Mandalong Southern Extension (Mod 10) - Additional longwall

Michael Astles
58 Mandalong Road,
MANDALONG NSW 2264
Mobile : 0457 772 234

Application No. SSD-5144-Mod-10

Dear Sir / Madam,

Thank you for affording me the opportunity to comment on Centennial Mandalong Southern Extension Project – Modification 10. Application No. SSD-5144-Mod-10.

I object to this proposal for the following reasons.

As a property owner and resident of Mandalong for almost 40 years I have serious concerns in relation to the second point in the application. ie. Allow greater flexibility on total fire ban days.
The wording of Centennial’s proposed modification makes no mention of “hot work” or other banned activities on total fire ban days.
Exploration drilling involves the use of heat generating activities the effect of which could cause ignition during a total fire ban weather event.
It is hard to believe that ceasing these operations on total fire ban days would have any impact on Centennial's productivity.

During the time my family and I have lived in Mandalong I have been an active member of Mandalong RFS including a stint as brigade captain.
I have experienced firsthand how quickly a fire can start and change it’s intensity and direction on a bad weather day. I have also witnessed the devastation and destruction fires can cause to a community and the landscape. In my opinion any outside work involving machinery in the bush on a total fire ban day has the potential to cause such devastation.

As you are probably aware there is a provision in the RFS Total Fire Ban Rules to allow interested parties to apply for an exemption to carry out approved activities during a total fire ban.
Not only does this process document any proposed activity but also provides RFS authorities with notice as to when and where these risky activities are to take place. This allows the authority (RFS) to better assess the risk in relation to current and expected weather events and the possible commitment of their own resources should the need arise.
It is in the best interest of all concerned for Centennial Morisset to follow the above process.

Decisions on the implementation of a total fire ban are made by experts in the field of bushfire management and control with regards to many factors. This expertise must be respected and the advice followed to ensure it’s credibility and effectiveness.

As a member of Centennial Mandalong’s Community Consultative Committee I have raised my concerns at a recent meeting.

Residents of Mandalong have endured decades of disruption to their lives caused by Centennial Coal’s activities.
I implore your Department to reject this section of Mandalong Southern Extension Project – Modification 10 to assure the community of Mandalong that any further risk to their lives, livelihood’s and property does not ensue.

Regards

I support the application with reasons given in my submission.

OBJECT to MOD 10 SSD-5144: variations to allow greater flexibility on total fire ban days:
As a property owner and resident of I OBJECT to the second point in the application. ie. Allow greater flexibility on total fire ban days. I therefore object to SSD-5144-Mod-10 as it stands.
I ask that your Department reject this section of Mandalong Southern Extension Project – Modification 10.
There is provision in the RFS Total Fire Ban Rules to allow interested parties to apply for an exemption to carry out approved activities during a total fire ban. The Mine should receive no exception from this process. If the Mine wishes to operate on a TOBAN day it can apply for a permit for that day.
I outline the reasons for my objection to the proposal of the Mine that it be exempted from the RFS Total Fire Ban Rules below.
The proposed modification in relation to flexibility to drill and operate machinery out in the open on total fire ban days places inadequate or no effective conditions or limitations on the application of this flexibility.
To reduce the risk of fires damaging or destroying life, property and the environment the NSW RFS Commissioner may declare a Total Fire Ban (TOBAN).
On TOBAN days, no general purpose welding, grinding, soldering or gas cutting can be done in the open. The Mine is asking that it be allowed to engage in some of these activities on Extreme Fire Days. Exploration drilling involves the use of heat generating activities the effect of which could cause ignition during a total fire ban weather event.
What will be the penalties to the Mine if their operations cause loss off life, property and environmental damage? Will the Mine fully compensate financially for this? What about the prosecution of individual workers & directors in the courts for negligence? Or does this application completely exonerate them from prosecution?
Any proposed guidelines that the Mine would operate under on Total Fire Ban Days (e.g. if the RFS gives them an exemption) must be published. Will the RFS be responsible if a fire causes damage that was started by Mine activities on a Total Fire Ban Day?
Why attach a condition for greater flexibility on TOBAN days to an application about one longwall (34), that will apply to all longwalls for the next 20 years of Mine operation? If this modification is allowed, it will, each and every year, pose a fire threat in our community and possibly beyond. Is it even financially sound for the Mine to make this application without a full inquiry about this part of the submission, as a full risk assessment needs to be done and published? Can they please share their financial risk assessment to them as an organisation, above and beyond the technicalities of being allowed to weld, solder and use gas in the open, on TOBAN days?
For the Mine it might only a question of convenience and cost, for the Community and District it could be life and death.
And in addition, surely each fire ban day is different and any exemptions, if there is any that could be justified, should be on a once-off basis for that Total Fire Ban Day only, as per RFS operation rules for TOBAN. Taking account of wind direction, strength, dryness etc. and the conditions on the day.
As you are aware there is a provision in the RFS Total Fire Ban Rules to allow interested parties to apply for an exemption to carry out approved activities during a total fire ban.
Not only does this process document any proposed activity, but also provides RFS authorities with notice as to when and where these risky activities are to take place. This allows the authority (RFS) to better assess the risk in relation to current and expected weather events and the possible commitment of their own resources should the need arise.
The Mine should receive no exception from this process. If it wishes to operate on a TOBAN day it can apply for a permit for that day.
It is in the best interest of all concerned that the Mine follow this the RFS process to the letter and not have a general exemption that applies to all TOBAN days across different locations over a 20 year period.
In the Australian bushfires of 2019-20, we all witnessed the devastation and destruction that fires can cause to community and the landscape. Outside work involving machinery in the bush on a total fire ban day has the potential to cause such devastation that is why there are RFS rules around it.
I ask that your Department reject the this section (“flexibility on TOBAN days”) of the Mandalong Southern Extension Project – Modification 10, to protect the community of Mandalong from risk to their lives, livelihood’s and property.

I object to the project on the grounds that consideration has not been given to the dangers involved when working on Total Fire Ban Days. There should be no flexibility allowed to Centenial Coal on total fire ban days. There are already regulations regarding total fire ban days on who can and who cannot work and believe this should be maintained. A controlled burn along the ridge between Crooks Road and Midway Road, Mandalong only two months ago got out of control because of wind changes and required water bombing to ensure fire was kept under control. If this had not been overseen by the RFS a different outcome would have been devastation to properties and possibly loss of homes in the area. It is therefore important that the RFS authorities should always be aware of any work being done in the bush that could cause a fire and be on hand to control any damage that may occur. Mandalong is a heavily bushed area and backs on to the Wollombi State Forest and a fire in this area would be devastating to the local community.

Please see attached Lake Macquarie City Council's response to this project.

Please find attached submission from Central Coast Council.