Mod 3 - Water Discharges + Coal Extraction

My submission to this development application is similar to the one I summit about the part 1 of the development. Arguments still apply. Please find my submission below.

Hello,

I strongly object to this new modification to Moolarben Coal Mine, the 14th one on the original project.
The number of modifications shows how the project strongly departs from initial approval.
I would like to also point out that due to recent amendments to the EP&A Act 1979 past by NSW Parliament, part 3A modifications will cease to be an available pathway in the next few months.
Adding an extra part 3A modification just before they are repealed goes against the intention of recent amendments to the EP&A act. These new modifications to Moolarben Coal Mine should be assessed under the new legislation.
My objection to this development, in addition to the fact that it is based on an obsolete piece of planning legislation, is based on the following 5 distinct categories of grounds and 15 subsequent points:
A/ Groundwater and River system related impacts
1. MCO proposed increase of licenced water discharge into the Goulburn River to
20 million litres per day will further degrade water quality and cause additional ecological stress to the river. The dumping of large quantities of salt every day in the river system will alter the natural ecological state of this essential resource for current and future communities.
2. The current MCO discharge licence of 10 million litres per day was never used. This existing licence is more than adequate, and does not require to be doubled.
3. The Water Management Plan for previous approvals, required by October last year, is not available. This does not allow the community and planning authorities to make informed decisions about this development application.
4. Brine from water treatment plant used for dust suppression will drain into sediment dams that are designed to overflow into the river adding more salt that hasn't been accounted for
5. Groundwater model assumptions do not reflect potential impacts on springs and the upper groundwater system
6. Long term effects of dewatering and draining the landscape above the mine have not been properly assessed
7. Considering all previous points about increase to licenced water discharge, salt discharge increase, absence of long term studies on effects, it is highly likely that approval of this part 3A Mod will threaten the Goulburn River National Park, downstream water users, and the Hunter River Salinity Trading Scheme
B/ Impact on noise and dust levels
1. Compliance of the mine with existing requirements linked to noise and dust conditions is based on the ongoing purchase of neighbouring properties that were not afforded acquisition rights in previous approvals. This puts at risk the social sustainability of the local communities. It is highly unlikely that MCO would have complied with existing noise and dust requirements without these purchases.

C/ Impact on biodiversity
1. The agreement in The Drip Deed to protect additional areas of land as State Conservation Area has not been met under the agreed timeframe of March 2017
2. Areas of two critically endangered ecological communities will be destroyed and habitat for 9 threatened bird species and 5 threatened microbat species recorded in the area. There is also loss of potential habitat for Koala, Regent Honeyeater and Brush-tailed Rock Wallaby
3. The biodiversity offset strategy has not been finalised
4. These dramatic impacts on the local biodiversity are contrary to the objects of the EP&A Act 1979. As reminded by Scot Mac Donald MLC during recent debates about amendments to the EP&A "the objects that are facilitating ecologically sustainable development and protecting the environment, including the conservation of threatened and other species of native animals and plants, ecological communities and their habitats". The proposed development goes against these objects due to points raised above in points 1.,2. And 3.
D/ Development negatively impacting local, state and national levels of carbon emissions
1. The proposal to increase coal production to 22 mtpa until 2038 is an unacceptable increase in carbon emissions, including fugitive emissions. Climate change is an imminent critical threat to the environment, society and the economy. These costs have not been assessed. As pointed out by Mr. David Shoebridge MLC during discussions in the Legislative Council about changes to the EP&A, "when it comes to mining, petroleum production and other extractive industries, that the current planning bill and current planning law have major flaws, in fact, climate-busting flaws, especially when it comes to the extraction of coal in New South Wales. The way that the planning Act operates is that if there is a large coalmine in the Hunter Valley, the planning Act will consider the greenhouse gas emissions in building a railway line out to the coalmine, putting in some trucks, using all the farmland, digging a ruddy great hole, digging up the coal, putting it on the rail line and sending it to the port, but that is it. For some reason the planning Act in New South Wales seems to pretend that the coal is not being burnt and ignores the 2½ tonnes of greenhouse gas emissions that are produced for every tonne of coal that is being burnt as though it is all going to be burnt on a different planet."
2. The NSW Climate Change Policy Framework establishes long-term objectives to achieve net zero emissions by 2050 and to make New South Wales more resilient to a changing climate. Increasing coal production to 22 millions of tonnes per annum goes directly against the NSW Climate Change Policy Framework. Reaching the targets agreed by Australia during the Paris Agreement with most other sovereign countries of the world necessarily implies to refuse approval to this development.

E/ Impact on local jobs and industries in the area
1. The increased coal production will not increase jobs nor guarantee job security.
2. The increased reliance on mines in the area for providing jobs is a threat to the economy, being given that diversification of sectors, industries and jobs is an economic asset. If the price of coal was to fall on transnational markets, and production was to be dramatically decreased, the socio-economic impacts in the Mudgee area would have a strong negative impact on the local communities. There are many international examples of the dangers of economic reliance on primary industries such as coal mining.

I urge you to consider my objection to this development. Impacts on water, noise and dust level, biodiversity, and greenhouse gases emissions are too important.
More in depth and long term studies are required before to statute on this development application.

Regards,
Thomas C.

Submission regarding Moolarben Coal 1 - MOD 3

I oppose this application for a number of reasons as outlined below:

1. Loss of habitat

I am concerned about the 81 hectares of disturbance to the flora including 39 hectares of native vegetation. This includes 7 hectares of threatened ecological communities.

This will result in loss of habitat for the 10 threatened fauna species that were identified in the surveys.

I am not satisfied that the environmental offsets have been adequately calculated. Similarly, I am not satisfied that the effects are "short term", under the assumption that the area will be area will be rehabilitated after mining has ceased. Rehabilitation has rarely been shown to be successful.

2. Increased Train Movements

Increased train movements will result in increase emission along the entire route to Newcastle Port. Recent applications for coal loading ports in the USA have been rejected due to the increased health effects on the local community. Specifically it was estimated that there is a 30% increase risk of cancer for those along the railway line.

http://www.ecy.wa.gov/geographic/millennium/

3. Loss of Aboriginal Heritage Sites

There are 9 new Aboriginal heritage sites identified in the survey. 2 of these fall within the modification area. On is considered of moderate scientific significance. However, they are all identified as having high cultural significance to the Aboriginal community.

4. Increased Coal Production

The modification proposes an increase in coal production. It is well documented that anthropomorphic climate change is occurring and any increase in coal production and burning is detrimental to the future of our planet and subsequently our health. There is no excuse for further coal production.

5. Air Quality

Increase production of coal will result in an increase in emissions. There has been over 70 air quality alerts in the upper Hunter in 2017. Consequently any increase in local emissions will cause a deterioration in air quality.

It should also be noted that there is not adequate baseline PM2.5 air quality records in the local area. Consequently, the estimates for Pm2.5 are likely to be inaccurate. Before any expansion of the mining occurs there needs to be adequate baseline PM2.5 data. As outlined in the application, there is "no readily available ambient PM2.5 monitoring data collected near the Moolarben Coal Complex".

Similarly, the data for PM10 ambient levels are based on measurements from 2011-2012. There has been further mining since that time as well as a deterioration in air quality. Consequently, the PM10 data is also unreliable.

There has been a failure of mitigation methods for deterioration in air quality in the Upper Hunter. Consequently, I have no confidence that the mitigation methods that our outlined in the application will be effective in mitigation against a deterioration in air quality.

6. Increased Greenhouse Gas Emissions

Increase in the production of coal will increase total global emissions. Australia is already struggling to fulfil its commitments to the Paris Agreement. Any increase in mining will make this harder to achieve.

Summary

I oppose this modification due to the increase health risks related to worsening of air quality and an increase in global emissions relate to the production of the coal as well as the subsequent burning of the coal.

Furthermore, I oppose this modification due to the damage to flora and fauna as well as Aboriginal heritage sites.