Dendrobium Mine Extension Project

This project will be important in providing for the future of the region

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.

 

The Dendrobium Mine Extension Project proposes 30 years of longwall mining in the water catchment for Wollongong, Macarthur and Sydney.  It will result in damage and loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs[i].  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.  We are in drought, paying for desalinated water and our dam levels are below 50% and yet the Dendrobium proposal has the highest water loss of any mine operating in the Greater Sydney Water Catchment area.

This project is not in the public interest; it is in the wrong place at the wrong time.  It would be reckless and immoral for the Department of Planning to support this expansion.

The proposal will result in significant quantities of greenhouse gas emissions

The proposal is estimated to create up to 23.7 million tonnes of CO2e in the production stage and 237 million tonnes in the transport and consumption of the coal produced. This brings the total emissions to between 256 million and 260.7 million tonnes of CO2e for the life of the project[ii].

The current climate emergency means it is no longer morally acceptable for the NSW government to support projects that will severely negatively impact its capacity to meet greenhouse gas reduction targets. The Rocky Hill case supported climate responsibility in its judgement against the Rocky Hill mine, citing the mining SEPP Clause 14 (2): “... the consent authority must consider an assessment of the greenhouse gas emissions (including downstream emissions) of the development.”[iii]

To put the volume of emissions in context, the federal government estimates Australia’s greenhouse gas emissions for the year to December 2018 as 538.2 million tonnes[iv]. Thus approval of this mine would lock in emissions over the life of the project the equivalent of 48% of the 2018 annual emissions for all of Australia.

Annually it would add an average of 8.69 million tonnes per annum (260.7 million tonnes over 30 years) of CO2e to the atmosphere[v]. This is comparable to 1.6% of Australia’s current annual emissions.
 

 

South 32’s brinkmanship should not compromise public interest

South 32 has said that if this proposal is not approved, it will spell the end for the Port Kembla Steelworks and the Port Kembla Coal Terminal. This is misleading and unhelpful to understanding the public interest in relation to this coal mine.

There are still 11 years of mining at Dendrobium under current approvals (for area 3A and 3B) and South 32 operates other coal mines in the region.  South 32 is only selling one third of Dendrobium’s coal to BHP for use in Port Kembla Steelworks. It is exporting the other two thirds.

Bluescope Steel’s Port Kembla steelworks declined to confirm that the steelworks would collapse if the proposed Dendrobium expansion does not go ahead[vi], so we have to question the truth and motivation for this brinkmanship.

 

30 year’s of mining is too long

South 32 is seeking approval for 30 years of mining at Dendrobium. This is far too long.   Increasing population pressure on water resources and impacts of climate change mean that it would be reckless and irresponsible for the New South Wales Department of Planning to support a 30 year approval.

 

South 32 has not provided alternatives to this aggressive and destructive mining proposal

The proposal comprises an aggressive plan for twenty one 305 meter wide longwall panels over 30 years. It provides no alternatives to this destructive proposal, a proposal which poses unacceptable risks to the Greater Sydney Water Catchment Special Areas.

 

Offsets do not compensate for mining-induced destruction of catchment land and ecosystems

South 32‘s proposal to offset catchment land and ecological communities that have been irreparably damaged by mining is not in the public interest; truly like-for-like offsets are rare. Furthermore, there is no “equivalent” land that could compensate for damaged and compromised water catchment.

 

Mining induced subsidence will damage the watercourses and swamps that feed our drinking water reservoirs

South 32 predicts that it’s 305 meter wide long wall panels may result in subsidence of 2m to 2.45m[vii]. Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative[viii].

The mining and associated subsidence will also cause 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.

No level of damage is acceptable to the Special Areas. It would be immoral for the NSW Department of planning to support this level of destruction in Greater Sydney’s water catchment.

 

Billions of litres of water will be lost from Greater Sydney’s Water Catchment

The proposed mining is just 300m from Avon Reservoir and 630m from Cordeaux Reservoir[ix].  The mining will cause loss of water from water courses and swamps that feed the reservoirs.

Water loss from the catchment due to Dendrobium’s mining will increase over the coming years, with surface water loss expected to peak at 27.6 ML per day in the year 2035[x].

Consultants estimate that up to 9,500 Megalitres[xi] (ML – million litres) of surface and ground water will flow into the mines each year, which is the equivalent to the annual water usage of 123,940 residents of Greater Sydney[xii].

 

We ask that you reject this application from Illawarra Coal and commence a process to close the mine at Dendrobium permanently.

 

Thank you for considering this submission.

 

Regards,
Scott Murchison

Submission in Support of the Dendrobium Colliery Extension

Coal is Australia’s and NSW’s most valuable export.
Our national, state and local economies rely heavily on coal mining which provides multiple benefits for all Australians.
The Dendrobium Colliery Extension will generate $2.8 billion in net economic benefit for NSW and generate a $1.1 billion net economic benefit for the Illawarra local community.

Coking coal from coal mines in the Southern Coalfield, such as Dendrobium Colliery, has ideal qualities for steel production and it has fewer impurities, such as sulphur and phosphorus, than coal from countries in Asia.

The ongoing employment of five hundred employees at Dendrobium Colliery is at stake. An additional 200 people will be employed during construction work.

The federal government’s ABS tables of multiplier effects show that more than three times as many indirect jobs are created for every person directly employed in a coal mine.
Australia and NSW need to focus on the positive aspects of coal mining and its many benefits so as not be distracted by ideologically driven anti-mining activists. Everyone should be proud of what coal mining is doing for NSW and Australia.
It is vital that high quality metallurgical (coking) coal is produced locally to supply the BlueScope steel works and other Australian industries. Local coal production minimises transport costs and ensures that high quality coke is produced. This assists Australia to maintain its competitive advantage compared with overseas producers.
The Dendrobium Colliery Extension will deliver $714 million in rates, royalties and taxes to local, state and federal governments.
Its continuance will maintain support for more than 400 NSW businesses which provide supplies and services to the mine.
The mine owner, South32, is making a $1 billion capital investment in the future of Dendrobium Colliery.
The report submitted by Dendrobium demonstrates its comprehensive coverage of all environmental issues. The benefits from the continuation of this coal mine are immense.

For all of these reasons I fully support the extension of Dendrobium Colliery.

I wish to object to the South 32, Illawarra Coal Proposed Mine Extension for Dendrobium. Project SSD-8194.

As a resident of Mount Kembla, and a neighbour of the Dendrobium pit top I have been witness to their operations.

I object on the following grounds:

NOISE-The noise from the Dendrobium pit top is excessive, intrusive and at odds with the natural, and residential surrounding environment. I believe that South 32 are exceeding the noise limits set out in their 2001 consent. I also believe that their monitoring of noise, as per the 2001 consent, has been incorrectly conducted in order to show lower noise monitoring results. I have frequently seen from my home, South 32 staff conducting quarterly noise monitoring next to their cars parked on Cordeaux rd. The 2001 consent states monitoring should occur on the specified property, and at the most affected point of that property, which would be a significant distance from Cordeaux Rd.

My experience is that large parts of the Dendrobium Noise Management Plan is not adhered to. I hear vehicles at all hours during the night when there should be a curfew, I hear reversing beeps all the time, when they are supposed to be low frequency alarms.

The levels of noise are debilitating. It has affected my productivity, it has affected my sleep, it would no doubt negatively affect my property value, and it has meant I am unable to gain an income from my property.

The impact of noise on local wildlife also cannot not be under estimated.

VISUAL IMPACT- South 32 are proposing a substantial list of constructions lasting at least 2 years. As well as the noise these constructions will create they will seriously impact visually on the natural environment, and detract from the village atmosphere of Mount Kembla. The proposal to build a 120 space carpark on the side of Cordeaux Rd as well as a tunnel underneath the road is utterly inconsistent with the natural environment. Mount Kembla has significant heritage value and there are strict conditions for residential developments, yet the mine is proposing to build a huge carpark, with no doubt, lights, tree removals, fencing etc.

I also do not believe that South 32 has addressed the requirements of the Planning Secretary’s Environmental Assessment- “Visual – including an assessment of the likely visual impacts of the development on private landowners in the vicinity of the development and key vantage points in the public domain” The visual impact of this expansion is likely to be significant, it is identified as a specific issue that requires addressing in the EIS, and this has not been done.


TRAFFIC- The increases in mine traffic that are suggested in the EIS Road and Traffic Assessment are completely unacceptable. Mount Kembla is a village with one road in and out. This road is already currently dominated by mine related traffic, and the associated noise of the heavy vehicles as they travel up the steep Cordeaux Rd. The suggested traffic increases of close to 50% are unacceptable, as each one of these vehicles also has a noise, pollution and safety impact on residents, the local school children and local wildlife.

30 YEARS- The proposed 30 year timeframe for the expansion is excessive. There are too many unknowns in such a period of time in the future. It would be reckless for the Department of Planning to approve a development for such a period of time.

THE ILLAWARRA-SHOALHAVEN SUBTROPICAL RAINFOREST OF THE SYDNEY BASIN BIOREGION WAS RECENTLY LISTED AS A CRITICALLY ENDANGERED ECOLOGICAL COMMUNITY- Extending mining, building carparks, removing trees is at odds with the NSW status of endangered ecological community and the Commonwealths status as critically endangered.

THE PROPOSAL WILL RESULT IN SIGNIFICANT QUANTITIES OF GREENHOUSE GAS EMISSIONS- Annually this proposal would add an average of 8.69 million tonnes per annum (260.7 million tonnes over 30 years) of CO2e to the atmosphere. Considering the current climate emergency it is no longer morally acceptable for the NSW government to support projects that will severely negatively impact its capacity to meet greenhouse gas reduction targets.

OFFSETS - South 32‘s proposal to offset catchment land and ecological communities that have been irreparably damaged by mining is not in the public interest; truly like-for-like offsets are rare. Furthermore, there is no “equivalent” land that could compensate for damaged and compromised water catchment.

SUBSIDENCE- Mining induced subsidence will damage the watercourses and swamps that feed our drinking water reservoirs. South 32 predicts that its 305 meter wide long wall panels may result in subsidence of 2m to 2.45m. The mining and associated subsidence will also cause 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. No level of damage is acceptable to the Special Areas. It would be immoral for the NSW Department of planning to support this level of destruction in Greater Sydney’s water catchment.

WATER LOSS - The proposed mining is just 300m from Avon Reservoir and 630m from Cordeaux Reservoir. The mining will cause loss of water from water courses and swamps that feed the reservoirs. It is estimated that up to 9,500 Megalitres of surface and ground water will flow into the mines each year, which is the equivalent to the annual water usage of 123,940 residents of Greater Sydney. This is unacceptable at any time, let alone in a time of drought and water restrictions.

We ask that you reject this application from Illawarra Coal and commence a process to close the mine at Dendrobium permanently.


Thank you for considering this submission.

We are in drought, paying for desalinated water and our dam levels are below 50% and yet the Dendrobium proposal has the highest water loss of any mine operating in the Greater Sydney Water Catchment area.
S32 proposes to take over 9 000 ML of water every year, equivalent to 125 000 peoples water use. Its completely unsustainable and prioritises corporate profit over community wellbeing.

I support this project. Dendrobium Colliery, Illawarra Metallurgical Coal and South32 are a cornerstone of the Illawarra and are key to sustaining industry in this area. South32 are diligent operators and strive for minimal impact to environment and community. This is an important development for the Illawarra and the jobs and revenue that this project will directly and indirectly influence.

Independent and reliable scientific evidence states that this proposed extension is a real threat to the water security of 5 million people in the Greater Sydney region and will produce significant greenhouse gas emissions.
I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium, Project SSD-8194 for the following reasons:

It proposes 30 years of longwall mining in the water catchment for Wollongong, Macarthur and Sydney. This will unequivocally contaminate and severely reduce water going to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs[i]. Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. This is astonishing and needs explanation from authorities.
The proposed mining is in the protected “Special Areas” of the water catchment: 5 million people rely on this for drinking water. We are in drought, paying for desalinated water and our dam levels are below 50%. The Dendrobium proposal has the highest water loss of any mine operating in the Greater Sydney Water Catchment area.
It is irresponsible for the Department of Planning to support this expansion. I ask, why is the Department ignoring reliable scientific evidence that this expansion will cause irrevocable damage to drinking water for 5 million residents under its protectorate?
The proposal will result in significant quantities of greenhouse gas emissions: total emissions will be between 256 million and 260.7 million tonnes of CO2e for the life of the project[ii].
• The current climate emergency means it is no longer morally acceptable for the NSW government to support projects that will severely negatively impact its capacity to meet greenhouse gas reduction targets. These must be taken seriously and considered secondary to profits from coal mining. [Australia is the only country in the world increasing its coal mining.]
There is a precedent for responsible consideration of Mine Extension Projects: Rocky Hill case supported climate responsibility in its judgement against the Rocky Hill mine, citing the mining SEPP Clause 14 (2): “... the consent authority must consider an assessment of the greenhouse gas emissions (including downstream emissions) of the development.”[iii]
• To put the volume of emissions in context, the federal government estimates Australia’s greenhouse gas emissions for the year to December 2018 as 538.2 million tonnes[iv]. Thus approval of this mine would lock in emissions over the life of the project the equivalent of 48% of the 2018 annual emissions for all of Australia.
What legacy are we leaving our children, grandchildren and future generations?
• South 32 predicts that its 305 meter wide long wall panels may result in subsidence of 2m to 2.45m[vii]. Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative[viii]. This is a real risk too great to contemplate. To ignore subsidence from previous mines is irresponsible.
• The mining and associated subsidence will also cause 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.
• No level of damage is acceptable to the Special Areas. The five million people depend upon you to make informed and responsible decisions and assume that you do this based on reliable scientific evidence and drawing parallels from existing / previous mining operations. It is disingenuous to pretend that damage that occurred in other areas under similar conditions will not occur in this Special Area.
Billions of litres of water will be lost from Greater Sydney’s Water Catchment
• The proposed mining is only 300m from Avon Reservoir and 630m from Cordeaux Reservoir[ix]. The mining will cause loss of water from water courses and swamps that feed the reservoirs.
• Water loss from the catchment due to Dendrobium’s mining will increase over the coming years, with surface water loss expected to peak at 27.6 ML per day in the year 2035[x].
• Independent and reliable consultants estimate that up to 9,500 Megalitres[xi] (ML – million litres) of surface and ground water will flow into the mines each year, which is the equivalent to the annual water usage of 123,940 residents of Greater Sydney[xii].
I ask that you reject this application from Illawarra Coal and commence a process to close the mine at Dendrobium permanently.
Please be mindful that your own descendants and Sydney's 5 million descendants rely on your Department to base your decision on reliable and trustworthy evidence. This is no light matter. It is critical that you as the Department of Planning are rigorous in determining which evidence presented to you by both sides is reliable and trustworthy. Is the evidence from independent scientists?
Yours sincerely,
Susan J Benham

See attachment.

Please refer to the attached file.

SUBMISSION FOR THE DENDROBIUM MINE EXTENSION SSD-8194
FROM: SUTHERLAND SHIRE ENVIRONMENT CENTRE

DATE: 15 September 2019
Contact Email: [email protected]

Objection to Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.

South32 proposes to extend the Dendrobium Mine Project for 30 years using aggressive longwall mining in the Special Area of the Sydney Water catchment. Documented evidence confirms the adverse impacts that previous operations at Dendrobium (and other mines in this area) have had on the water catchment. This proposal will result in further damage to the catchment area and loss of irreplaceable water for Australia’s largest city.
Sutherland Shire Environment Centre (SSEC) calls for the NSW Government to reject South32’s Proposed Mine Extension for Dendrobium Mine.

My full submission is attached

Dr Gregory Walker
For and on behalf of Sutherland Shire Environment Centre
15 September 2019

I would like to support this application. This project will ensure the ongoing employment of not only South32 employees, but associated businesses supplying labour, services and products. The coal that is produced from the mine is heavily utilised by BlueScope Steel, another major employer in the region. The impact on sourcing an alternative supply would put added pressure on that company's viability and ability to compete in the worldwide market. The roll on effect to the Illawarra region should this application not be approved will be devastating to the community and youth employment which is currently high. South32 actively supports the local community, and again the effects of not having this ongoing support will place pressure local schools and community initatives. Dendrobium Mine currently operates under conditions to minimise its impact to the environment and the local community, i.e. noise and traffic management etc. and actively liaises with the local community to address issues as they arrive.

I believe the impacts on the water catchment area have not been adequately considered. Especially in light of the recent findings into damage within catchment areas due to long wall mining. Given the ongoing threat of water security this mine expansion is not sensible, nor does it consider the significant impacts to the greater Illawarra and Wollondilly areas of water shortages and the impact it will have.

I wish to strongly object to the proposal. Sydney is already raiding Shoalhaven water. The mine extension will greatly negatively impact on the coasts water supplies, with the water lost being irreversible. I have been to discussions with water/ mining industry professionals who stressed the negative impact already being felt on Sydney's water supply - due to the cracking under the dams and in the catchment areas. The intensity of the current drought must be a huge warning sign of further environmental destruction i.e. our water supply. Have any of you actually been up to the water supply protection areas where the extensive damage is hidden from public view - unless one has a drone!!

Please see attached

Submission objecting to the Dendrobium Mine Extension SSD-8194

I wish to object to Illawarra Coal’s proposed mine extension for Dendrobium SSD-8194 for the following reasons:

1. Damage to the Greater Sydney Water Catchment Area

The Dendrobium Mine Extension Project is for 30 years of longwall mining in the water catchment for Wollongong, Macarthur and Sydney. According to their own documentation ( Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101) it will result in damage and loss of water to swamps, watercourses and the Avon, Cordeaux and Nepean Reservoirs and states that the proposed mining is just 300m from Avon Reservoir and 630m from Cordeaux Reservoir. Water loss from the catchment due to Dendrobium’s mining will increase over the coming years, with surface water loss expected to peak at 27.6 ML per day in the year 2035 (Surface Water Assessment, HEC, 2019, p ix). It is estimated that up to 9,500 Megalitre (ML – million litres) of surface and ground water will flow into the mines each year (ibid, p 101).

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 which provides 5 million people with drinking water. We are in drought, paying for desalinated water and our dam levels are below 50% and the Dendrobium proposal has the highest water loss of any mine operating in the Greater Sydney Water Catchment area. This project is not in the public interest.

2. Offsets cannot compensate for permanent damage to the water catchment

South 32’s proposal to offset catchment land and ecological communities that have been permanently damaged is disingenuous and not in the public interest. There is no “equivalent” land that could compensate for damaged water catchment.

3. Significant greenhouse gas emissions (GHGE)

According to the Environmental Assessment Part 2, Section 6, pp 150-151 this proposal could create up to 23.7 million tonnes of CO2e in the production stage, and 237mt in the transport and consumption, of the coal produced during the life of the project. This is completely unacceptable at this time of climate emergency when Australia must reduce its emissions as close to zero as possible by 2050 to keep temperature rise to below 1.5 degrees.

It is morally unacceptable for the NSW government to support such projects. The Rocky Hill case (2019) supported climate responsibility in its judgement against Rocky Hill mine, citing the mining SEPP Clause 14 (2) “…the consent authority must consider an assessment of the greenhouse gas emissions (including downstream emissions) of the development.”

Annually this Dendrobium expansion would add an average 8.69mt (or 260.7 mt over its 30 year life) of GHGE to the atmosphere (Environmental Assessment Part 2, Section 6, pp 150-151). This would be equivalent to 1.6% of Australia’s current annual emissions, at a time when we are committed to reducing our emissions towards zero.

See formal submission attached

We are destroying the Shire AND threatening an extinction of Mankind. Water is Life, not money. I have only spent 3 years looking at politics, and I am now 100% aware that we, the people, do not matter. Please help us put a stop to a select few putting the rest of us in imminent danger. I cannot believe that it is legal to do this.
Please help us Dendrobium Mine Extension Project, and try and place some legislation to stop this across the board in the future..

16th September, 2019

Re: Illawarra Coal’s proposed mine extension for Dendrobium

I object to the mine extension. Project SSD-8194.

What is the most important and valuable asset in the world?
A – Water

Why?

Without adequate water every person, animal, fish, microbe and flora die

Why are there “Special Areas” with $44,000 fines for trespassing?

A – To protect our most important and valuable asset

Is planet Earth in the middle of a Climate Emergency?j

Many politicians will give a firm, “No” or remain non-committal, that’s because the coal and gas lobby are massive donars to the two major political party’s ie LNP/Nationals and Labor at a state and federal level. So the two major parties are compromised, --- when you take the donation money, the payback is mandatory. Additionally state royalties from coal runs into the $billions.

BUT to everyone else, ie the uncompromised ordinary people, it real. Throughout the world the qualified university trained experts in the field say it is real and warn we have to act now and stop all new fossil fuel projects, now. There are some alleged experts who claim the opposite but a check of their credentials will reveal that many of them are on the payroll of fossil fuel lobbying organisations.

The Paris Agreement came into existence because of the threat, and the threat has become more real since then, it is now an existential threat, far greater than previously estimated.

If we rely on the politicians to save us, then we are doomed! Take a look at the Murray-Darling Basin fiasco. The Murray-Darling Basin Authority was set up and was given billions of dollars to co-ordinate the use of river water for the environment, farmers and drinking water. The ABC Four Corners episode “Pumped” shows the whole process has been corrupted at state and federal level.

Regional towns are running out of water and Australia is being bombarded with wild bush fires and massive floods and storms far stronger, intense and earlier than has ever been experienced before.

Ordinary Australians don’t have a problem with accepting and acknowledging that we are in the middle of a climate emergency; unlike the politicians we are not compromised by coal and gas donars.


Wars and mass migration

The defence forces of the major powers throughout the world have done detailed risk assessments in regard to the climate emergency and all have concluded that because of droughts, wild-fires, cyclones, sea-level rise, lack of drinking water; there will be massive financial costs. This will be accompanied by wars and mass migrations.

So the value of clean, safe drinking water will keep going up. We shouldn’t risk wasting or losing it through new coal mining or extending current projects.

Coal and Gas Vs Renewable Energy

Coal exports may be our biggest export earner but that will change quickly. The present LNP Federal government are wedded to coal and gas. Two years ago present PM Scott Morrison held up a lump of “varnished” coal in the Parliament of Australia and gleefully said to the opposition benches and to all Australians, “This is coal. Don’t be afraid. It won’t hurt you.” His party formed the “Monash Forum” to promote coal production and the building of new coal-fired generators. Coal-fired generators pollute the atmosphere and break down very frequently during the hot days of summer.

A lot of countries, or their states, throughout the world are committed to not building any more new coal mines or coal-fired generators. The financial sector and superannuation companies are divesting from coal and moving investments to renewable energy. So no matter how confidentially the politicians talk about coal, they are wrong and the coal sector is presently in a death spiral which will accelerate over the next 10 years.

Renewable Energy Sector

The conversion to renewable energy throughout the world is a multi-trillion dollar business opportunity; this Third Industrial Revolution is unstoppable and necessary.

Importantly, there is an answer to stopping the CO2 [carbon dioxide] and CH4 [methane] produced by coal and that is renewable energy, which is safer, cleaner and cheaper than coal or gas.

The Australian Renewable Energy Agency [ARENA] and the Clean Energy Finance
Corporation [CEFC] have been on the front foot supporting the transition to
renewable energy.

Audrey Zibelman the CEO at the Australian Energy Market Operator [AEMO], in
regard to the energy transition said, “The fact of the matter is, it’s happening really
fast. Everyone’s predictions around solar uptake, even the most aggressive ones,
were below what it actually is.”

She also said, “… We need to make sure it’s an orderly transition. This is a critical
industry .. If we get energy right, then our economy prospers. If we get it wrong,
it suffers.”

CEO Zibelman calls the “democratisation” of the grid – one of the four Ds that will
shape the future NEM, alongside decentralisation, digitalisation and decarbonisation.
[1]

AEMO is drawing up an Integrated System Plan (ISP), rather than an integrated grid plan, to reflect that over time, the ISP will by necessity consider a wide spectrum of interconnected infrastructure and energy developments including transmission, generation, gas pipelines, and distributed energy resources.
The June 2018 ISP is not the end of the process, but rather the first of many steps, with updates in future years to reflect the dynamically changing nature of the power system and the need to continually innovate and evolve strategies for the future.

What about the $billions that will be lost to treasury if coal becomes redundant?

It will be replaced by the $billions that will be generated by wind farms, solar farms, pumped hydro, utility scale batteries, house batteries, rooftop solar, solar thermal generation, renewable hydrogen etc., And more new jobs are being and will be produced, much more than the coal industry produces. The fuel is free and there is no atmospheric pollution.

What will be the negative impacts of the extension to the Dendrobium mine?

30 years of longwall mining will result in damage and loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs [2]

It will create up to 23.7 million tonnes of CO2 emissions in the production stage and 237 million tonnes in the transport and consumption of coal produced. This brings the total emissions to between 256 million and 260.7 million tonnes of CO2 emissions for the life of the project. [3]

The approval of this mine would lock in emissions over the life of the project the equivalent of 48% of the 2018 annual emissions for all of Australia.

The proposal comprises an aggressive plan for 21 x 305 metre wide longwall panels over 30 years. It provides no alternatives to this destructive proposal, a proposal which poses unacceptable risks to the Greater Sydney Water Catchment Special Areas.

South 32 predicts that it’s 305 meter wide long wall panels may result in subsidence of 2m to 2.45m[4].

Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative[5].

The mining and associated subsidence will also cause 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.

The proposed mining is just 300 metre from Avon Reservoir and 630 metre from Cordeaux Reservoir [6]. The mining will cause loss of water from water courses and swamps that feed the reservoirs.

Water loss from the catchment due to Denrobium’s mining will increase over the coming years, with surface water loss expected to peak at 27.6 ML per day in the year 2035 [7]

Consultants estimate that up to 9,500 Megalitres [11] (ML-million litres) of surface and ground water will flow into the mines each year, which is the equivalent to the annual water usage of 123,940 residents of Greater Sydney [8]

Conclusion

Our drinking water catchment area is finite and priceless!

It must be protected and preserved today and for ever.

Coal mining should never have been allowed in our drinking water catchment area in the first place.

If we destroy or compromise our drinking water catchment area it cannot be repaired or replaced.

The renewable energy revolution is here, embrace it, “If the climate emergency was cancer, then renewable energy would be the cure.”

The politicians are compromised, if we ordinary people rely on them we are doomed.

Hopefullly, the independent, uncompromised adjudicators from the NSW Department of Planning tasked with assessing all the evidence will reject the proposed mine extension.

References

[1]
https://reneweconomy.com.au/australia-has-to-look-forward-on-energy-says-zibelman-we-have-no-choice-20176

[2]
Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696

[3]
Environmental Assessment Part 2, Section 6, pp 150 – 151 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696


[4]
Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696

[5]
Ibid

[6]
Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696

[7]
Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696

[8]
Based on an average daily water usage for Sydney residents of 210 litres. Source:
https://theconversation.com/why-sydney-residents-use-30-more-water-per-day-than-melburnians-

Water is an essential resource. The preservation of our water catchment is vital for Sydney's future.

At Dendrobium existing mining has already caused surface subsidence of up to 3m. The fissures shown here were up to 1m wide at the top. Some fissures are 15m deep. Rainfall which should run off to the storage reservoirs will instead infiltrate deep into these cracks and very likely be lost to the storage.

Why should this industry be given consent to mine in our 'Special Areas' when no other activity, even walking, is banned? Catchment damage is permanent.

In order to fulfil its responsibility WaterNSW claims that:
"WaterNSW opposes any longwall mining located within the Dams Safety Committee notification areas surrounding WaterNSW’s dams in the Declared Catchment, or elsewhere, where it is predicted to damage Sydney drinking water supply infrastructure... In Declared Catchment Areas mining and coal seam gas activities must not result in a reduction in the quantity of surface and groundwater inflows to storages or loss of water from storages or their catchments.... The integrity of WaterNSW water supply infrastructure must not be compromised”

As a resident of Wollongong Council area (who have recently declared a Climate Change Emergency) and a mother, I beg you to stop all further mining in our Water Catchment areas so secure the supply of drinking water and protect the wildlife in these key areas.

Illawarra Coal’s Proposed Mine Extension for Dendrobium

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.

There should be no coal mining in water catchments at all. Australia is the only country in the world where coal mining occurs in water catchments threatening our water security for future generations.

The world is facing the reality of the climate crisis. It would be irrational and immoral to allow new mines and mining expansions to be approved.

GHG emissions must be considered.
South 32 is seeking approval for another 30 years of mining at Dendrobium until 2048!! With the ever increasing population putting greater and greater demands on water resources in the midst of climate change it is a reckless project. It would be irresponsible for the Department of Planning to approve such a plan.
The proposal will result in significant quantities of greenhouse gas emissions. The proposed mining is estimated to create up to 23.7 million tonnes of CO2e in the production stage and 237 million tonnes in the transport and consumption of the coal produced. This brings the total emissions to between 256 million and 260.7 million tonnes of CO2e for the life of the project. Annually it would add an average of 8.69 million tonnes per annum of CO2e to the atmosphere. This is comparable to 1.6% of Australia’s current annual emissions.
The current climate emergency means it is no longer morally acceptable for the NSW government to support projects that will severely negatively impact its capacity to meet greenhouse gas targets. The Environmental Planning and Assessment Act 1979 as well as the Mining State Environmental Planning Policy and other applicable environmental planning instruments have created an environmental assessment framework that requires the consent authority to consider the impacts of greenhouse gas emissions - including downstream emissions along with direct and indirect emissions. ( Clayton UTZ 12 Feb 2019 p.2 )
It is irrational to argue that the emissions from this one mining expansion aren’t significant on a global scale. With the ever increasing threat of global warming, the global problem of climate needs to be addressed by multiple local actions. Therefore this project’s cumulative greenhouse gas emissions must be considered as they will become part of the global total of greenhouse emissions which will affect the climate system and cause climate change impacts.

Threats to water security
“In the Southern Coalfields, WaterNSW considers the greatest current and historic risks to the Sydney water supply are posed by mining operations beneath the Metropolitan and Woronora Special Areas.”
(Water NSW submission to the Independent Expert Panel on Mining in Sydney Catchment - Task 1 Matters May 2018)
It is shocking to think that the Department of Planning might approve these expansions that will drain more and more water from our catchments every day. This project is not in the public interest.
NSW's Chief Scientist said that our catchment is the only publicly owned drinking water catchment in the world where coal mining is allowed. A 2016 poll found that 84% of people in NSW want farmland, water and environment protected from coal mining and CSG.

The Dendrobium Mine Extension Project proposes 30 years of longwall mining under the water catchment for Wollongong, Macarthur and Sydney. There is extensive evidence that longwall mining results in loss of water from upland swamps, water courses, creeks and rivers due to subsidence in the water catchments. The proposed mining is in the protected Metropolitan Special Area where NO ENTRY is allowed. 5 million people rely for drinking water on the Greater Sydney Water Catchment. We are in drought, feeling the effects of climate change and our dam levels are below 50%. The desalination plant has been turned on and we are paying for it. Yet the Dendrobium proposal has the highest water loss of any mine operating in the Greater Sydney Water Catchment area.

Longwall mining is particularly aggressive and mining induced subsidence is inevitable and will damage the water courses and swamps that feed our drinking water reservoirs. South32 has predicted that its 305 meter wide long wall panels may result in subsidence of 2m to 2.45m. However, In March, in a submission to an independent scientific panel, WaterNSW found major concerns around water loss and surface-to-seam fracturing around the mine. “Findings have confirmed that subsidence from Dendrobium Mine is causing impacts greater than were predicted and approved,” it said. Therefore it is reasonable to assume that south 32’s prediction may be conservative.
The Dendroium mine long walls lie between the Cordeaux and Avon reservoirs. These dams rely on the aquifers in the Sydney Basin Bioregion. The coastal upland swamps in the Sydney Basin Bioregion are an endangered ecological community. The coastal upland swamps are endemic to NSW and have the role of acting as buffers, sponges and moderators regulating the flow of water into the dams.
The major threats to the coastal swamps are:
• Alteration of habitat including hydrology following subsidence due to long wall mining.
• Changes in climatic moisture associated with climate change
• Alteration of fire regimes
In the face of a changing climate and expected extreme temperatures and weather patterns the swamps and groundwater systems in our special areas must be protected. The signs along highways and roads reading that trespassers to the area will be fined up to $44,000 indicates the specialness of special areas and yet mining is allowed entry and is inevitably causing permanent changes and damage to these ecosystems that cannot be rehabilitated. The cumulative effects from subsidence will continue forever. In fact the scale of the damage worsens after the mines close.
The signs are, in reality, protecting the activities of the mines. Greater transparency and public knowledge of the effects coal mining is having in the water catchments is absolutely urgent and essential. Water security is the right of all people.

Inadequate modelling.
“WaterNSW understands and accepts that uncertainty in predicting impacts and consequences from mining on overlying catchments is inevitable.”…………
Even though companies and the government have been attempting for decades to assess and predict the risks posed by undermining in the catchment, any proposed predictive modelling has been considered inadequate. We are talking about damage to the ecosystems that provides us with water to sustain life! Its irrational and irresponsible to approve mining in water catchments without accurate knowledge concerning the damage it will cause. There should be no mining in water catchments at all if there are any risks at all to our water security. Water is life.
Groundwater in the superficial and regional aquifers forms an important component of the overall water balance for surface catchments across the Special Areas. Groundwater sustains baseflows to streams, and on a local scale supports (or partially supports) a variety of ecosystems, including some upland swamps.
4.4.3. Uncertainties in groundwater modelling
A primary source of uncertainty in groundwater impact predictions is the nature and heterogeneity of the rock formations overlying the coal seams. Although the sub-horizontally bedded strata of the Sydney Basin have been extensively investigated by government authorities and mining companies within their exploration and mining tenements, rock formations are formed through complex natural processes and are inherently heterogeneous at various scales.
In intact formations, the heterogeneity of hydrogeological flow fields is largely controlled by the amount and orientation of fine-grained materials within bedding planes which greatly affect horizontal permeability rates, and fractures/faults and other discontinuities in the rock, which largely control vertical permeability. The most fundamental change and ensuing uncertainty regarding the hydrogeological regime in the Special Areas is how much it is modified by subsidence-induced fracturing following undermining. As discussed in Section 2.2, the distribution and orientation of subsidence-induced fracturing is not currently well understood and can’t be accurately predicted.” (WaterNSW submission to the IEP- Task 1 Matters May 2018 - p.26-28)
“some knowledge remains elusive, some things remain unknown and in these circumstances precaution and damage avoidance is the best strategy.” (Water NSW Submission to the IEP -1. Initial task, May 2018, p.18.)

Unsatisfactory remediation and offsets

Attempts to repair damage to cracked rocks and drained swamps has been unsuccessful. If you plug cracks with whatever material it will not be permanent as the cracks will continue to move, enlarge, fracture and change and the plugging material will eventually erode and drop away, causing serious and dangerous pollution in the catchment. To reach the bedrock of swamps it would be necessary to disturb the peat-like buildup of organic matter that forms the sponge, exposing the underneath bedrock, leaving the area vulnerable to further dying, deterioration and irreparable damage.

South 32’s proposal to offset catchment land and ecological communities that have been irreparably damaged by mining is not in the public interest. There is simply no way to compensate for damaged and compromised water catchment land. Once the damage has happened it will continue to escalate for the life of the mine and into the future. There is no modelling to predict when, if ever, it will stop. We are talking about destruction of the delicate and complex systems that allow water flow to dams that supply us with water. There are no offsets to compensate for this?

For the reasons above, I am asking you to reject this application from Illawarra Coal.