MOD 8 - Water Transfer to Western Coal Services

Dear Sir/Madam,

I am a resident of Kanimbla, NSW 2790. Our property border sthe Coxs River south of Lake Lyell and we use it for garden irrigation and recreational swimming. I’m also a keen bushwalker and visit the Gardens of Stone SCA regularly, incl. Newnes Plateau, Ben Bullen, Wolgan State Forests as well as Wollemi and Blue Mountains NP.
I have some concerns/objections to the proposal and ask for them to be considered in a revised version of the plan and before approval.

Potential contamination of Coxs river and Sydney’s drinking water supplies

Whilst it is positive to hear that the level of salinity and pollutant contamination at LDP001 is likely to be decreased through the dilution of discharge, concentrations are still too high.
My own measurements of conductivity of Coxs River in the Kanimbla Valley clearly show that conductivity (hence salinity) is most above the ANZECC standard of 350μS/cm (see graph in PDF attachment).

Any additional discharge of higher concentrations is likely to increase salinity further. Also, the mine effluent will have elevated levels of heavy metals if salinity is treated to the proposed 350μS/cm standard. This level of treatment may not adequately protect aquatic ecosystems, especially macroinvertebrates, given the flow of mine water at the LDP001 entry point into Wangcol Creek. Wangcol Creek flows to the Coxs River and is part of Sydney’s Drinking Water Catchment. The modifications will see more contaminated mine water going into the Wangcol Creek from the Western Coal Services site. This water is likely to be contaminated with toxic chemicals such as arsenic and selenium that have been recorded as present in the mine water of the Springvale-Angus Place mine water system.
The proposed discharges should not meet the “neutral or beneficial” test for water pollution because it adds to the overall pollution load in the creek. The transfer of 10ML/day of mine water from Angus Place to the Western Coal Services site for discharge should not be allowed. Adding mine water to a highly polluted element of the Wangcol Creek catchment is also likely to flush out more heavy metals from that contaminated site. These contaminated discharges would then enter the Coxs River, a key part of Sydney's water catchment that flows through the Greater Blue Mountains World Heritage Area.
These modification proposals to allow large discharges of mine water also defeat the purpose of the Springvale Water Treatment Project (SSD-7592, approved in June 2017) that was built to eliminate mine water discharges into the Coxs River catchment from Springvale Mine and Angus Place Colliery.

Potential damage to important wetlands

In 2018, Angus Place Mine Modification 5 was approved allowing pumping at a rate of 10 ML/day from mine workings (areas 800 and 900). Following this approval, the groundwater table dropped between 21 and 30 metres (Centennial Coal, Coxs River Swamp Review, July 2018, pg 44). This drop in groundwater was observed to quickly dry out Kangaroo and Lambs Creeks and associated swamps, as well as the Coxs River and swamps (Lithgow Environment Group, pers. comm. 4 Oct, 2023).
Since 2018, far-field loss of surface waters in Newnes Plateau streams and swamps has been observed over a kilometre away following depressurisation of groundwater in a coal seam due to coal mining at Springvale. Such far-field impacts may explain the observations made by Lithgow Environment Centre in 2018 and why future surface water losses from dewatering areas 800 and 900 may be expected.
The proposed modification 8 which would allow pumping at 10ML/day from areas 800 and 900 will again lower the groundwater table.
Due to the proximity of the Lithgow Coal seam to the surface at Angus Place West project area, the proposed pumping may also cause regional drawdown or localised far-field drawdown of near-surface groundwater. The pumping may damage Kangaroo and Lambs Creeks and swamps, as well as the upper Coxs River and its swamps. Nationally endangered plants may also be harmed, including Xerochrysum palustre (Swamp everlasting), Pultenaea glabra, Kunzea cambagei, Veronica blakleyi, Grevillea acanthifolia, Gentianella cunninghamii, Prasophyllum australe and Latham's Snipe (a rare migratory bird species).
Thank you for taking note of these comments.

Yours sincerely,

Prof. Thomas Wiedmann
Kanimbla, NSW 2790

Wellington Valley Wiradjuri Aboriginal Corporation membership are supportive of Centennial Coal's modification and believe that it will have environmental and economic benefits for the region.

Please see attachment

I whole heartedly object to the proposal for many reasons including -
• The lack of time for comment on these damaging proposals
• The modification proposals should be part of the Angus Place West major project, not treated like a separate project
• Nationally endangered wetlands and swamps could be damaged
• Sydney's drinking water supplies might be contaminated – the water Centennial Coal is proposing to dump can't be treated at the specially built 40ML/day mine water treatment plant
• The modification proposals should be subjected to scrutiny under Federal environmental law
• Centennial's track record means its environmental report on these proposals should not be relied upon
• Another reverse osmosis treatment plant is needed right now to treat this additional mine water.
* Australia should be doing its utmost to stop any more coal mining and instead develop renewable energy

I have been a resident of the Blue Mountains for over 40 years. My son has grown up here in the Blue Mountains World Heritage National Park where he and his friends use the area for bush-walking, rock climbing, bird watching and photography. My family and friends are also keen bush-walkers and observe the amazing array of fauna and flora. The enormous value of this area for recreational enjoyment and environmental conservation cannot be over-stated.
I am objecting to this proposal for the following reasons:
If approved, these modifications could obscure the extent of impacts from the future Angus Place West mine expansion proposal on national heritage in the new Gardens of Stone reserve. Modifications are supposed to allow for minor changes to approved major projects. These modifications could damage nationally endangered swamps and plants and drain water from streams in the new Gardens of Stone State Conservation Area. These proposals seek to by-pass the $120 million reverse osmosis mine water treatment plant and permit the discharge of mine water into the Coxs River catchment.
It appears that Centennial Coal is trying to get around the purposes of the Environmental Planning and Assessment Act, 1979

In 2018, Angus Place Mine Modification 5 was approved allowing pumping at a rate of 10 ML/day from mine workings (areas 800 and 900). Following this approval, the groundwater table dropped between 21 and 30 metres (Centennial Coal, Coxs River Swamp Review, July 2018, pg 44). This drop in groundwater was observed to quickly dry out Kangaroo and Lambs Creeks and associated swamps, as well as the Coxs River and swamps (Lithgow Environment Group, pers. comm. 4 Oct, 2023). Since 2018, far-field loss of surface waters in Newnes Plateau streams and swamps have been observed over a kilometre away following depressurisation of groundwater in a coal seam due to coal mining at Springvale.
Such far-field impacts may explain the observations made by Lithgow Environment Centre in 2018 and why future surface water losses from dewatering areas 800 and 900 may be expected. The proposed modification 8 which would allow pumping at 10ML/day from areas 800 and 900 is likely to again lower the groundwater table, and probably also impact on surface water resources in the area of operations for the Angus Place West proposal.
Other consequences of this proposal could mean that nationally endangered plants may also be harmed
The mine effluent will have elevated levels of heavy metals if salinity is treated to the proposed 350?S/cm standard. This level of treatment may not adequately protect aquatic ecosystems
Wangcol Creek flows to the Coxs River and is part of Sydney�s Drinking Water Catchment. The modifications will see more contaminated mine water going into the Wangcol Creek from the Western Coal Services site. This water is likely to be contaminated with toxic chemicals such as arsenic and selenium that have been recorded as present in the mine water of the Springvale-Angus Place mine water system.
This would risk contamination of Sydney’s water supply.
I am concerned that the modifications have not been referred for Commonwealth assessment under the EPBC Act. We think that this project is likely to have significant impacts on water and that the modifications should be referred to Environment Minister Plibersek to determine if the water trigger applies. Commonwealth assessment and the application of the water trigger is important to ensure that there is rigorous assessment of the surface and groundwater impacts of the modifications.

The mine water that is to be discharged into the Coxs River flows downstream into the Greater Blue Mountains World Heritage Area. Any downstream impacts of mine water arising from the proposed modifications on World Heritage values of the World Heritage property must be considered. They are likely to impact on water resources of a drinking water catchment, a World Heritage Area and nationally endangered plants and communities. Nationally endangered wetlands and swamps could be damaged
Modification 8 Angus Place and Modification 5 Western Coal Services should be controlled actions under the EPBC Act.

Centennial has failed to demonstrate that it can operate responsibly in the Gardens of Stone region without causing irreversible damage to the environment. Records of environmental incidents and harm, consent and licence non-compliances, and inaccurate predictions of environmental impacts from its operations suggest that current impact predictions in the environmental assessment for these modifications should not be relied upon. An audit of Centennial�s mining licences for the past five years has found at least 134 licence non-compliances across its sites in the Gardens of Stone region.
It is for these reasons that I strongly oppose this modification proposal.
I would also like to raise my concern over proposal process;
The lack of time for comment on these damaging proposals
The modification proposals should be part of the Angus Place West major project, not treated like a separate project
The modification proposals should be subjected to scrutiny under Federal environmental law

I have two concerns about Centennial Coal's latest plans for its Angus Place Mine:
1. As a resident of Sydney, I find it entirely unacceptable that a coal mine should be permitted to act in a way that risks contaminating Sydney's precious water supplies with toxic metals. My understanding is that the level of treatment of proposed mine effluent may not be sufficient to prevent toxic chemicals like arsenic and selenium from entering the Wangcol Creek catchment, with the likelihood that they will flow into Cox's River and from there into Sydney's water catchment. Even a slight elevation in the levels of these chemicals puts at risk the health of millions.
2. As a regular visitor to the Gardens of Stone region, I am very conscious that this is an important ecosystem with high environmental values, as well as a place of great natural beauty. It needs to be protected, not put at further risk by coal mining. Centennial Coal has a poor track record in terms of environmental damage from its coal mining operations, and this indicates that the NSW public cannot trust its assurances. As recently as 2022, Centennial breached its development consent for Airly mine resulting in significant fractures to million-year-old sandstone pagoda. Its operations have also drained water from creeks and swamp areas. As the impact of climate change on our weather increases, with increased temperatures, we cannot afford to put our remaining natural water systems under further pressure. That's leaving aside the general impact of mining and burning more coal generating more carbon emissions and generating more climate change, caused by Centennial's operations.

Please see attached submission. Please consider the climate change implications of the project as well as the environmental concerns that I have outlined.

As a keen bushwalker and a person concerned about out natural environment I would like to object to Centennial Coal’s plan to pump toxic effluent from the Angus Place Coal Mine into Sydney’s drinking water catchment area in order to lay the groundwork for a new coal mine. I am deeply concerned both by the development of new coal mines and the possible results of the pump out in damaging nationally endangered wetlands and swamps in the area. I am also concerned that Sydney’s water supplies may be contaminated by the pump out

Please confirm receipt of submission

Summary of objections:
• There has been a lack of time to comment on these damaging proposals
• The modification proposals should be part of the Angus Place West major project, not treated like a separate project
• Nationally endangered wetlands and swamps could be damaged
• Sydney's drinking water supplies might be contaminated – the water they are proposing to dump can't be treated at the specially built 40ML/day mine water treatment plant
• The modification proposals should be subjected to scrutiny under Federal environmental law
• Centennial's track record means its environmental report on these proposals should not be relied upon
• Another reverse osmosis treatment plant is needed right now to treat this additional mine water.
Please see attachment for further comments.

I am a resident of NSW and I am deeply concerned about the damage that we are doing to our environment, locally in NSW, nationally across Australia, and globally. Like many people I value greatly the natural environment and spend a lot of time in it, mostly walking and birdwatching, and I was delighted when the significance of the Gardens of Stone area recently received formal recognition.

As a public health doctor, I am extremely aware of the damage that is being done to human health by the degradation of the environment. It is obvious that human health and welfare is completely dependent on having a healthy natural environment and that civilisations have developed over the last 12,000 years only because we have enjoyed an historically unique period of environmental and meteorological stability. This is threatened, in fact already being undermined, by the damage we are doing to the environment. The consequence is completely unnecessary illness and premature death.

I am greatly concerned by the proposal by Centennial Coal to pump toxic waste from the Angus Place coal mine and dump it into Sydney’s water catchment area. This is completely irresponsible.

I also think it is ridiculous that Centennial Coal can take as long as it likes to prepare and submit its proposal and yet the public is given only two weeks to make submissions about it. I would have hoped that the NSW government, anxious to make the best decision possible, and take all factors into consideration, would be keen to give the public ample opportunity to respond to the proposal. Two weeks is unfair, inefficient and an insult to the citizens of NSW. I fail to see what possible reasonable reason there can be for this extremely short time frame. It would be appropriate in my view for the government to extend the submission period for at least four weeks beyond the current deadline.

Returning to the proposal itself:
• The modifications being proposed should be considered with the proposed Angus Place West mine expansion, not on their own. This fragmentation of proposals is nothing but a ruse to prevent all the impacts being considered together.
• The modifications are likely to pollute surface water and have a severe harmful effect on the ecology of several local creeks and swamps.
• The contaminated waste will contaminate Sydney’s drinking water and will contribute to ill health among the population.
• The modifications should be referred to the Commonwealth government for assessment under the EPBC Act.
• It is now well recognised that if global warming is to be kept under the internationally agreed 1.5oC, no new fossil fuel projects, including expansions of existing ones, should be approved.
• The dreadful consequences for human health of global warming are also now well recognised. These are already occurring and will get worse as greenhouse gas emissions continue.

In my view, it is completely irresponsible in terms of the local environment, Sydney’s drinking water, climate change and human health for this proposal to be approved.

see attached

I object to the proposal. The short-term benefits are significantly outweighed by the permanent impacts of the proposal, including impacts to the Greater Blue Mountains World Heritage Area. The proposal and assessment are critically flawed and far too brief to merit approval, for the following reasons.

- The assessment of impacts is far too brief and requires further detail and assessment.

- The length of time for consultation and submissions is too short.

- The assessment has not considered any potential impacts from groundwater drawdown due to removal of mine / groundwater, including assessing potential impacts to swamps or wetlands.

- The assessment of impacts to surface water states there will be an increase in some metals discharged into the Coxs River catchment, which flows into the Greater Blue Mountains World Heritage Area.

- The assessment of impacts to surface water justifies discharges to the Coxs River catchment by saying discharges will dilute existing approved more contaminated discharges. This justification should in no way be acceptable. Any water discharged into the Greater Blue Mountains World Heritage Area catchment should be treated to a high standard.

- The proposal does not provide intergenerational equity - "that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations". Continued extraction of coal leading to greenhouse gas emissions, drawdown of groundwater and discharge of untreated water into the Coxs River catchment in no way maintains or enhances the environment for future generations.

- Centennial Coal has a track record of repeated and serious environmental breaches causing permanent damage to the Greater Blue Mountains World Heritage Area which should be taken into account, including discharge of coal fines into the Wollangambe River, fracturing of pagodas, and permanent loss of peat swamps.