Mod 4 - Sound Power Levels

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I completely object to the modification.

This submission opposing Maules Creek( Mod 4 ) Sound Power Levels is submitted by New England Greens Armidale Tamworth (NEGAT), which includes members and supporters in the immediate vicinity of the Maules Creek Coal Mine.
NEGAT is aware that Whitehaven's Maules Creek Coal Mine is now one of only three mines in NSW to hold the Environmental Protection Agency's highest environmental risk level (level 3), following a review of incidents in the past 12 months to May 2017. The company has a record of noise non-compliance and incurred an official warning by the Department of Planning in August 2017.
The Department of Planning's failure to take account of community concerns prior to approval must not be exacerbated by approval of this modification. Mandatory Noise Audits in 2015 and 2016 revealed that many of the fixed plant at MCCM were unable to operate within the noise levels Whitehaven provided to the Department to gain approval.
The lack of transparency of process causes concern: in May 2016, the Department of Planning issued Maules Creek Coal Mine with an advisory letter and show cause letters regarding 2015 Sound Power Levels of mobile and fixed plant equipment. Maules Creek Coal Mine reportedly provided a written response and action plan, but this has not been made public. Similarly noise filters, which filter out certain sound frequency levels, are being incorrectly or inappropriately applied during monthly compliance monitoring, and Whitehaven refuses to disclose the filters being used to the community.
There has been no public consultation for this proposed modification and no explanation as to why it should be granted. This is a standard "sound power" clause; all other mines in the region have this clause and manage to abide by it. A consistent, regulatory framework across the region is desirable. Communities have the right to expect compliance and consistent improvement in environmental performance from mining companies as technologies improve. The mine is expanding to the west and north; as more communities are impacted the requirement should surely be for more stringent commitment to the regulations.
The practice of gaining modifications rather than implementing regulations has occurred to the detriment of the community and local environment previously in Whitehaven's operations- it is unconscionable that Maules Creek Coal Mine should once again be rewarded for failure to conform to the regulations by having sound regulations modified.

Please see attached submission

I object to this Modification. I attach my submission and an attachment which is the full data of a noise reading outside Kumbogie property on 6th June 2015 which was an exceedance of mine noise limits. There were no extraneous noises on that occasion of monitoring.

See attached

submission uploaded

This submission is an OBJECTION to the Maules Creek Coal Mine Modification 4.
This is a brazen and disgraceful ask of a company with a poor noise record

On behalf of the Leard Forest Research Node, the citizen science group based in Maules Creek, NSW, I attach a submission against Modification 4 of the Maules Creek mine approval. I also attach "Noise Impacts from Mines in Rural Areas" by Hunter and Central Rivers Alliance and the Leard Forest Research Node, 2017.

All references to noise monitoring by LFRN are based on unfiltered noise, all operator record sheets are available for viewing. All monitoring is conducted on nights with no extraneous noise whatsoever, and if there are any they are manually as per discussed with NSW EPA and approved.

submission attached

Please see our submission attached.

Please see attached letter objecting to theproposed changes at Maules Creek

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uploaded

pdf OBJECTION attached

I object to this proposal submission uploaded

This submission is an objection to the Maules Creek Coal Mine Modification 4- Sound Power Levels. Thank you for the opportunity to take part in consideration of this proposal.

In the past I was able to camp on a friends' property in the Maules Creek area and enjoy the quiet beauty of the area. That stopped when Maules Creek coal mine arrived with its day and night long noise pollution, light pollution and air pollution.

I read with dismay that, Maules Creek is now one of three mines in NSW with the highest environmental of risk level.

I understand that Maules Creek coal mine has been unable to comply with a sound condition (Condition 12a of Schedule 3) which stipulates that the Sound Power Levels (SWLs) of fixed and mobile machinery at the mine must be "equal to, or better than, the indicative SWLs adopted for modelling purposes in the Maules Creek Coal Project Environmental Assessment"

The community at Maules Creek has long argued that false and misleading noise modelling was provided by Whitehaven Coal in its original Environmental Assessment in order to gain approval.

I further understand that:
* Whitehaven's most recent annual environmental review in 2016 admitted that the company was not compliant with this "sound power level" condition. That report also details non-compliance with blast level criteria and blast monitoring requirements;
* The mine has also reported non-compliance with the relevant noise criteria for some nearby properties, but disregards non-compliant reading that are 2 decibels above the noise limit specified in its conditions. This effectively means that Maules Creek coal mine considers itself to be operating on a 37dbA limit, not 35dbA, as specified in its approval;
* The sound compliance levels expected of Whitehaven are the same as those required of other mines in the region.

At a time when Whitehaven is expanding mining activity and has committed to reviewing its plant and equipment to reduce noise, it is simply inconceivable that this application should be granted; Whitehaven must be held to the commitments they made to the local community and the wider community of NSW when it obtained approval for these operations.

12th October 2017
Carolyn McNally
Secretary
Department of Planning and Environment [email protected]
Dear Ms McNally,
Re: Maules Creek coal mine Project Application Number: 10_0138 Mod 4
The proponent Whitehaven Coal, are seeking to remove a section from Condition 12a, Schedule 3 from Planning Approval 10_0138 regarding the Maules Creek coal mine. That is the deletion of the wording and requirement to-
"ensure that all equipment and noise control measures deliver sound power levels that are equal to or better than the sound power levels identified in the EA, and correspond to best practice or the application of the best available technology economically achievable;"
I object to the Mod 4 and Whitehaven Coal removing a specific requirement for continuous environmental noise improvement by maintaining or reducing mining equipment sound power. I disagree that a mine can be approved under specific conditions and then seek to change these conditions to support its continuous noncompliance.
Being that the mine is seeking to expand, it is paramount that more stringent noise control measures are exercised not more lenient requirements.
This will be detrimental for the community surrounding Maules Creek, and will make the whole planning assessment look like a joke if this is granted.
As the Department of Planning ignored the community's rejection of the mine and has consequently led to the mine being ranked as one of the worst in the State as far as environmental protection. The Department now has an obligation to ensure that Whitehaven Coal adheres to its compliance requirements, not allow changes to the requirements to suit Whitehaven Coal.
I strongly support the rejection of this Modification 4, and expect that the wishes of the local community be heard and respected.
Thank you for your consideration.

Please see attached letter.