Mod 2 - Longwall 6

I believe this proposal to be thorough and with excellent environmental considerations. The long history of this mine, its current restructuring, new management and dedication to environmental impacts is impressive. So far as the compnay works closely with environmental bodies at each stage of advancement, I do not see any valid reasoning to not grant approval for longwall 6. The future economic stability of the Wollongong region and the vast number of people this mine employs both directlly and indirectly calls for a swfit resopnse.

Dear Sir/Madam,

Russel Vale Colliery - Preliminary Works Project Mod 2 - Longwall 6 (MP 10_0046 MOD 2)

This is a submission as an objection to this proposed longwall panel. The proposed longwall should not proceed as proposed for the following reason:

Longwall mining over old workings will set a bad precedent as the predicted levels of valley closure, tensile and compressive strains are unacceptably high. Catastrophic cracking damage to the area above the longwall, including important upland swamps is a mathematical certainty.

Approval of this proposal will help to establish totally unacceptable standards for mining in the drinking water supply catchment.

The consideration of past damage to swamps is rubbish, as no pre-mining data exists. The catchment and its swamps will be severely damaged.

Thank you for the opportunity to object to this unacceptable proposal.

Yours sincerely,

Keith Muir
Director
The Colong Foundation for Wilderness Ltd

I oppose the approval of the Longwall Mining of Panel 6. There are significant risks to the area on the surface under the area to be longwalled, including- by the Companies own admission- likely draining of upland swamps and loss of flow in the Cataract Creek catchment.
Upland swamps in the area are valuable ecosystems that are largely unique in the world and as such are irreplaceble. They provide filtration of water into the catchment as well as habitat for many species.
I am concerned that there will be the loss of water flows in the catchment- more than ever we should be concerned about impacts on water catchment and it's subsequent effects on water supply for the whole Sydney Catchment area.
The company is aware that it faces significant issues with an overall expansion approval because of these impacts (and others), this peicemeal approach needs to be halted and a single overall decision made about the totality of the plansd for the project.
This application is approval by stealth of the overall plans.

I am totally against this proposal as the impact on the local environment and water catchment areas will be devastating not to mentioned transporting all that coal by truck to Port Kembla will negatively impact on the health of everyone living in the vicinity of memorial drive

I write to object to the proposal of Wollongong Coal (WC) (formerly Gujarat NRE (GNRE)) for Modification to the Preliminary Works Project MP 10_0046. Some of the reasons for my objection are as follows:

Damage to Sydney Water Catchment Special Area and loss of surface and groundwater

* The proposed longwall is in the Sydney Water Catchment Special Area. Falling within the expected subsidence area are two Upland Swamps of Special Significance listed under the Threatened Species Conservation Act 1995. The first of these (CRUS 1) flows directly into Cataract Reservoir. The second (CCUS4) drains into Cataract Creek and then on into Cataract Reservoir. Cataract Creek also falls within the subsidence area. The watercourses and swamps to be undermined are an integral part of the Sydney Water Catchment system that supplies Cataract Reservoir. Longwall coal mining is a listed Key Threatening Process; it is known to damage the surface and crack water courses and swamps, causing water contamination and loss.

* The development is expected to increase groundwater inflows to the mine from an average of 1.1 million litres a day to around 1.6 million litres a day (Ref: EA, p.ii). The four coal mines operating in the Sydney Water Catchment Special Area currently drain 3 billion litres (or 1,200 Olympic sized swimming pools) from the Special Areas. The Sydney Water Catchment Area supplies drinking water for 4.6 million residents of Greater Sydney area.

* The proposal involves longwall mining a third seam of coal beneath two previously mined seams. Single seam subsidence impacts are difficult to predict; the uncertainty is compounded by triple seam mining and this poses unacceptable risks to the water catchment area. Application of the precautionary principle should be the basis of assessment - and rejection - of this proposal.

Piecemeal Planning process

* Although WC claims the incremental environmental impacts of Mod 2 over and above impacts from existing operations are likely to be minimal, the cumulative impacts to the Special Areas of this mining along with past and proposed future workings in the Wonga East area must be considered. A piecemeal approach driven by the financial imperative of one under-resourced foreign-owned mining company, is not only bad planning, it is negligent.

* An application for mining longwall 6 is already under consideration by DoPI as part of the Underground Expansion Project (MP 09_0013). It is clear that this proposal cannot sensibly be regarded as simply a modification to the Preliminary Works project. WC/GNRE is again attempting to incrementally establish its expansion project. Moreover, recent ICAC findings have exposed extensive corruption in the planning process, in particular in regard to water and coal mining. To stem further erosion of public confidence in the Major Project planning process, DoPI should refuse this application and complete assessment of the Underground Expansion Project in a systematic and transparent manner.

* The application makes the misleading claim that this development is necessary so that WC can continue to mine. In fact, WC has an existing approval to mine the V panel. It is both inappropriate and irresponsible to take up the valuable time of government agencies and community members once again to consider a half-baked application aimed at solving the immediate cash flow problems of this company.

Particulate pollution will increase morbidity and mortality

* Russell Vale Colliery is located in what is perhaps the most densely populated area of any colliery in Australia, with houses and schools bordering the site and just 250m from the huge coal stockpiles. Moreover, the only exhaust fan from the Wongawilli seam - not even mentioned in this EA - blows pollutants over West Corrimal. This development will increase human morbidity and mortality from respiratory and cardiovascular disease caused by coal particulate pollution in the area of Russell Vale, Corrimal, Bellambi and surrounding suburbs. Coal dust will also impact the health of residents along the trucking route to Port Kembla Coal Terminal.

Unsuitability of the proponent

* WC has been responsible for multiple compliance failures and has demonstrated that it is unable to self-regulate. The Russell Vale Colliery contains antiquated infrastructure and WC has failed to fulfil requirements of previous development approvals to upgrade the facilities on the site to modern standards. These failures include: construction of a sound wall and coal loading facility and the realignment of Bellambi Creek to prevent flooding of residents downstream in the event of a major flood event. The company has also failed to pay carbon tax and mining royalties. It even failed to pay its own workers for several months in 2013.

* Although WC has a different name and a different major shareholder and director, the corporation is in essence the same as GNRE, with the same staff, the same financial problems and, as is apparent from this application, the same style of using brinkmanship to incrementally establish its unapproved expansion. WC should receive no special treatment for its financial woes as the new investors' due diligence would have informed them of the company's financial and planning situation.

Jobs and royalty revenues may be lost with the rejection of this entirely unacceptable proposal. However, the broader community interest and inter-generational considerations are of greater significance. The number of jobs at stake is small relative to the regional work force and likewise the royalty revenues, if they are ever collected, are very small relative to annual State and Federal incomes. The value of the natural assets that would be put in harm's way by this proposal cannot be sensibly quantified; they are priceless.

Wollongong Coal acknowledges that the longwall may crack two upland swamps and Cataract Creek. Both swamps and Cataract Creek feed into Cataract Dam. Cataract Dam is one of the water storage dams for Sydney Water Catchment Area, an area that supplies drinking water for 4.6 million residents in Greater Sydney.
The development will increase groundwater inflows into the mine by half a million litres a year.

Russell Vale Colliery is located in what is perhaps the most densely populated area of any Australian colliery. Mod 2 will increase morbidity and mortality in surrounding residential areas from respiratory and cardiovascular disease caused by coal particulate pollution.

I do not want to extend Coal mining into our Water catchment area. The new section of the underground coal mine, Longwall 6, is located in the Sydney Water Catchment Special Area, an area so vital to the integrity of the water catchment that a member of the public could be fined $44,000 just for stepping foot in there.
- Wollongong Coal acknowledges that the longwall may crack two upland swamps and Cataract Creek. Both swamps and Cataract Creek feed into Cataract Dam. Cataract Dam is one of the water storage dams for sydney Water Catchment Area, an area that supplies drinking water for 4.6 million residents in Greater Sydney.
- The development will increase groundwater inflows into the mine by half a million litres a year.
It's crazy to think we would even consider allowing this to go ahead!

I object to this project going forward. Especially as it would be tampering with Sydney's drinking water.

Objections to Proposal MP 09_0013

I am writing to object to the proposal of Gujarat NRE for their Underground Expansion Project MP 09_0013 at the Russell Vale Coal Mine.

I object because I believe the proposed modification will have unacceptable impacts on water resources, ecological communities and local residents, and because the proponent has in the past behaved in such a way as to demonstrate that they are not a suitable proponent. Here are some more detailed reasons for my objection, against each of these points of concern.

· Longwall coal mining is a listed Key Threatening Process in NSW. It damages the surface of the land and cracks water courses and swamps, causing water contamination and loss. (Damage of this sort has been documented already in relation to Waratah Rivulet.) The proposed mining undermines and threatens Cataract River, Cataract Creek, Lizard Creek, Wallandoola Creek and Cataract Reservoir, a number of upland swamps, including swamps of significance, Endangered Ecological Communities and Threatened Species habitats, major cliff lines and Aboriginal Heritage sites - including a sacred birthing site. The watercourses and swamps to be undermined are an integral part of the Sydney Water Catchment system that supplies Cataract dam. The catchment has already been badly damaged by mining, by this proponent and others, and thus there is good knowledge of the likely impacts of further mining; the limited royalties and jobs do not justify further damage, which will impact every future generation living in the area, not to mention the permanent damage caused to the natural environment.

· The proposal includes 390 metre wide longwalls - the widest proposed to date for the Southern Coalfields. Longwalls of this width will certainly result in the loss of surface water. In a time of climate change and increasing frequency of El Nino and droughts, taking risks with surface water already in scarce supply is unacceptable.

· Single seam subsidence impacts are difficult to predict; the uncertainty is compounded by triple seam mining and this poses unacceptable risks to the catchment. Application of the precautionary principle should be the basis of assessment - and rejection - of this proposal.

· The Russell Vale Colliery is the closest to residential areas of any in the Illawarra. Its proximity already causes significant public health impacts. These will become considerably worse if the modification is approved. New coal storage stockpiles are proposed, with options varying from 315,000 to 840,000 tonnes. These proposed stockpiles would be up to 42m high (or the height of a 14 storey building) and would be located 220m from residences, 375m from a school and 500m from a pre-school. This is an unacceptable development for such a heavily populated area. Moreover, the only exhaust fan from the Wongawilli seam blows pollutants over West Corrimal.

· There is increasing awareness and concern about the health impacts of coal dust. A recent study by the World Health Organization found that any level of exposure to particulate pollution is dangerous to health. However, the proponent's studies included as part of the EA only measure particulates down to 10 microns; the Department of Planning and Infrastructure must consider the public health impacts of 2.5 micron particulates and smaller - these are among the most dangerous particulates, and measurement of them is especially important.

· The development would result in 682 truck movements daily at peak times on Bellambi Lane and the Northern Distributor, or one truck every 80 seconds, causing unacceptable public health impacts from coal dust, diesel exhaust, noise and traffic congestion. The Northern Distributor is already becoming unacceptably crowded and occasionally dangerous to drive on; these additional truck movements will push congestion to completely unacceptable levels.

· GNRE is an unsuitable proponent. It has been responsible for multiple compliance failures, including failing to install subsidence monitoring points before commencing Longwall 4 and destroying tracts of upland swamp vegetation "by accident". It has demonstrated that it is unable to self-regulate and does not have the investment capital to modernise the mine and colliery infrastructure to acceptable standards. The EA itself is below current standards, comprising documents that date back a number of years, and thus does not provide a robust basis for decision making at this point in time.

At the very least, the proponent should be required to resubmit its EA so that it includes up to date documentation allowing a fully informed decision by the approver. However, in view of the points made above, I believe the proposed modification should be rejected.

I am opposed to all new coal mines because of the danger that coal poses to the stability of Earth's climate. The short term financial gain of such projects in no way justifies the huge burden of climate chaos that coal is causing.

The NSW Department of Planning is too close to the coal industry and needs to move away and start planning for mitigating climate change, and restructuring our economy to one powered by renewable energy. Anything less is negligent and morally corrupt.

It's time to quit coal.

This proposal disregards the rights of many people local near and far alive today and infringes on the rights of those yet to be born. This proposal presents significant risks to the environment and passes costs to this least able to afford it. This allows for the unbridled impacts of emissions and chemicals to pollute a vulnerable catchment. This proposal should not be permitted.

I would like to object on the basis of my concerns about the integrity of Cataract Dam and upland swamps viz

Location for the new longwall, Longwall 6, is in the Sydney Water Catchment Special Area, an area so vital to the integrity of the water catchment that a member of the public could be fined over $44,000 just for stepping foot in there.

I and a number of others have sought permission to access the Sherbrooke area of the Cataract Dam catchment area and this has been denied us because of the integrity demanded by the Sydney Catchment Authority. So to read this proposal is totally bizarre and inappropriate. If the Cataract Dam catchment is too special to allow restricted and controlled visits onto the site then it is too special to allow it to be damaged by longwall mining underground.

Further Wollongong Coal acknowledges that the longwall may crack two upland swamps and Cataract Creek. Both swamps and Cataract Creek feed into Cataract Dam. Cataract Dam is one of the water storage dams for Sydney Water Catchment Area, an area that supplies drinking water for 4.6 million residents in Greater Sydney.
There has been pressure to mine under Cataract Dam for over 100 years and the government vetoed this in the early 20th Century years because they wanted to keep it pristine. This position should remain unchanged.

The development will increase groundwater inflows into the mine by half a million litres a year.

From a sustainability perspective it is not appropriate to waste precious dam water. It is already known that there have been problems with water loss from creeks from Appin mine generated subsidence - and if we enter another drought period water conservation is a must.
If Longwall 6 is approved, it may presuppose the approval of this mine's Major Expansion Project, a large and controversial project of triple seam coal mining in the Special areas. This would potentially compound the concerns raised to date.

Objections to Proposal MP 10_0046 - MOD 2

1) this proposal is not a "modification" to preliminary works - it is the further sneaky approach to gaining permissions for a contentious proposal by incremental applications and special pleading. At the time of the approval of the first modification the PAC told Community members at the meeting held with them (in lieu of a proper meeting because of the proximity of christmas) that no further modifications could be countenanced and that this abuse of process would not become ongoing.
2) This proposal seeks permission to undertake what is perhaps one of the most contentious elements of the overall project before the full project proposal is properly considered. It must be noted that ALL of the delays in the approval of the major project have been due to tardy submissions and under resourcing of necessary studies by the proponent. This is procedurally insupportable and makes a mockery of the notion of proper processes for seeking approvals
3)Wollongong Coal (previously Gujarat NRE) continue a pattern of failure to implement required actions from previous stages of projects and seeking to have conditions previously required removed after the actions to which the conditions were attached are concluded. The community can have no confidence that the conditions which relate in particular to the impacts that this mine in a residential area has on the amenity of the residents will ever be met. We have already heard that the company has no intention of beginning the long promised Bellambi gully works which are required to prevent flooding of homes downstream of the mine site which were supposed to be completed long ago at any time in the foreseeable future - indeed, having undertaken the works to which the condition applied they will now seek to have the condition removed.
3) There is no sign that the company has the financial capacity to undertake the works they seek permission for and to meet its obligations to future monitoring and remediations which are a condition of their existing approvals.
4) The company is believed to owe substantial sums and indicates that it must have this approval in order to continue to meet its environmental and safety obligations. If that is a true statement of the financial position of the company then they do not have sufficient funds to undertake this project or any future mining in this environmentally sensitive area
5)The Bellambi Creek realignment must be completed before any further approvals are granted. The residents of this area expect that current standards and expectations will be applied to the present owner of the mine, just as current planning standards apply to the residents when they seek approvals - imagine if one of us had conditions placed on our developments such as ensuring we met our obligations not to flood our neighbours, we then somehow manage to get approval to build some of our development (perhaps by pleading that a local builder needs the business) but do not do the drainage works and then seek permission to complete the development and have the drainage conditions removed... I doubt we would receive any further permissions until we were compliant , and the possibility that we would default on our obligations to our employees and contractors would not be seen as a reason that we should receive special consideration.
6)GNRE and now WC are continuing to operate this mine with antiquated and outdated infrastructure. They have made application in their Expansion Project, their subsequent PPR and now in this Modification to continue to load coal off the stock pile and on unsealed roads. The PPR has requested an increase of coal production up to 3 million tonnes but has not fully committed to the construction of new truck loading facilities in a timely manner. It is vital that these truck loading facilities are constructed and fully operational prior to any further approvals at this mine. The noise and dust generation from this antiquated infrastructure impacts greatly on the local residents. WC has also been refusing to design and plant vegetated windbreaks on site that would drastically reduce the 670 tonnes of coal dust currently being eroded from their small stockpile each year. Fifty tonnes of dangerous 0.25 micron dust is blown over the surrounding residential areas each year and this is from their current 60,000 tonne stock pile. (Reference: Final Report - NRE No. 1 Colliery Particulate Matter Control Best Practice Pollution Reduction Program, PAE Holmes, 2012, p. 10).
7)WC has made an assumption that because this application only deals with the first 400m of LW6 that there will be only minor impacts they are not considering cumulative impacts of previous and future approvals. This small part of the longwall cannot be taken in isolation but should be taken into consideration within the whole development. This piecemeal approach has been the problem with mining approval in general in the water catchment area. The whole of the proposed development impacts should be assessed at one time.

8) The first 400m of Longwall 6 will have the most dramatic effect on the swamps, the water catchment area and the Cataract Dam. If WC were committed to low impact on the catchment area and dam they would propose mining the last 400m or use bord and pillar extraction.

9) This proposal should not be considered if any further piecemeal approval is to be allowedit should be relocated towards the east beyond any impact on Cataract Creek, this will mean that there is no impact on upland swamps, there will be less potential impact on Cataract Dam and less potential future impact on Cararact Creek. If WC were committed to lessening the impact on the catchment area and dam to enable them to continue operation they would provide options rather than just resolutely continue with their proposed PPR layout. They could for instance divide the LW6 down the middle with gateroads and mine it in two halves. This would drastically reduce subsidence and risk to our precious water catchment. They could mine the first portion of longwall 6 using bord and pillar to reduce subsidence and damage to the Special Areas. They could also mine the eastern portion of longwall 6 first, thus avoiding the problematic western section.

10)WC needs to be more active in proposing solutions to their own financial, management and planning difficulties, rather than relying on the Govt agencies and community to take pity on their self-induced woes.

11) Cataract Dam has already had long wall mining conducted underneath it. This is in close proximity to the proposed realigned longwalls. The proposed first 400m of LW6 already encroaches on the Wongawilli seam exclusion zone and the 35° marginal zone has already been compromised by the mining in the bulli seam above. This is a blatant disregard for the safety of the Cararact Dam. The recently released end-of panel report for Longwall 5 at this site makes clear the failure of modelling methods to correctly predict subsidence under these unprecedented conditions and the observed value (which may yet increase with further settling) lies barely within the upper bound of the amended model. It is an unacceptable risk to test the validity of modelling procedures by approving the riskiest of the presently proposed (but unapproved) alignments. If the modelling offered as the basis for approval is found to be deficient, the most vulnerable area will have been used as the test site. This is against all proper risk management principles which would see models tested in areas of minimum risk.

12) The extraction of coal from Longwall 6 will cause subsidence within an area that includes Cataract Creek and several upland swamps. Cataract Creek has been recognised by the Planning Assessment Commission (PAC) as having "highly significant values" making it "worthy of protection" (Bulli Seam Operations report, 2010). Subsidence impacts on swamps, surface waters and groundwater has been described in detail in the Southern Coalfield Inquirse reports recognise the importance of swamps both as water stores and filters, and as biodiversity pools of very high conservation value. The evidence that swamps cannot be safely undermined is overwhelming. Remediation of swamps is not possible and there are no examples of `self-healing'.
Swamps CRHS1, CCHS3 and CCHS4 have special significance status under DECCW (now OEH) 2011 draft guidelines, and CCHS3 and CCHS4 include rare Tea-Tree communities. Recommendation 18 of the Metropolitan Coal PAC report includes the following; "swamps of special significance will be protected from negative environmental consequencey report and the PAC reports for the Metropolitan Coal and Bulli Seam Operations (BSO) projects. Thes". Aboriginal site 52-3-0322 is located on the edge of CRHS1 and Aboriginal site 52-3-0320 is on the edge of CCHS3. CCHS3 and CCHS4 overly Longwall 5 and CRHS1 is within the subsidence zone of Longwall 5. Approving Longwalls 4 and 5 would approve the loss of these swamps.
Two first order streams join together directly over Longwall 5 to form a second order tributary to Cataract Creek; these streams will be severely impacted by the subsidence over Longwall 5. There is also a first order stream that appears to commence over or at the edge of Longwall 5. Low order streams play a vital role in connecting upland swamps to higher order streams.

Subsidence, increased strata permeability and strata depressurisation risks redirection and loss of surface and ground water from the Cataract catchment, as the Sydney Catchment Authority believes has occurred as a result of damage to the Waratah Rivulet. Recent work by Professor Philip Pells (Thirlemere Lakes report and addenda, and research accepted for publication in Australian Geomechanics) shows that the Bald Hill claystone layer cannot be counted on to protect surface and near surface waters from depressurisation and water loss.
In Appendix E Pells cites examples highlighting the uncertain nature of subsidence prediction. The severe damage to two kilometres of the Waratah Rivulet provides another example of modelling and prediction failure. The widths of the longwalls that caused the catastrophic damage to the Waratah Rivulet were much the same as the width of Longwalls 4 and 5. Compounding this uncertainty, there appears to be little precedent for multi-seam mining, for which additional subsidence factors of up to 80% have been suggested. Such risks and uncertainties are unacceptable in relation to our water supplies and the need for biodiversity conservation.
The Gujarat EA is misleading in several respects, for instance is suggests that a report by Geoterra (Appendix I) indicates little or no impact to swamps over Longwalls 4 and 5. This report refers specifically to CRHS1, which is not located above the longwalls, and makes no mention of the swamps that are directly over the longwalls. The EA provides no subsidence information, predicted or observed, for Longwall 4. Longwall 5 would reactivate and compound the subsidence of Longwall 4. There appear to be no predictions for valley closure or upsidence, other than a mention of upsidence in CRHS1. Appendix J does not seem to contain monitoring and management plans referred to in the EA. The EA provides essentially no mitigation information. The Metropolitan Special Area is a Schedule 1 area for which SCA consent is required, it is not a Schedule 2 area as the EA suggests. The EA makes no reference to the Sydney Drinking Water SEPP or its embodied Neutral or Beneficial Effect (NorBE) on water test.
The water catchment area is not ours to risk. We have a responsibility to preserve the catchment special area and its underlying land and aquifers undamaged, so that future generations of this area can have the access to drinking water that we have taken for granted in our lifetime.
12) Residents in the vicinity are exposed to airborne particulates from the colliery's operations. These operations include; a coal stockpile located just 200m from people's homes; a resizing (crushing) facility; an enormous ventilation fan that blasts air from the underground mine directly at homes in West Corrimal; and trucking of coal past people's homes to Port Kembla Coal Terminal. All of these issues are factors which resort to modern technology could significantly alleviate. If the costs of mining at this site are inconsistent with maintaining proper environmental standards for the community then the mine is uneconomic and the proprietors should close it down.
13) The proponent of this project publicly encourages the view that the mine has been located here for longer than any of the residents. This does not justify the mine being operated at standards which applied in the early 20th century. The mine was only recently purchased by the present company - indeed the current proprietors are very much the newcomers here. "We were here first" is not the basis on which the planning decisions must be made. They must be made in the context of the laws and conditions now governing planning and the undertakings given by those who seek the community's support to govern them.

If our community is to have any confidence that mining approvals are properly scrutinised in the context of their impact on our environment and our all important future water storage, then this proposal must be refused and the processes already in place to review the entire proposal should continue.

Our community is worn out trying to ensure that the planning processes which should be applied to this mine are properly conducted. Considerable effort went in to making submissions to the major expansion project approval at this site and all of the objections to that proposal must be considered as objections to this most contentious element of the overall expansion. If this modification has passed by with limited objection, it could be that the community has been misled by the assurances that there would be no further modifications sought, coupled with the exhibition period (which is largely determined by the timing of the submission by the proponent) encompassing two long weekends and the school holidays.

This modification must be rejected - the company has approvals to mine which it chooses not to use. If it cannot operate the mine in an economic manner then it should stop expecting the community subsidising it.

Objections to Proposal MP 10_0046 - MOD 2

1) this proposal is not a "modification" to preliminary works - it is the further sneaky approach to gaining permissions for a contentious proposal by incremental applications and special pleading. At the time of the approval of the first modification the PAC told Community members at the meeting held with them (in lieu of a proper meeting because of the proximity of christmas) that no further modifications could be countenanced and that this abuse of process would not become ongoing.
2) This proposal seeks permission to undertake what is perhaps one of the most contentious elements of the overall project before the full project proposal is properly considered. It must be noted that ALL of the delays in the approval of the major project have been due to tardy submissions and under resourcing of necessary studies by the proponent. This is procedurally insupportable and makes a mockery of the notion of proper processes for seeking approvals
3)Wollongong Coal (previously Gujarat NRE) continue a pattern of failure to implement required actions from previous stages of projects and seeking to have conditions previously required removed after the actions to which the conditions were attached are concluded. The community can have no confidence that the conditions which relate in particular to the impacts that this mine in a residential area has on the amenity of the residents will ever be met. We have already heard that the company has no intention of beginning the long promised Bellambi gully works which are required to prevent flooding of homes downstream of the mine site which were supposed to be completed long ago at any time in the foreseeable future - indeed, having undertaken the works to which the condition applied they will now seek to have the condition removed.
3) There is no sign that the company has the financial capacity to undertake the works they seek permission for and to meet its obligations to future monitoring and remediations which are a condition of their existing approvals.
4) The company is believed to owe substantial sums and indicates that it must have this approval in order to continue to meet its environmental and safety obligations. If that is a true statement of the financial position of the company then they do not have sufficient funds to undertake this project or any future mining in this environmentally sensitive area
5)The Bellambi Creek realignment must be completed before any further approvals are granted. The residents of this area expect that current standards and expectations will be applied to the present owner of the mine, just as current planning standards apply to the residents when they seek approvals - imagine if one of us had conditions placed on our developments such as ensuring we met our obligations not to flood our neighbours, we then somehow manage to get approval to build some of our development (perhaps by pleading that a local builder needs the business) but do not do the drainage works and then seek permission to complete the development and have the drainage conditions removed... I doubt we would receive any further permissions until we were compliant , and the possibility that we would default on our obligations to our employees and contractors would not be seen as a reason that we should receive special consideration.
6)GNRE and now WC are continuing to operate this mine with antiquated and outdated infrastructure. They have made application in their Expansion Project, their subsequent PPR and now in this Modification to continue to load coal off the stock pile and on unsealed roads. The PPR has requested an increase of coal production up to 3 million tonnes but has not fully committed to the construction of new truck loading facilities in a timely manner. It is vital that these truck loading facilities are constructed and fully operational prior to any further approvals at this mine. The noise and dust generation from this antiquated infrastructure impacts greatly on the local residents. WC has also been refusing to design and plant vegetated windbreaks on site that would drastically reduce the 670 tonnes of coal dust currently being eroded from their small stockpile each year. Fifty tonnes of dangerous 0.25 micron dust is blown over the surrounding residential areas each year and this is from their current 60,000 tonne stock pile. (Reference: Final Report - NRE No. 1 Colliery Particulate Matter Control Best Practice Pollution Reduction Program, PAE Holmes, 2012, p. 10).
7)WC has made an assumption that because this application only deals with the first 400m of LW6 that there will be only minor impacts they are not considering cumulative impacts of previous and future approvals. This small part of the longwall cannot be taken in isolation but should be taken into consideration within the whole development. This piecemeal approach has been the problem with mining approval in general in the water catchment area. The whole of the proposed development impacts should be assessed at one time.

8) The first 400m of Longwall 6 will have the most dramatic effect on the swamps, the water catchment area and the Cataract Dam. If WC were committed to low impact on the catchment area and dam they would propose mining the last 400m or use bord and pillar extraction.

9) This proposal should not be considered if any further piecemeal approval is to be allowedit should be relocated towards the east beyond any impact on Cataract Creek, this will mean that there is no impact on upland swamps, there will be less potential impact on Cataract Dam and less potential future impact on Cararact Creek. If WC were committed to lessening the impact on the catchment area and dam to enable them to continue operation they would provide options rather than just resolutely continue with their proposed PPR layout. They could for instance divide the LW6 down the middle with gateroads and mine it in two halves. This would drastically reduce subsidence and risk to our precious water catchment. They could mine the first portion of longwall 6 using bord and pillar to reduce subsidence and damage to the Special Areas. They could also mine the eastern portion of longwall 6 first, thus avoiding the problematic western section.

10)WC needs to be more active in proposing solutions to their own financial, management and planning difficulties, rather than relying on the Govt agencies and community to take pity on their self-induced woes.

11) Cataract Dam has already had long wall mining conducted underneath it. This is in close proximity to the proposed realigned longwalls. The proposed first 400m of LW6 already encroaches on the Wongawilli seam exclusion zone and the 35° marginal zone has already been compromised by the mining in the bulli seam above. This is a blatant disregard for the safety of the Cararact Dam. The recently released end-of panel report for Longwall 5 at this site makes clear the failure of modelling methods to correctly predict subsidence under these unprecedented conditions and the observed value (which may yet increase with further settling) lies barely within the upper bound of the amended model. It is an unacceptable risk to test the validity of modelling procedures by approving the riskiest of the presently proposed (but unapproved) alignments. If the modelling offered as the basis for approval is found to be deficient, the most vulnerable area will have been used as the test site. This is against all proper risk management principles which would see models tested in areas of minimum risk.

12) The extraction of coal from Longwall 6 will cause subsidence within an area that includes Cataract Creek and several upland swamps. Cataract Creek has been recognised by the Planning Assessment Commission (PAC) as having "highly significant values" making it "worthy of protection" (Bulli Seam Operations report, 2010). Subsidence impacts on swamps, surface waters and groundwater has been described in detail in the Southern Coalfield Inquirse reports recognise the importance of swamps both as water stores and filters, and as biodiversity pools of very high conservation value. The evidence that swamps cannot be safely undermined is overwhelming. Remediation of swamps is not possible and there are no examples of `self-healing'.
Swamps CRHS1, CCHS3 and CCHS4 have special significance status under DECCW (now OEH) 2011 draft guidelines, and CCHS3 and CCHS4 include rare Tea-Tree communities. Recommendation 18 of the Metropolitan Coal PAC report includes the following; "swamps of special significance will be protected from negative environmental consequencey report and the PAC reports for the Metropolitan Coal and Bulli Seam Operations (BSO) projects. Thes". Aboriginal site 52-3-0322 is located on the edge of CRHS1 and Aboriginal site 52-3-0320 is on the edge of CCHS3. CCHS3 and CCHS4 overly Longwall 5 and CRHS1 is within the subsidence zone of Longwall 5. Approving Longwalls 4 and 5 would approve the loss of these swamps.
Two first order streams join together directly over Longwall 5 to form a second order tributary to Cataract Creek; these streams will be severely impacted by the subsidence over Longwall 5. There is also a first order stream that appears to commence over or at the edge of Longwall 5. Low order streams play a vital role in connecting upland swamps to higher order streams.

Subsidence, increased strata permeability and strata depressurisation risks redirection and loss of surface and ground water from the Cataract catchment, as the Sydney Catchment Authority believes has occurred as a result of damage to the Waratah Rivulet. Recent work by Professor Philip Pells (Thirlemere Lakes report and addenda, and research accepted for publication in Australian Geomechanics) shows that the Bald Hill claystone layer cannot be counted on to protect surface and near surface waters from depressurisation and water loss.
In Appendix E Pells cites examples highlighting the uncertain nature of subsidence prediction. The severe damage to two kilometres of the Waratah Rivulet provides another example of modelling and prediction failure. The widths of the longwalls that caused the catastrophic damage to the Waratah Rivulet were much the same as the width of Longwalls 4 and 5. Compounding this uncertainty, there appears to be little precedent for multi-seam mining, for which additional subsidence factors of up to 80% have been suggested. Such risks and uncertainties are unacceptable in relation to our water supplies and the need for biodiversity conservation.
The Gujarat EA is misleading in several respects, for instance is suggests that a report by Geoterra (Appendix I) indicates little or no impact to swamps over Longwalls 4 and 5. This report refers specifically to CRHS1, which is not located above the longwalls, and makes no mention of the swamps that are directly over the longwalls. The EA provides no subsidence information, predicted or observed, for Longwall 4. Longwall 5 would reactivate and compound the subsidence of Longwall 4. There appear to be no predictions for valley closure or upsidence, other than a mention of upsidence in CRHS1. Appendix J does not seem to contain monitoring and management plans referred to in the EA. The EA provides essentially no mitigation information. The Metropolitan Special Area is a Schedule 1 area for which SCA consent is required, it is not a Schedule 2 area as the EA suggests. The EA makes no reference to the Sydney Drinking Water SEPP or its embodied Neutral or Beneficial Effect (NorBE) on water test.
The water catchment area is not ours to risk. We have a responsibility to preserve the catchment special area and its underlying land and aquifers undamaged, so that future generations of this area can have the access to drinking water that we have taken for granted in our lifetime.
12) Residents in the vicinity are exposed to airborne particulates from the colliery's operations. These operations include; a coal stockpile located just 200m from people's homes; a resizing (crushing) facility; an enormous ventilation fan that blasts air from the underground mine directly at homes in West Corrimal; and trucking of coal past people's homes to Port Kembla Coal Terminal. All of these issues are factors which resort to modern technology could significantly alleviate. If the costs of mining at this site are inconsistent with maintaining proper environmental standards for the community then the mine is uneconomic and the proprietors should close it down.
13) The proponent of this project publicly encourages the view that the mine has been located here for longer than any of the residents. This does not justify the mine being operated at standards which applied in the early 20th century. The mine was only recently purchased by the present company - indeed the current proprietors are very much the newcomers here. "We were here first" is not the basis on which the planning decisions must be made. They must be made in the context of the laws and conditions now governing planning and the undertakings given by those who seek the community's support to govern them.

If our community is to have any confidence that mining approvals are properly scrutinised in the context of their impact on our environment and our all important future water storage, then this proposal must be refused and the processes already in place to review the entire proposal should continue.

Our community is worn out trying to ensure that the planning processes which should be applied to this mine are properly conducted. Considerable effort went in to making submissions to the major expansion project approval at this site and all of the objections to that proposal must be considered as objections to this most contentious element of the overall expansion. If this modification has passed by with limited objection, it could be that the community has been misled by the assurances that there would be no further modifications sought, coupled with the exhibition period (which is largely determined by the timing of the submission by the proponent) encompassing two long weekends and the school holidays.

This modification must be rejected - the company has approvals to mine which it chooses not to use. If it cannot operate the mine in an economic manner then it should stop expecting the community subsidising it.

Attention: Director, Mining and Industry Projects
Major Projects Assessment
Department of Planning
GPO Box 39
Sydney NSW 2001

Proposal MP 09_0013

Dear Planning Director

I wish to lodge an objection to the proposal of Gujarat NRE for their underground expansion project MP 09_0013.

In my view too much damage has already been caused to Cataract Creek and from what I have read the consensus on the likely cause of existing damage is subsidence due to previous mining activity.

I also do not ever wish to see a situation where methane leaking to the surface makes creek water flammable and I certainly would be very dismayed if cracks in the creek bed caused by any future mining activity led to water disappearing from the watercourses in the area

The area around Cataract Creek and its associated upland swamps are very special items of environmental significance not only to NSW but to the nation - including the nation of first peoples.

I do not wish to see long-wall mining with the potential to result in loss of surface water to occur anywhere near the proposed site and believe that the proposal should be rejected purely on environmental grounds.

In my view no kind of potential economic benefit in terms of either employment or profit should be allowed to jeopardize our precious water catchment and associated areas of environmental significance.

Yours faithfully,

Dr Joseph Davis

The Black Diamond Heritage Centre in the past has been supported by the coal mining industry in the Illawarra. And the Centre is seeking to maintain awareness of the regions coal mining history.
However the Black Diamond Heritage Centre also respects the special nature of the Cataract Catchment Area. Over the last month the Centre has hosted events as part of the National Trust NSW Annual 2014 Heritage Festival - these were based on the theme of the Lost Village of Sherbrooke which was destroyed to make way for the Cataract Dam in the early 20th Century. The events attracted over 200 people many of them descendants of those whose land was compulsorily resumed in 1903 for the Dam. Soon after the Dam was completed in the early 20th Century years there was pressure to allow the coal mines to mine under the Cataract Dam but the NSW Government then deemed the catchment area too sensitive for mining operations then. The Sherbrooke descendants who visited the Heritage Festival events at the Black Diamond Heritage Centre would dearly like to visit the land of their ancestors - but it is denied them by the Sydney Catchment Authority because the Cataract Dam catchment area is deemed too special by the SCA. And yet these same descendants are querying why if they are denied access that the Cataract Dam could be damaged by the proposed longwall extension ? Is there one law for individuals and another for corporations when it comes to Dam Catchment Areas ?
Wollongong Coal acknowledges that the longwall may crack two upland swamps and Cataract Creek. Both swamps and Cataract Creek feed into Cataract Dam. Cataract Dam is one of the water storage dams for Sydney Water Catchment Area, an area that supplies drinking water for 4.6 million residents in Greater Sydney.
The development will increase groundwater inflows into the mine by half a million litres a year.

From a sustainability perspective it is not appropriate to waste precious dam water. It is already known that there have been problems with water loss from creeks from Appin mine generated subsidence - and if we enter another drought period water conservation is a must.

For the last 150 years coal mining has been an important part of the Illawarra's regional economy - however its contribution to employment in the region has been dramatically shrinking ever since 1982. And for over 100 years the NSW Government has taken the view that our State's Dams must be protected.

The Black Diamond Heritage Centre therefore requests that any approval for the Wollongong Coal Longwall extension must not compromise the integrity of the special nature of the Cataract Dam and its catchment area - and that the decisions be made in accordance with the Precautionary Principles developed in Rio 1992 in concert with the Gro Harlem Bruntland 1987 Report "Our Common Future" on Ecological Sustainable Development.

I object to the proposal of Wollongong Coal for Modification to the Preliminary Works Project MP 10_0046. The reasons for my objection are:

-The proposed longwall is in the Sydney Water Catchment Special Area and will involve damage to this area as well as loss of surface and groundwater. The watercourses and swamps to be undermined are an important part of the system that supplies Cataract Reservoir. Within the expected subsidence area for the longwall are two Upland Swamps (CRUS1 and CCUS4) listed under the Threatened Species Conservation Act 1995, and Cataract Creek. The development is also expected to increase groundwater inflows to the mine from an average of 1.1 million litres a day to around 1.6 million litres a day.

- The proposal involves longwall mining a third seam of coal beneath two previously mined seams. Subsidence impacts are difficult to predict, and these are tripled with this proposal, introducing risk to a sensitive and vital area.

- The application does not consider the cumulative impacts to the Special Areas of this proposal along with past workings, when cumulative damage to the drinking water supply is a major risk that must be considered.

- This proposal will increase coal particulate pollution. Russell Vale Colliery is located in a densely populated area, with houses and schools bordering the site. Coal dust will impact the health of local residents, and those along the truck route to Port Kembla Coal Terminal.

Attention: Director, Mining and Industry Projects
Major Projects Assessment
Department of Planning
GPO Box 39
Sydney NSW 2001

Objections to Proposal MP 10_0046 MOD 2

As a public health academic, well aware of the many challenges facing Sydney's water catchment, I am extremely concerned and strongly object to the proposal by Wollongong Coal (formerly Gujarat NRE) for Modification to the Preliminary Works Project MP 10_0046.

I do not support Wollongong Coal's proposal to expand its longwall mining operation under the Special Protected Areas of Sydney's water catchment. The activities proposed do not represent a mere modification - they are significant and substantial actions with important environmental health risks. Furthermore, given existing impacts, I strongly object to the additional uncertainty of subsidence and subsurface and ground water impacts of mining a third seam underneath two previously mined seams.

Before any accurate assessment of the merits of this proposal versus its costs to the community, more information on potential direct health impacts is required. In particular, the current and enhanced risk of exposure of the local population to air-borne particulates from the coal stockpiles at the Russell Vale Colliery, and from exposures and accidents associated with the truck transport of coal to the Port Kembla Coal Terminal need to be assessed.

I declare my interest is in the protection of human health and wellbeing, and emphasise that, particularly in the coming decades, these fundamental values will be increasingly determined by the degree of environmental integrity we have maintained. I note that in most discourse and writing about longwall mining in the catchment, there is little reference to the fact that protecting water catchments and water security also equates to the protection of human health. Hence when activities cause ecological and structural damage and raise uncertainties about water security and/or affordability, these are also threats to human health.

The location of this proposed mining activity is one, if not the, most important areas of land in Australia for human health. Sydney and surrounding areas is home to 4.6million people, roughly 20% of the nation's population. This number is expected to rise to about 6 million by 2036, likely increasing household, agricultural and industrial demand and pressure on the water catchment areas to meet that demand.

A clean, secure, sufficient and affordable water supply is an absolutely fundamental requirement of good population health. Australia is the driest inhabited continent on the planet. Greenhouse gas pollution has already increased our average temperature by 0.9oC, and we have experienced longer and more severe droughts. This has had and will increasingly exert visible and painful impacts on our health, wellbeing and food production sector, which is severely limited by water availability.
Temperature increases will at least double, depending on the speed of our transition away from fossil fuels, and rise many-fold if we don't move fast enough. Hence, in addition to the population pressures mentioned above, the catchment will also be facing the following challenges:
* In dry times:
o more heat increasing evaporation from all open areas of the catchment,
o more severe and longer droughts reducing inflows into the catchment,
o more severe bushfires reducing vegetation and increasing heavy metals and other pollutants and erosion
* And in wet times:
o more downpours and floods, increasing run off and the risk of contamination and subsequent eutrophication in dry periods.

It is imperative that we look at the existing and proposed impacts of longwall mining in our Special Protected Areas of the water catchment in light of decreasing reliability of water inflows at the same time as an increase in demand for the growing metropolitan and greater Sydney region.

There is no doubt that the four coal mines that have been operating in Sydney's water catchment have had a large, visible structural impact, which includes fracturing of rock bars and riverbeds, loss of flows and drainage of pools, interference with natural groundwater flows and surface to groundwater interfaces, mobilization of metals leading to high and toxic concentrations to aquatic life and degradation of ecological and aesthetic values of these important areas. At particular risk are the now endangered upland swamps, which play a key role in holding water and maintaining creek flows are badly affected by subsidence.

This is the context in which the Wollongong Coal proposes to expand its operations of an additional longwall, and remarkably proposes to mine a third seam, underneath two previously mined seams underneath these sensitive areas.

The proposed Longwall 6 is located beneath two Upland Swamps of Special Significance that feed into the Cataract Reservoir. The reservoir's feeder creek, Cataract Creek, is also within the subsidence area. Based on existing knowledge about subsidence in these areas, there is every opportunity for unpredictable impacts to occur that will seriously impact on the ecological and structural integrity of this part of the catchment.

Increased water consumption from the proposed expansion will also be significant, with increased groundwater flows into the mine estimated to be 1.1-1.6 million litres each day, adding to the enormous use of ground and surface water to underground coal mining across the entire catchment, of an estimated 3 billion litres.

 
In summary, in the interests of human health and water security for the people of Sydney and future generations, and the uncertainties already inherent in the continued provision of our most necessary and limited resource given population pressures and climate change, I urge the Department of Primary Industries to take the responsible step in rejecting this proposal.

The one impact that is truly under our control is the reduction of activities that cause direct risks to the functional capacity of our catchments - that is, longwall mining. This proposal, regardless of its potential merits, introduces a range of new risks to an already challenged situation. Kindly put human health and future water security as a priority, and protect the community from the known and additional uncertainties associated with this unacceptable proposal.

I have not made a reportable political donation.

Yours sincerely,


Dr. Melissa Haswell, Associate Professor of Public Health and Community Medicine, UNSW

please reconsider this action , our water needs to stay safe and clean

I object to the above submission on the following grounds:
- The new section of the underground coal mine, Longwall 6, is located in the Sydney Water Catchment Special Area, an area so vital to the integrity of the water catchment that a member of the public could be fined $44,000 just for stepping foot in there.
- Wollongong Coal acknowledges that the longwall may crack two upland swamps and Cataract Creek. Both swamps and Cataract Creek feed into Cataract Dam. Cataract Dam is one of the water storage dams for sydney Water Catchment Area, an area that supplies drinking water for 4.6 million residents in Greater Sydney.
- The development will increase groundwater inflows into the mine by half a million litres a year.