering an ecosystem.
- In response to the IPC’s rejection of ICH’s previous proposal, Bluescope announced that an adequate supply of coking coal was assured if the Dendrobium extension was not to proceed. Bluescope is receiving significant government funding and strong shareholder support to move towards the rapidly developing technology of green steel production using hydrogen as a heat source. Why needlessly jeopardise the water supply of Sydney and Wollongong?
- Employment is important, but this time of low unemployment provides alternative work opportunities lasting beyond 2041. No evidence is provided to support the claim that failure to approve this mine extension will of itself jeopardise all mining in the Illawarra. The world wide move to renewable energy and the flight of investment capital from coal mean that coal mining will not provide a long term option. When tractors, trucks and cars replaced horses for transport tens of thousands of blacksmiths found alternative employment. Chaffcutters employed thousands of workers in our wheatbelts but when they were rendered obselete by combine harvesters no one argued for the retention of chaffcutters. So too, with the support of governments, must coal miners find alternative employment. Generation and delivery of renewable energy will create employment and expansion of mining rare earth elements (other than those in water catchments) will create new jobs in mining.
- Finally, please consider the serious and costly negative health effects of coal mining, transport and combustion on workers and communities living within range of windblown coal-dust particles (which build up rapidly on my window sills when the wind blows from the south-west).

This project provides a lot of jobs to the local area and a commodity that is required to live (steel)

I am writing to object to this project. I have already objected to the previous version of this project and spoke at the IPC, and was very relieved that the IPC rejected that previous version. I cannot believe that the revised project has been declared as state significant infrastructure - the first and only time a coal mine has been so designated - at a time when the NSW government has committed to rapidly reducing carbon emissions. This project proposes to extract coal for an additional forty years, from an area where the coal seams have a high methane content, and in a context where the coal is not locally required but will largely be exported.

I object on the following grounds.

(1) There is no reasonable basis on which this project could be declared as State Significant Infrastructure. The NSW Government has claimed that the SSI designation is because the mine expansion is necessary for the ongoing operations of the Port Kembla steelworks. However, media reporting and other sources make it clear that the steelworks is NOT dependent on Dendrobium coal, and indeed already has arrangements in place to access the required coal mix. (See for example the reporting here https://www.illawarramercury.com.au/story/7543140/threat-to-steelworks-overblown-if-mine-closes-says-councillor/). Furthermore, evidence has recently emerged in the media that it was the NSW government that coached South32 to emphasise the link with the steelworks (see https://www.abc.net.au/news/2022-06-10/dendrobium-foi-reveals-coaching-environmentalists-say-/101135878). So the argued basis for the SSI designation is itself weak. Furthermore, this is a time when the state could see a significant boost in jobs from accelerating the transition to green (renewably generated) steel, and when state and federal governments are stumping up significant funds to support the transition.

If the steelworks can keep going without South32's Dendrobium coal, the extension doesn't need to be approved at all. If a transition period is needed, then given the 2050 net zero target and the need for urgent action now to meet that target, approving a 40-year coal mine extension (i.e. to 2062!) is completely unnecessary.

(2) Harmful impact on cultural heritage. There is significant Aboriginal cultural heritage in the proposed mine extension areas 5 and 6. The EIS finds presence of multiple shelters with art extant and some with potential archaeological significance, and many areas hosting axe grinding grooves. These individual areas are all significant, but the place more broadly is significant to the local Aboriginal people and the Illawarra Local Aboriginal Land Council has stated that cultural heritage is wider than any individual 'site' where something of cultural significance has been located. Australia is on the threshold of meaningful change in relation to recognition of an Aboriginal voice or voices in parliaments, treaties and other important changes. This is not the time to privilege estimates of economic benefit over significant cultural heritage.

(3) Harmful impacts on environmental values. There are too many factors here to mention. My previous submission made many points in this regard and I refer the decider to my previous submission. In particular, there will be deleterious and potentially irreversible impacts on (a) koalas (now declared as endangered) and their habitat (b) upland swamps, an endangered ecological community about which there is no evidence of potential to remediate (c) aquatic ecosystems, essential but understudied ecosystems; new research is appearing almost weekly about aquatic ecosystems, with new species and indeed genera being discovered (e.g. acquatic fungi) (d) the vegetation of the Illawarra escarpment, where vulnerability to fire is increased with the increase in fire risk on the vegetation under the mine as creeks and hanging swamps are dewatered and the soil and vegetation dry out.

(4) Increased bushfire risk to the city of Wollongong. 300,000-odd people live in the area east of the mine expansion area. Increased flammability of vegetation increases the risk of bushfire in the region, including bushfire reaching the urban area, much of the western portion of which is cloaked in rainforest vegetation that, while normally resistant to fire, will burn in extreme conditions. A catastrophic fire day could see a repeat of the 1968 bushfire, where high temperatures and strong westerly winds caused fire to descend the escarpment slopes, after which a southerly change resulted in fire then burning northward along the escarpment's vegetation. So much of NSW and eastern Australia burned in the Black Summer of 2019-2020, and the Illawarra was incredibly lucky to avoid a repeat of 1968; areas to the south and north burned terribly and this region now contains one of the largest remaining unburnt areas of natural vegetation in the whole of the state. It represents essential refugia for many species that have been decimated or worse in other areas, and an essential repository of biodiversity for revegetating damaged areas elsewhere, particularly the critically endangered subtropical rainforest areas along the further south coast of NSW. Why on earth would the government of NSW do ANYTHING that increases the risk of bushfire in the Wollongong area?

(5) Impact on water availability. You will read this in many of the submissions, because it is true, obviously true, and ought to be a knock-down case against the mine expansion. Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. It is an anomaly and it should stop as soon as possible. WaterNSW has stated that there should be no mining in the Special Areas of the greater Sydney water catchment, and indeed the legislation setting out the Special Areas has the same purpose. Over 300,000 people and businesses in Illawarra get their water from the Avon reservoir, which will lose water from mining under watercourses that feed it. 30% of the population of greater Sydney depend on water from the southern catchment area - and it was only a couple of years ago that Sydneysiders were getting water pumped up from the Shoalhaven River.

In conclusion, I respectfully plead that heed the advice of WaterNSW not to permit mining under the Special Areas, the recommendation of the IPC against approval of the previous version of the project, the concerns of the Land Council, and the many environmental factors cited above, and reject the project. Thank you for attending to this submission.

Put the health of the environment and people before profits for coal miners. The adverse environmental impacts of this mine expansion are well documented, as is the importance of phasing out fossil fuels. Do not let the Dendroboum Mine Expansion Project to proceed!

I am a resident of Wollongong and a parent.

I am writing to express my opposition to the the expansion of Dendrobium Mine in Sydney and Wollongong’s water catchment.

I am opposed to the mine for the following reasons:

1. I am concerned about potential damage to Sydney and Wollongong’s drinking water catchment.
2. I am also very worried about damage to Aboriginal Cultural Heritage.
3. Given that koalas are almost extinct I am exceeding worried about the impact on koalas and their habitat.
4. I am also concerned about damage to aquatic ecosystems and swamps
5. I am concerned about the effect of coal wash, mine outflow and brine dumping on creeks, waterways, harbours and oceans.
6. I am also very concerned about climate impacts and the a massive increase in greenhouse emissions that would result if this mining goes ahead.

I urge the Minister to reject the proposal to expand the Dendrobium Mine.

My name is Andrew Telfer. I am an environmental engineer working in the field of water and stormwater.
I object this revised proposal as I did the previous. I believe water to be a much more precious resource than the coal from this mine. Current and past dodgy practises of extraction underneath water catchments is an unfathomable risk for water security in this changing climate exacerbated by burning fossil fuels. This project is a lose-lose for water security and climate crisis. Let's provide justice for the future generations and provide sustainable jobs for those currently. Oppose this mine expansion and work towards sustainable solutions. We need better practises and better solutions.