Mod 10 - Extension of time

Rix's Creek Mine is in breach of its current consent conditions
The modification application provides no information about where
mining operations are still occurring on the mine site or what area
will be disturbed during another 9 months.
An updated assessment of air quality impacts for the entire mine site
is required under the new EPA 2016 guidelines and new NEPM standard
No information has been supplied about the volume of coal being
produced
The greenhouse gas emissions from another 9 months mining have not
been assessed
The application for an extension of time must be rejected

Rix's Creek Mine is in breach of its current consent conditions
The modification application provides no information about where
mining operations are still occurring on the mine site or what area
will be disturbed during another 9 months.
An updated assessment of air quality impacts for the entire mine site
is required under the new EPA 2016 guidelines and new NEPM standard
No information has been supplied about the volume of coal being
produced
The greenhouse gas emissions from another 9 months mining have not
been assessed
The application for an extension of time must be rejected

I object to Rix's Creek South Modification 10 - extension of time (DA
49/94).

The mine is in breach of its current consent conditions. The
application, critically, doesn't indicate what area will be disturbed
during the additional time requested. There must also be an updated
assessment of air quality impacts, something which is critical given
the high number of exceedances detected in the area generally already.
Cumulative impacts matter.

The modification is not in the interests of the community.
It provides no information about where mining operations are still
occurring on the mine site or what area will be disturbed during
another 9 months.
Singleton, Camberwell and Muswellbrook all exceeded the annual
standard for PM 10 in 2018. No further mines should be approved.
An updated assessment of air quality impacts for the entire mine site
is required under the new EPA 2016 guidelines and new NEPM standard
No information has been supplied about the volume of coal being
produced. The Rocky Hill judgement establishes that the burning of the
product coal is a relevant consideration in mine approvals.
The greenhouse gas emissions from another 9 months mining have not
been assessed
The mine is against the interests of the people of NSW and should be
rejected.

I wish to state my objection to Rix's Creek South Modification
10-Extension of time, for the following reasons:
1. The adverse economic and environmental implications to the people
of NSW from the continuation of the proposed mining project
Application SSD6300, which has yet to be determined but is to be
facilitated by the RCS extension of time proposal.
2. The current consent for RCS shows that mining should already be
completed. No information has been provided by the proponent as to
where they will mine if granted an extension of time.
3. RCS has breached consent conditions - illegally disturbing lands
outside of the approved mining area and providing false and misleading
information. Ref:
https://www.resourcesregulator.nsw.gov.au/_data/assets/pdf_file/oo08/722654/Bloomfield-Collieries-EU-Reason-for-Decision-doument.pdf
The seriousness of this breach should preclude an extension to their
proposal.
4. New and updated air quality impact statements, in line with EPA
2016 and new NEPM standards need to be presented for due consideration
of this proposal.
5. This proposal arrogantly presupposes consent being granted for
Application SSD6300 which is still under review and justifies consent
on the basis that the extension of time for operations will
financially and operationally benefit the proponents' Rix's Creek
North mining operations. The proponent's note that Modification 10 is
a short-term measure to prop up operations at RCN. This proposal is
all about what is best for the proponents. Government should not be
seen to facilitate Bloomfield's commercial viability.
6. Obviously, there is a need for the proponent to show how they are
planning for their workforce to transition from coal mining. Coal
mining now can only offer high-risk, short-term employment
opportunity. The proponent does not provide a time-frame for sustained
employment, probably because it cannot. Importantly, assurances of
continued employment must be considered in the context of the Reserve
Bank's recent recommendation that Australia must make an orderly
transition to a low carbon economy in order to mitigate the costs of
climate change.
7. The proponents must provide up to date evidence of their actions to
reduce operational emissions, and at the very least account for the
projected greenhouse emissions this proposal for an extension of time
will entail. The Government has a duty of care to all residents of NSW
to ensure the cumulative climate impacts of the projects under
consideration are fully costed and greenhouse gas emissions are
prevented and mitigated. The Reserve Bank has now forewarned that
companies that generate significant pollution are likely to face both
reputational damage (already experienced by coal companies) and/or
legal liability from their activities, and changes to regulation could
cause previously valuable assets to become uneconomic.
Thank you for the opportunity to lodge my objection to Rix's Creek
South Mine Modification 10 DA 49/94. The proposal should be rejected.

I object to the modification for the following reasons:
-It is being placed on exhibition during the caretaker period of the
NSW Government;
-There are no details provided of exactly what will occur during the
period of extension;
-No environmental impact assessment has been prepared

Rix's Creek mine is in breach of its conditions of consent. There is no
information about where the mine is going to operate in the next 9
months nor the amount of coal intended to be produced. The greenhouse
emissions are not stated and there is not updated assessment of air
quality impacts for the entire mine site.

1. Rix's Creek Mine is in breach of its current consent conditions
2. The modification application provides no information about where
mining operations are still occurring on the mine site or what area
will be disturbed during another 9 months.
3. An updated assessment of air quality impacts for the entire mine
site is required under the new EPA 2016 guidelines and new NEPM
standard
4. No information has been supplied about the volume of coal being
produced
5. The greenhouse gas emissions from another 9 months mining have not
been assessed
6. This application must be rejected. It is time to move away from
coal for the future of humanity

I object to this proposed modification to the approval period of the life
of the Rix's Creek Mine.

Rix's Creek open cut coal mine really has nearly run out of time, not
just in law. It is too late to take any more coal from the ground. The
consequences of burning any more coal to the global carbon budget is
clearly established. We cannot afford to continue business as usual.
This is the time for action on climate change.

The impact of this proposed modification to the existing development
consent condition 2 has not been assessed. There appears to be an
implicit assumption that the application for the extension of the mine
life currently under assessment will be approved. This is improper if
not unlawful.

The application provides little information on which to consider the
impact. There is little confidence in the Bloomfield Group sticking to
their conditions of consent given their cavalier approach that
resulted in 96 ha of illegal land disturbance before their extension
application (SSD6300) has been approved.

This application does not consider, nor assess the greenhouse gas
emissions over the next nine months that would result from an approval
to this Modification 10 application.

The location of the current and proposed mining operations is not
provided. This is particularly important as the land that was
illegally disturbed has not been included in the environmental
assessment of the current approval.

Furthermore, under the new EPA 2016 guidelines and new NEPM standard
an updated assessment of air quality impacts for the entire mine site
is required. This has not been provided.

Under DA 49/94 conditions of consent, this mine should have almost
completed the final landform and rehabilitation works by now. The mine
closure plan should be in place from 24 March 2019. Conditions of
Consent must be complied with.

This is not an EIS nor is there any adequate Statement of
Environmental Effects.
This application for Modification 10 must be rejected.

The proposal is one of a number of modifications applied for following
the original consent conditions. There has been no information
provided about the environmental effects of the modification. In
particular, no information has been provided about the cumulative
impacts on air quality in the Hunter regional airshed or the
contribution of Scope 3 greenhouse gas emissions. I object to the
modification due to the lack of information about environmental
effects.

I oppose extension and expansion of coal projects in NSW including Rix's
Creek South, due to the effect of coal combustion on greenhouse gas
emissions and resulting global climate change.

Following the Intergovernmental Panel on Climate Change report
published in October 2018, it is evident that our economies must
transition away from fossil fuel extraction if we are to limit global
temperature rises to the safest possible level, which at present
appears to be 1.5C above the pre-industrial global average surface
temperature.


Global temperature increases will have multiple negative health
effects on the people of New South Wales due to increasing heat,
drought and famine, pollution, changing patterns of infectious
disease, and disruption to health services following extreme weather
events.

The most potent way of ameliorating the progress of global climate
change that has been identified to date is expediting the reduction of
carbon emissions.

Projections of global temperature increase show the best odds of
achieving a limited temperature increase involve limiting carbon
emissions as soon as possible.

No other regulatory agency has the power to limit the damage that will
occur to the environment due to the Scope 3 emissions resulting from
this coal project, and so it is imperative that they be taken into
account when assessing this and all other fossil fuel extraction
projects planned for NSW.

We note that the Rix's Creek open cut coal mine current approval runs
out on 24 June 2019. Under this approval the mine should be nearing
completion of rehabilitation and final landform. A closure plan should
be in place from 24 March 2019. The community expects no less!

The owners, Bloomfield, submitted an application for a mine extension
in 2014 to produce 4.5mtpa coal until 2038. In the meantime they open
cut nearly 100 ha outside the area approved for mining. This is not
acceptable!

None of this area has been assessed for environmental impact.In 2017
DPE took them to the Land & Environment Court for illegal land
disturbance. The outcome
was a requirement to find a biodiversity offset. There was no other
penalty for this breach of the Mining Act and EP&A Act. That is a
scandalous position for this government to take!

The extension application went before a public hearing of the IPC in
June 2018 (extinguishing our merit appeal rights.) DPE is still
waiting for more information to complete a final assessment report.
That fact alone should ring alarm bells?

Modification 10 is an application to extend the life of the mine until
March 2020 - expecting an approval of the extension. This was put on
exhibition by DPE for 2 weeks during the NSW Govt caretaker period
leading up to the state election.

Key Points of Objection:
1. Rix's Creek Mine is in breach of its current consent conditions
2. The modification application provides no information about where
mining operations are still occurring on the mine site or what area
will be disturbed during another 9 months.
3. An updated assessment of air quality impacts for the entire mine
site is required under the new EPA 2016 guidelines and new NEPM
standard
4. No information has been supplied about the volume of coal being
produced
5. The greenhouse gas emissions from another 9 months mining have not
been assessed
6. The application for an extension of time must be rejected

The application for an extension of time must be be rejected for the
following reasons:
1, The company has open cut nearly 100ha outside the area approved for
mining without any assessment of environmental impact. This is an
illegal land disturbance under the Mining Act and the Environmental
Planning and Assessment Act for which there has been little or no
penalty. It remains to be seen whether the company will be able to
find a biodiversity offset area equivalent to the area mined as
required by the Land and Environment Court. The company therefore, is
in breach of it's current consent condition and should not be rewarded
with an extension of time.
2. There is no information provided on where mining operations are
still taking place on the site or what areas will be further disturbed
in the course of another 9 months of mining.
3. There is no updated air quality assessment of air quality impacts
for the entire site as required under the new EPA guidelines and the
new NEPM standard.
4. There is no assessment of greenhouse gas emissions from another 9
months of mining, transporting and burning extracted coal.
5. No information has been provided about the amount of coal being
extracted.
The above points are only the absolute minimum usually required for
Environmental Impact Assessment
For the above reasons, the application for an extension of time should
be rejected.

Rix's Creek South Modification 10 - extension of time (DA 49/94)
I thank you for the opportunity to oppose the `extension of time'
application for Rix's Creek South Mine. (DA 49/94)
Considering Rix's Creek have already shown a blatant disregard for the
existing consent conditions when they open cut almost 100 hectares
more than they had approval for, it would be unacceptable to grant
permission for an extension. The mining company appear to be a law
unto themselves.
Climate change is real. The time frame for action to try and save the
planet as predicted by climate change scientists is very short. There
should be no approvals for new mines or extensions of existing mines.
Instead the Government should be creating jobs for the existing mine
workers to transition towards alternate employment.
With the amount of open cut coal mines already operating, the
deterioration of the air quality in the Hunter Valley poses a real
threat to human health in the area with toxic emissions travelling
many kilometres. This was highlighted by a meeting of doctors who have
researched the affect of small particle dust in the area which is
causing significant health problems.
As a long time resident of the Hunter Valley with family including
Grandchildren (who already suffer from respiratory problems),
investing their future in this area it disturbs me greatly that the
`powers that be' appear to totally ignoring the climate change science
plus air quality problems and continuing to approve mine after mine
and extension after extension.
Alison Hodges

I object to Rix's Creek South Modification 10 - extension of time (DA
49/94) for the following reasons:

1. Rix's Creek Mine is in breach of its current consent conditions and
must not be granted consent.
2. The modification application provides no information about where
mining operations are still occurring on the mine site or what area
will be disturbed during another 9 months.
3. An updated assessment of air quality impacts for the entire mine
site is required under the new EPA 2016 guidelines and new NEPM
standard.
4. No information has been supplied about the volume of coal being
produced.
5. The greenhouse gas emissions from another 9 months have not been
assessed.
6. The application for an extension of time must be rejected.
7. What about our children? Why does the fate of their children and
our children not concern our politicians?

Given the abundant evidence that we are all now privy to, any
government that approves such a project as Rix's Creek South
Modification 10 is culpable of ecocide and associated social and
cultural devastation. To allow such a project is unconscionable. To
approve such a project does not meet our obligations to our future
generations.

I object to Rix's Creek South Modification 10 - extension of time (DA
49/94) and remind you again that the world no longer has an appetite
for such projects and already we are seeing litigation being commenced
by young people who recognise how their futures have been
significantly compromised by today's greedy politicians and
multi-national companies.

Kind regards,
Sue Abbott

I support the proposed continuation of the Rix's Creek mine with the
associated employment and economic benefits to the state, Singleton
and the surrounding towns.

I am an employee of The Bloomfield Group working at Rix's Creek Mine in
the Environmental Department. I support the Rix's Creek South
Modification 10 for a nine (9) month extension of time.

This modification will allow the current approved mining operation to
continue for an additional nine months, should it be required, for the
IPCN to reach a determination on the Rix's Creek South Continuation
Project.

This modification does not involve any changes to the approved mining
development consent.

All environmental monitoring and reporting will continue without
change, this means the current approved limits and reporting
requirements will be maintained.

As an employee of The Bloomfield Group working at Rix's Creek Mine I
strongly support the Rix's Creek South Modification 10 for a nine (9)
month extension of time.

Mod 10 will allow Rix's Creek Mine to continue the current approved
mining operations for a further 9 months and allow extra time for the
IPCN to reach a determination on the Rix's Creek South Continuation
Project.

Mod 10 will ensure continued employment and stability for all existing
Rix's Creek employees while the Rix's Creek South Continuation Project
is still being determined. Rix's Creek employees a total of 303 people
(2018). The local communities that include the largest number of
employees are Singleton Council (33%), Maitland City Council (25%) and
Cessnock City Council (13%).

I currently work at Rix's Creek Mine and support Modification 10 that
requests an extension of time on Rix's Creek Mines current development
consent. The Bloomfield Group are a fantastic company to work for and
are an important contributor to the Singleton and Hunter economy.
Rix's Creek Mine supports my family, and many family's that reside in
the Singleton and Hunter region.

I object to the extension of the life of this mine given the following
ongoing unresolved issues:
1. Rix's Creek Mine is in breach of its current consent conditions
2. The modification application provides no information about where
mining operations are still occurring on the mine site or what area
will be disturbed during another 9 months.
3. An updated assessment of air quality impacts for the entire mine
site is required under the new EPA 2016 guidelines and new NEPM
standard
4. No information has been supplied about the volume of coal being
produced
5. The greenhouse gas emissions from another 9 months mining have not
been assessed
6. The impacts on uncertain water entitlements and security as per the
Greater Hunter Regional Water Strategy should mean any new
developments should be curtailed and existing draw downs on water
supply should diminish.

This application for an extension of time must be rejected.