Modification 4 Longwall 317 and 318 Modification

The Peabody Energy mine is threatening not only the drinking water catchment in Woronora, but it threatens the ecosystems in the Royal National Park, the oldest park in Australia and where I live and am raising a family.
In March 2025, I learned that Peabody was convicted of two pollution events that occurred in the royal national park in 2022 that resulted in black coal sludge contaminating the river system. They were fined $196,560, but able to continue their business. This seems like a slap on the wrist with very 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 further, 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.

The Peabody Energy mine is threatening not only the drinking water catchment in Woronora, but it threatens 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.
In March 2025, I learned that Peabody was convicted of two pollution events that occurred in the royal national park in 2022 that resulted in black coal sludge contaminating the river system. They were fined $196,560, but 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. My experience in the UK is that no development would be approved on a sensitive ecological area and that a buffer zone would be required. So, I’m truly puzzled that this would even be considered in NSW. 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 governments renewable energy framework.

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.

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

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 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.

Refer attached submission and attachment

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

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.

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.

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.

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

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.

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 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.

I object to this Modification