Modification 4 Longwall 317 and 318 Modification

I am a resident of the Sutherland Shire, and I deeply value both the Royal National Park and the Woronora Reservoir. The reservoir provides our community with safe, clean drinking water, and I am seriously concerned that the proposed mine expansion places this essential water supply at risk. Any long-term damage or contamination would be unacceptable for our region and for future generations.

Although the Metropolitan Mine extracts metallurgical coal for steel production, the climate impact of its operations remains severe.

* In the 2024 financial year, Metropolitan’s Scope 1 emissions reached almost 700,000 tonnes of CO₂-equivalent — the highest since the Safeguard Mechanism began in 2016.
* More than 80% of these emissions were methane, which has 86 times the warming potential of carbon dioxide over a 20-year period.
* Metropolitan is now the fifth largest Scope 1 emitter of all coal mines in NSW.

NSW has committed to net zero targets, but approving further expansions of high-emission coal projects directly undermines these commitments. Continuing to lock in new sources of greenhouse gases makes it harder for our state to meet its climate goals and exposes our communities to the worsening impacts of climate change, such as extreme heat, bushfires, and storms.

I strongly urge the NSW Planning Department to reject this proposed mine expansion. Protecting our drinking water supply and meeting our climate commitments must take priority over extending the life of a high-emissions coal project.

As my friend drove me through the Royal National Park, I could not help but think to myself: How could
anyone not fall in love with this place? How could you possibly trade this gift for something else?
And yet, that is exactly what is happening. The environment is being sacrificed for something else -
something that promises profit and wealth, quick and easy. But at what cost?
The swamps in the Woronora Reservoir area will be irreversibly damaged. What has been here for 15,000
years, long before British coloniser came to this land, is at risk of perishing forever. It leads to degradation of
the whole ecosystem. Along with that is the loss of the home for countless species, much like the way the
land was taken from Aboriginal and Torres Strait Islander people. Do we want to make the same mistake
again? Have we learnt nothing from history?
You may not realise how lucky you are to have such easy access to the nature. It took me approximately 9
hours to fly across the ocean, to have my feet on this land. I have been to European countries, I was bom in
Vietnam, and there is no place as special as Australia. My love for the nature began here. Growing up, I did
not know what it feels to be surrounded by the trees, with clear sky above my head and drinkable water under
my feet.
You may not recognise the privilege you have - being able to breathe without hesitation, to walk outside
without wearing a mask, to drink clean water straight from the tap. And now, you are taking it for granted.
Please, take a moment to imagine what life would be like if these things were no longer true. The stakes are
high, and your way of life is not prepared for what would come.
You may need coal to generate energy to your house. But remember, it is nature that sustains us. Nature is
where our homes are, and it is what gives us life.
I am just an individual, but I speak not only for myself, but for generations from the past to the future. And I
am also speaking for the creatures that don’t share our language, but whose lives are intertwined with ours.
We are a part of nature. To betray nature is to betray ourselves.
If we don’t protect this land, the damage will be irreversible, and the cost will be far greater than any profit.
Let us not be the generation that sacrifices the nature for the sake of temporary gain. Let us be the generation
that protects what truly matters.

25 August 2025

OBJECTING TO METROPOLITAN MINE MODIFICATION 4 LONGWALL 317 AND 318 MODIFICATION

I am writing to strongly object to the proposed Modification 4 – Longwalls 317 and 318, Metropolitan Colliery.

I find it absolutely unbelievable that this proposal – to endanger a critical drinking water source for over 5 million people – could even be considered.

I am a longtime resident of the Sutherland Shire. I greatly value living near the Royal National Park and being surrounded by beautiful waterways and nature. With our growing population, I want to protect our precious environment. This includes our flora, fauna, waterways, climate – and our drinking water. Surely it’s not appropriate to mine in drinking water catchment areas that are so close to the Royal National Park.

Longwall mining is known to cause subsidence, fracturing of rock layers, and irreversible damage to watercourses, reservoirs, and upland swamps. Swamps such as S106 could be at risk, should this proposal go ahead. This will undermine long-term drought resilience and compromise our clean water supply.

I believe this mine to be one of the highest methane emitters in NSW. When we are trying to reach net zero by 2050, should we be even thinking about expanding coal mining in 2025? The recent flooding rains in NSW and the reports about melting sea ice in Antarctica all confirm our climate concerns.

It is unacceptable that the 2009 approval process for this mine to continue its operations is still allowed. At the very least there should be a fresh assessment – a full Environmental Impact Statement – made under current laws and science.

For all the reasons above I strongly urge the Minister to reject this proposal in order to protect our water, environment and climate.

Yours sincerely,
Vicki Simpson
14 Percival Road, Caringbah South, NSW. 2229

Both the Woronora Reservoir Catchment and the Hacking River Catchment are facing irreversible damage from the disastrous effects of Longwall mining.
The polyethylene gap filler used to fill the enormous cracks caused by the mining process is falling into the mine workings.
Peabody should pay for the damage the Longwall Mining has already created.
Retention monies should have been collected as the damage occurred and is still occurring putting Sydney's water supply at risk.
NO OTHER COUNTRY IN THE WORLD MINES UNDER ITS WATER SUPPLY

The proposed modification expansion would not be passed today if it was put through as a new mine application. This modification expansion proposal is underhandidly attempting to bypass stricter environmental protections that mining operations are now subject to. This proposal should be brought before the Independent Planning Commission so we can be sure our catchments are protected.

Already, so much damage has been caused by coal mining, subsidence and seam to surface cracks through rocks - resulting in the loss of millions of litres of water from our water catchment. Creeks and swamps are drained, bushland and forest dry out causing irreversible damage.
Further damage is inevitable if Modification 4 is approved with Peabody estimating the loss of 6 swamps.
Peabody's proposal to clear 4 hectares in the middle of swamp land to build an industrial area is unacceptable. The area is a protected water catchment NOT a mine site.

I oppose the project.
It will cause damage to the Woronora catchment which supplies clean water to the Sutherland Shire. Long wall mining has already caused damage to the area. It will cause contamination to surface water and groundwater. Important environmental vegetattion will be damaged by the clearing.Will cause damage to threatened species and further pollution which the company has already engaged in without regard for the enviornment or anyone. Dont allow this project.

See attached - pdf document

I am very concerned about the modifications proposed by Peabody to their mine. Peabody's track record for preventing water contamination is proven to be poor, with the pollution events of 2022 and this modification risks contaminating drinking water catchments, as well as precious ecosystems in the Coastal Upland Swamps, which are already in danger of going extinct. These impacts on the environment cannot be undone with a fine, this is our biodiversity and water security that is at stake. As a regular walker in the Royal National Park and a resident of Sydney I am shocked that we are discussing modifying and perptuating coal mines when our climate crisis hits new records each year. We know that endangering biodiversity and ecosystems impacts on climate change, too. Finally, I would ask, if approval for these works is granted, how can we be certain that Peabody's mine will NOT impact the local environment illegally, given the already detrimental impact that is already happening on the river and the life it supports. I oppose the modifications proposed.

Dear Sir,
Re: Modification 4 Longwall 317 and 318 Modification
I hereby object to Peabody’s Modification to their mining licence on the following grounds:
1. The extension of the mining activity in the Woronora catchment area will cause greater damage and result in contamination of the drinking water this reservoir supplies to the Sutherland Shire.
2. A number of threatened species will be impacted by this development, including the recently reintroduced platypus to the Royal National Park.
3. This will cause pollution in the Hacking River which will never be remediated.
4. Peabody has already been convicted in the Land and Environment Court and fined for pollution spills.

As a lifetime resident of the Sutherland Shire for the past 28 years, and a scientist working in the water industry, the pristine condition of Sydney’s drinking water is very important to me. Our water supply comes from the Woronora Dam, along with most other areas of the Sutherland Shire. Wornora Dam is the sole water supply to our neighbouring suburbs Helensburgh, Engadine and Lucas Heights. Any work done that would greatly increase the risk of contamination of this clean drinking water is unthinkable, and could greatly impact many residents, particularly those that live in suburbs which solely rely on Wornora Dam and reservoir. A clean water supply is essential to life and not something that should be negotiable in a first world country. As Peabody has already been convicted for pollution spills, I believe the risk is too high to give them further licence to expand their mining operations further into the catchment area. As the world must move into increasing renewable energy, it is preposterous to put an integral part of the Sydney water supply network at risk for further mining.

Growing up close to bushland, and the Royal National Park, I was immersed in the natural environment from a young age. It is this immersion that helped build my passion of working for and with the environment. I felt a great sadness watching the news reports of black sludge being detected in the Hacking River, and seeing images of a thick coal sludge contaminating the water close to the area where platypus had been reintroduced after they were wiped out 50 years ago due to an oil spill. I do not trust Peabody to effectively prevent any further spills. If one should occur, they have not shown to have the capability to remediate damage caused to the environment. The Coastal Upland Swamps which are listed as an Endangered Ecological Community under the Threatened Species Conservation Act, are also under threat by proposed clearing for the mining expansion, and any future contamination caused by this in the area. These environments are particularly vulnerable to ecological collapse caused by outside factors to their environment, and would not be able to be remediated in the event of severe pollution, particularly if large swathes of the environment nearby are cleared.

I take great pride in my position as a water quality analyst, ensuring all of Sydney has water that is safe to drink. We are lucky to live in a city where turning on the tap and receiving water that is safe to consume is a given. If the government allowed this mining expansion, I would be ashamed that our elected officials would put our pristine, world class drinking water network at such great risk.

I strongly oppose this modification and feel it should be brought before the Independent Planning Panel. It is a critical issue that needs to be addressed, before unalterable damage can be done.

Lia Ramsay

I object to this project and have attached my letter of submission.

I am writing to express my strong opposition to the approval of Modification 4 – Longwalls 317 and 318 at the Metropolitan Colliery. As someone who deeply values the protection of natural areas in the Illawarra and across New South Wales, I am alarmed by the risks this expansion poses, particularly to the Royal National Park and the integrity of the Woronora Reservoir, a critical drinking water source for millions of people.

1. The Importance of the Greater Sydney Water Catchment
The Woronora Reservoir is part of Sydney’s drinking water catchment and supplies clean water to over five million residents, including communities in the Sutherland Shire, northern Wollongong, Helensburgh, Engadine, and Lucas Heights. Approving coal mining expansion in such proximity to this vital water source is reckless and short-sighted.

Longwall mining is well-documented to cause ground subsidence, fracture rock layers, and permanently damage watercourses and upland swamps. Independent experts and WaterNSW itself have confirmed that longwall mining has already caused surface cracking, swamp drying, and groundwater diversion in the area, which are undermining water security and the filtration function of natural systems

These processes pose a clear and unacceptable risk to water quality and long-term security of supply, particularly in a future marked by climate change and growing demand. Swamp S106 and other sensitive ecosystems perform a crucial hydrological function, especially during extreme weather events, storing and releasing water slowly. Destroying these systems undermines our drought resilience.

2. Environmental and Biodiversity Concerns
The area under threat is part of a fragile, biodiverse ecosystem home to several threatened and critically endangered species, including:
• Swift Parrot (Critically Endangered)
• Bynoe’s Wattle, Thick-leaf Star-hair, Woronora Beard-heath, and others (Vulnerable)

Disturbing this land through mining-induced subsidence or pollution will only hasten the decline of these species. The proposal also places at risk Aboriginal heritage and culturally significant landscapes, a further unacceptable cost.

Moreover, pollution or habitat degradation caused by mining could extend into the adjacent Royal National Park, Australia’s oldest national park and a place of immense ecological and cultural value. Peabody has a history of causing environmental harm in the region. In 2024, the company was convicted and fined $500,000 for two pollution events where coal sludge contaminated Camp Gully Creek and the Hacking River in the Royal National Park, turning the water black

3. Climate and Emissions Impact
At a time when the NSW Government has committed to Net Zero targets, approving further expansions to one of the state’s highest methane-emitting coal mines is profoundly contradictory.

In FY2024, Metropolitan Colliery’s Scope 1 emissions reached nearly 700,000 tonnes of CO₂-equivalent, with over 80% of those emissions being methane. This makes Metropolitan the fifth highest emitter among all NSW coal mines.

No matter the coal type, the climate impact is clear and devastating. Every tonne of emissions undermines NSW's climate goals and global efforts to limit warming.

4. Social and Strategic Concerns
We must support coal-dependent communities with a just transition, not tie them to decades more of extractive, polluting industries. Continued approval of coal expansions benefits foreign-owned companies like Peabody Energy, which has a poor record of corporate conduct and industrial relations. Peabody pays no corporate tax in Australia, despite profiting heavily from our resources and workforce.

Notably, Peabody has been found guilty of unfairly dismissing workers and locking out employees during lawful industrial actions. It is unjust to compromise vital public resources like our drinking water catchments for the short-term benefit of such a company.

5. Planning Integrity and Proper Process
This expansion relies on a modification pathway under a 2009 approval, an outdated process that fails to account for today’s realities, including the climate crisis, biodiversity collapse, and modern water management challenges.

This proposal poses unacceptable and irreversible risks to our drinking water, biodiversity, climate commitments, and public interest. It compromises long-term sustainability for the benefit of a foreign-owned company with a poor track record.

I urge the NSW Government to reject Modification 4 and invest in supporting coal communities through a fair and sustainable transition. The future of our environment, climate, and water security depends on it.

I oppose the granting of the Modification 4 Longwall 317 and 318 Modification
Continued mining in the Woronora Catchment causes subsidence even with the modification proposals to employ conservative longwall geometry to reduce subsidence effects and environmental impacts. Raised Upland Swamp S77 is predicted to subside up to a maximum amount of 1.45m and Upland Swamp S74 lying above a northern section of Longwall 317 and with a portion above the pillar between it and Longwall 318 is predicted to subside 0.954m or essentially 1m. Further-more a total of 32 Upland swamps are predicted to suffer subsidence as a result of the modification. The cumulative effect of this disturbance will impact surface water flows and cause degrees of dehydration to vegetation and alter the plant types over time. This leads to changes in the ecosystem and losses of plan density due to dehydration will lead to increased erosion and siltation of the catchment.
Damage to Upland swamps is irreversible and they are classified as an endangered ecological community under the Threatened Species Act. Best practice would be to leave them undisturbed. They are also habitat for the Giant Dragonfly presenting another reason for conservation and not compromise.
There are numerous lines of evidence which indicate that impacts from undermining on the Woronora Reservoir stored waters and supporting catchments are substantial, including widespread draining of the ridges due to the imposition of subsidence-induced fracturing and shearing, as well as the metal and salt laden discharging into the Woronora Reservoir. Some biological consequences of these subsidence effects have already been reported, but it is likely that the hydrological, chemical and ecosystem impacts will become much more widespread in coming years and decades.
An allied concern is the extensive fracturing in the Hawkesbury Sandstone aquifer leading to desaturation of the ridges around the reservoir as well as the possibly permanent loss of ecologically important surface flows.
The changed baseflow patterns will alter catchment ecosystems which are adapted for pre-mining conditions. A likely result of these changed baseflow patterns is that a large proportion (potentially all) of the riparian, swamp and forest ecosystems on the undermined ridges will become drier and presumably less capable of filtering surface flows entering the reservoir.
Formation of rapid subsurface flow paths may also be expected to add a substantial but as yet unquantified addition of metal and salt (drinking water contaminants) discharged into this drinking water via subsurface springs created by basal shear planes. These metals are additional to the already alarming exceedance of stream water quality performance indicators with the contamination increasing with the ongoing expansion of the mine beneath the drinking water catchments.
State Planning needs to initiate rigorous studies into understand the long-term impacts or transfer dynamics of the additional metals and salts entering the reservoir from creek and spring discharges due to long wall mining. The addition of metals mobilized by water flows due to surface fractures caused by long wall mining may eventually create a legacy requiring continual high-cost water treatment in the future.
These studies need to be completed before the modification is granted and further mining exploration licenses are considered.
Impacts of the proposed Modification upon Eastern Pygmy Possum, Powerful Owl and Giant Dragonfly will require offsets for predicted impacts associated with vegetation clearance in the Development Footprint. The problems with this methodology is that offsets will occur elsewhere thereby reducing habitat for these lifeforms in the catchment. The catchment is surrounded by urban developments and private holdings with no ability to reduce these for offsets.
Potential indirect impacts to native vegetation adjacent to the Development Footprint include edge effects, changes to hydrology, habitat fragmentation, and potential degradation of habitat quality.
In summary, the Woronora Catchment should be purposed solely for water catchment and not compromised for underground longwall coal mining. Damage to Upland swamps is irreversible and their protected status should be respected. Water quality in the Woronora Dam will be at its best quality for no additional water purification costs if the long wall mining stops and no related additional subsidence impacts the catchment.

As someone who is regularly in the Royal National Park and Helensburg area for recreation and community, I am writing this submission because I am very concerned about Peabody's coal mine extension. There have already been major coal waste spills as a result of mismanagement by Peabody, and the effects of this damage to the Hacking River are still ongoing. Furthermore, this mine has already caused many swamps, creeks, and streams above its longwall to run dry due to surface cracking, damaging critical ecosystems and allowing metal contaminants to leak into Woronora Reservoir.

Future spills will occur if further longwalls are added, further damaging ecosystems and the recently reintroduced platypus in the area. Peabody does not have adequate risk management plans to address future coal spills.

The vegetation clearing proposed by Peabody will damage fragile ecosystems and impact several endangered species such as ground parrots and burrowing frogs.

This area is unsuitable for mining, especially for further extensions of a mine that has already caused significant environmental damage, as well as leaking into human drinking water supply in the Woronora Reservoir.

The Peabody Energy mine threatens the drinking water catchment in Woronora, and the ecosystems in the Royal National Park, which is my local backyard. I value this natural area and spend a lot of time hiking and swimming there with family and friends, connecting with nature.
Peabody has already been convicted of two pollution events in the royal national park in 2022 that resulted in black coal sludge contaminating the river system. They were fined $196,560, but was able to continue their business. This seems like a slap on the wrist with little consequence. How can we even contemplate allowing them to expand their operations when they show such negligence?
The modification proposal could damage the Woronora catchment, impacting the drinking water supplies for the Sutherland Shire and Northern Illawarra LGAs. The additional longwall mining is likely to further impact the swamps and wetlands at the surface, which are already drying up.
Surface cracking is also linked to contaminant leaching into surface water and groundwater. The extent of this impact could be significant as there is the potential for contaminants to travel through aquifers and fractured rock long distances
Peabody has proposed clearing 4 hectares of vegetation for the construction of the modification proposal in sensitive ecological areas surrounded by coastal upland swamps. Equally, if the modification goes ahead, it’s my understanding that Peabody would operate under their original licence agreement from 2009, which likely has lighter environmental controls.
Lastly, as NSW has a plan to transition to renewable energy, I’d like to know how NSW can support ongoing and additional coal mining. This is in direct contradiction to the state government’s renewable energy planning framework. https://www.planning.nsw.gov.au/policy-and-legislation/renewable-energy/renewable-energy-planning-framework
I am also interested in seeing the environmental impact statement associated with the modification proposal.

I object to Modification 4 – Longwalls 317 and 318, Metropolitan Colliery. Due to many reasons - the most frightening being it is in the water catchment area - why risk any chance of any accidental contamination. Why are we extending coal mines when effort must be placed into renewable energy- make it happen - no more delays. Our climate is already damaging and unreliable. This coal seam is particularly “gassy” with excessive damaging methane . Why chance polluting more ? Destruction of indigenous cultural sites continues and is unforgivable when we do not need to extend this long wall. Approved many years ago when the risk of climate change was less obvious and the biodiversity of the area less known - we know more now and this should now go back to a transparent process for public scrutiny before approval. A process that assesses this under 21st Century knowledge & expectations of the population for their future in the approval of projects.
Please do not approve
Please note this strong objection.
Thankyou

Refer attached submission and attachment

I strongly oppose Peabody Energy’s proposal to extend its mining operations deeper into the Special Areas drinking water catchment. This catchment is a critical public asset, supplying clean drinking water to millions of people. Allowing further mining in this area poses unacceptable risks to water quality, long-term security, and public health.

Independent reports and past experience already demonstrate that longwall mining has caused subsidence, cracking of riverbeds, and the release of pollutants into our waterways. Peabody has a record of environmental harm, and the cumulative impacts of its existing operations have not been adequately addressed. To permit expansion without fully remediating existing damage would contravene the precautionary principle and undermine public trust in our planning system.

Water catchments must be protected as a matter of public interest and intergenerational equity. Coal is a finite, polluting resource, whereas safe and secure drinking water is essential and irreplaceable. Once compromised, it cannot be restored. Regulatory bodies have a duty to prioritise the health and wellbeing of communities, ecosystems, and future generations over short-term corporate profit.

For these reasons, I urge decision-makers to reject this proposal in its entirety. The integrity of our water catchments must be safeguarded. Water is life.

The project is important for contributions to Australia's steel industry with Bluescope as well as Metropolitan's contribution to employment and growth in the Helensburgh region

I live in Bundeena in the Royal National Park.
I am a Fire fighter with FRNSW at station 080 Bundeena.

To hear this news through channels not officially advertised for local people is disheartening.

I have several concerns with this modification of two additional longwalls to the Metropolitan Colliery.

The Wornora Catchment is a public asset. The catchment’s primary function is our drinking water supply for this area. The Woronora Catchment area has already suffered numerous detrimental impacts as a result of Peabody’s longwall mining operations.

Longwall mining causes subsidence and cracking of the surface level stone. In a fragile water catchment such as Woronora, this is leading to damage to the fragile upland swamps, streams, creeks, and rivulets which make up the catchment.

The Coastal Upland Swamps, are listed as an Endangered Ecological Community under the Threatened Species Conservation Act. Subsidence damage to upland swamp ecosystems is considered to be irreversible, meaning that the damage that Peabody has already caused to the Woronora Catchment’s swamps, as well as the damage which will be caused by the proposed modification, will effectively kill these ecosystems forever.

These vital ecosystems are also home to numerous threatened species, such as the Giant Dragonfly, Giant Burrowing Frog, Littlejohn’s Tree Frog, and Red-crowned Toadlet. It would be terrible to see these species go locally extinct.

The community of Bundeena are very aware of the overflow of coal waste that has caused the Hacking River to run black on numerous occasions. This can damage can never be undone. How many more times will this be allowed to happen in our National Park?

I think it’s about time that we prioritise the safety of our drinking water and parks the profits of an American mining company.

Sincerely,
Jodie Riach

I object to the project because of the following reasons:
Irreparable damage to the water catchment. Feeble attempts by this company in the past to glue the water catchment back together with epoxy have failed. We cant keep allowing new damage in new areas.
Damage to aboriginal cultural sites and landscape.
This company has lost its social licence to operate after multiple serious pollution incidents in the RNP, its poor treatment of workers (unfair dismissal during covid, locking out workers over pay disputes) and avoidance of paying company tax in Australia.
Thank you for considering this objection and I hope this application is either rejected outright or sent to a hearing of the IPC.

I object to this proposal for a longwall mining extension/modification under sensitive environmental areas which are also an important drinking water supply catchment.
Longwall mining results in subsidence as well as cracking of the earth's surface allowing creeks, wetlands and water catchment areas to lose precious water (for the environment as well as people).
With climate change and associated increases in droughts and bushfires, we need to protect our water supply systems and protect environmental systems. This area is likely to support koala populations which lost much habitat in the 2019/20 bushfires.
The environmental risks associated with this proposal under the stewardship of this company which has a poor environmental record should be clearly understood, leading to refusal of the application.
I suggest the Minister consider referring this proposal to the Independent Planning Commission for a public meeting and to enable independent assessment of the environmental implications of this proposal.