Modification 4 Longwall 317 and 318 Modification

I support the extension of Metropolitan Mine to continue the employment of 100's of people in the local community.

I am very concerned about the potential of the project to increase subsidence under water catchments and possibly the Royal National Park (which was formed in 1879 and is the second oldest national park in the world), and other sensitive areas.
An official NSW Government 1998 publication called Action for Transport 2010 foreshadowed an 11 km rail tunnel from near Waterfall/Helensburgh to Coledale. It is important that this option remains viable.
I can still recall coal mining (not necessarily by the applicant_ that occurred in 1985 that led to the need to close the South Coast Railway line to undergo expensive repairs to the Stanwell Park Viaduct.
40 years on, in 2025, the applicant for this modification in Court admitted to a breach of licence conditions, and was ordered to pay $500,000 in costs and fines for Royal National Park pollution. (see below)

I object to any expansion of long wall mining due to the harmful and irreversible impacts on the terrain and wildlife and potential harms to human health.

Peabody has previously shown disregard for the environment by allowing coal waste to pollute port hacking.

Please consider my children, and all future generations and do not jeopardize our water catchments.

I strongly oppose this modification :

1. Threat to Sydney and Illawarra’s Water Catchment
This modification proposes continued coal mining within the Special Areas of the
Woronora Catchment — a critical drinking water source for over 5 million people,
including the Sutherland Shire, northern suburbs of Wollongong, and
communities such as Helensburgh, Engadine, and Lucas Heights.
The longwall panels are located alarmingly close to the Woronora Reservoir, which
is a crucial asset for regional water security. Longwall mining is known to cause
subsidence, fracturing of rock layers, and irreversible damage to watercourses,
reservoirs, and upland swamps(1).

The proposed modification places swamps including Swamp S106 at risk.
Swamps are vital to the health of the catchment: they absorb water during heavy
rainfall, store it, and gradually release it during dry periods. Their destruction
undermines long-term drought resilience and compromises clean water supply.

2. Biodiversity and Threatened Species at Risk
This modification threatens the habitat of several vulnerable and critically
endangered species, including:

Bynoe’s Wattle (Acacia bynoeana) – Vulnerable
Pilotbird (Pycnoptilus floccosus) – Vulnerable
Prickly Bush-pea (Pultenaea aristata) – Vulnerable
Swift Parrot (Lathamus discolor) – Critically Endangered
Thick-leaf Star-hair (Astrotricha crassifolia) – Vulnerable
White-throated Needletail (Hirundapus caudacutus) – Vulnerable
Woronora Beard-heath (Leucopogon exolasius) – Vulnerable
This area is part of a fragile and unique ecological zone. Any additional disturbance
or habitat degradation caused by mining-induced subsidence or pollution will
accelerate the decline of these species and further erode the region’s biodiversity.
We are in a biodiversity crisis and this damage is unacceptable.

3. Economic Claims and Corporate Conduct
The proponent, Peabody Energy, is a U.S.-based multinational that pays no
corporate tax in Australia, despite earning substantial profits from its Australian
operations (2).
Peabody also has a record of poor treatment of workers:

In 2020, it unlawfully dismissed workers at the Metropolitan Mine — a case the High Court ruled was unfair dismissal (3).
More recently, it locked out its workforce following a one-hour protected industrial action (4).
We recognise the value of employment in the region. However, it is unjustifiable to
compromise a vital water catchment for limited short-term employment, especially
when workers could be supported to transition into sustainable industries.

4. Climate Impact of Ongoing Coal Extraction
While the Metropolitan Mine extracts metallurgical coal used in steel production, its
climate impact remains significant.

In FY2024, Metropolitan’s Scope 1 emissions (direct from mining operations) reached nearly 700,000 tonnes of CO₂-equivalent — its highest on record since the Safeguard Mechanism began in 2016.
Over 80% of these emissions were methane, a potent greenhouse gas with 86 times the warming potential of CO₂ over 20 years.
Metropolitan is now the fifth highest Scope 1 emitter among all coal mines in NSW.
NSW is not on track to meet its net zero targets. Continuing to approve
expansions of high-emission mines, regardless of coal type, undermines our climate
commitments.

5. Planning Integrity and Approval Process
The current mine footprint was originally approved in 2009 by then Labor NSW
Planning Minister, Kristina Keneally. At that time, the implications of climate
change, water security, population growth, and biodiversity collapse were far less
understood or prioritised.
The ongoing use of a modification pathway to prolong mining operations under an
outdated approval process is unacceptable. A proposal of this type — with serious
environmental and public interest concerns — must undergo a full Environmental
Impact Statement and fresh assessment under current laws and science.
Consistent with Labor government promises both before and after the most recent
election, Metropolitan Modification 4 must also be referred to the Independent
Planning Commission of NSW for an independent and transparent assessment.

Please note. This submission attached is slightly corrected and should replace previous submission on behalf of the Sydney Knitting Nannas.

I strongly support this project because steel making coal is essential to energy transition.
This project not only supports direct local jobs and jobs at the local steelworks while upholding strong environmental standards.
Mine has been operating for over 130 years and supported generations of workers and there is no reason why this should not continue.

I am a health worker in the Illawarra and my father was a coal truck driver. I understand that coal mining was important for employment in the area in our past however, coal does not belong in our future. I strongly object to Modification 4 Longwall 317 and 318 Modification of the Metropolitan Mine. I urge the Minister to reject this proposal to protect our water, environment, and climate.

This mine produces significant methane and contradicts the NSW Government’s Net Zero targets. NSW is not on track to meet its net zero targets. Continuing to approve expansions of high-emission mines undermines our climate commitments.We are facing increasing climate extremes, it is unacceptable to expand a high emission coal mine. We need to support the Illawarra and all coal communities to move away from damaging fossil fuels not lock us into more years of damaging mining. Expanding this mine only benefits Peabody Energy, is a U.S.-based multinational company that pays no corporate tax in Australia.

This modification proposes continued coal mining within the Special Areas of the Woronora Catchment which is a critical drinking water source for over 5 million people. As a health worker I am I am concerned that the proposed mine expansion risks the long-term security of our drinking water supply.

We need to prioritise our health not foreign profits.

I support the Metropolitan Mine modification because it will protect local jobs, sustain $200+ million in spending with local suppliers, and continue to inject hundreds of millions into the NSW economy without expanding the mine’s footprint. The plan extends operations by two years, ensures stable production, and strengthens our steelmaking supply chain. Importantly, it reduces environmental impacts by relinquishing coal reserves, shrinking the mine’s footprint, and investing in water protection and conservation programs. Supporting this expansion means securing economic stability for the Illawarra region while upholding strong environmental commitments.

To whom it may concern,

I strongly oppose Peabody Energy’s proposed Modification 4 to mine deeper beneath Sydney’s drinking water catchment.

Peabody has already caused serious environmental damage through past mining activity in this sensitive area polluting waterways, cracking vital creek beds, and putting long-term water security at risk. Allowing them to extend or deepen their operations is irresponsible and dangerous.

Water is life. Our drinking water catchments must be protected, not exploited for short-term profit. Once our water sources are damaged, there’s no going back. The risks are too high, and the community has made it clear time and again that this is not acceptable.

I urge the Department of Planning and Environment to reject this modification and prioritise the health of our ecosystems, communities, and future generations.

I wish to express my strong support for the proposed expansion of the Metropolitan Mine.
The expansion will secure the ongoing operation of the mine, which is a critical contributor to the local and regional economy. Most importantly, it will help safeguard a substantial local workforce, providing stable employment opportunities and supporting the livelihoods of many families in the community.
The continuation of the mine will not only maintain direct jobs but will also sustain the broader network of suppliers, contractors, and service providers who rely on the mine’s operation. This flow-on effect is vital for the resilience and growth of local businesses and the regional economy more broadly.
For these reasons, I fully support the Metropolitan Mine expansion and encourage its approval.

Metropolitan Coal Mine has been a provider of employment and community support for over 100 years. Currently there are approximately 400 workers at the mine who directly or indirectly support the local community and the greater Wollongong area and spend in excess of $73 million dollars annually, without the mine this level of support will disappear along with the benefits to the community. The mine also supports local businesses both through contracted work and the purchase of supplies for over $200 million dollars annually. The greater NSW economy also benefits from the operation of the mine. It is estimated that over $300 million dollars annually is pumped into the NSW economy. Steel making coal is also critical for the production of steel which supports the implementation of renewable energy projects. The approval of the modification application will ensure continued employment for workers and contractors and also the cash injection into the economy and the provision of steel making coal.

Objection to Metropolitan Coal Mine Expansion: Submission from the Sydney Knitting Nannas
Introduction
We, the Sydney Knitting Nannas, are a community of elder volunteers dedicated to protecting our land, water, and air for future generations. Our commitment stems from the urgent need to safeguard the environment not only for ourselves, but for all those who come after us.
Objection to the Mine Expansion
We strongly oppose the approval of the Metropolitan Coal Mine expansion, specifically Longwalls 317 and 318 under Modification Application No. MP08_0149-Mod-4. Granting this approval would threaten the health and wellbeing of communities across the Illawarra and Greater Sydney regions. This decision also carries broader global implications, including climate change impacts and the Australian government’s and NSW Government’s legal obligations and moral responsibility to meet IPCC commitments.
Environmental and Social Concerns
• Back in 2009, in-principle approval was given for ten longwall mines directly beneath the Woronora Reservoir. Over the past fifteen years, our scientific understanding of climate change and the environmental harm caused by mining has greatly increased.
• Advancements in climate science and IPCC reports over these years have informed governments and citizens alike about the urgent need to halt new fossil fuel projects and embrace our duties as global citizens.
• Crucial upland swamps, which naturally filter our drinking water, are being irreparably damaged. Mining subsidence causes fractures that allow leachates to enter the catchment, threatening water quality for local residents and the Greater Sydney area.
• The Hacking River catchment in Royal National Park has experienced multiple pollution events. Peabody, the mining company responsible, was fined $500,000, yet there is little evidence that they have taken meaningful action to stop these pollution incidents.
• Approval of the mine’s expansion would result in an additional 3.2 million tonnes of coal being extracted and the release of significant amounts of methane, a potent greenhouse gas.
• Peabody, a company owned overseas, has not paid company tax in recent years. We do not regard Peabody as a good corporate citizen.
Supporting Evidence
Risks to Metropolitan Special Area Ecosystems
Sydney's Metropolitan Special Areas are protected to ensure high-quality drinking water, to 5.3 million people. [2] However, longwall mining has caused subsidence that harms the upland swamps essential for water quality and supply. Research by Peter Dupen, a former WaterNSW Mining Manager and hydrologist, supports this concern. [3]
Dupen concluded that:
• The aquifers above and feeding the streams are draining faster than before mining, sometimes rapidly and completely, because of unexpected, large-scale shear planes forming at their base.
• If these subsidence mechanisms are widespread, many protected ecosystems could dry out and change permanently. Another major risk is increased contamination of the Woronora Reservoir by metal-laden discharges from unmeasured shear plane vents.
An independent review commissioned by the NSW government acknowledged Dupen's findings, stating that while alternative explanations exist for the anomalies he observed, neither his hypothesis nor the alternatives can be fully validated with current evidence. There is further research raising serious concerns of irreparable damage to ecosystems which form a part of purifying water flowing into our drinking water catchments.
An example of further research is by Dr. Mason of UNSW states [4]:
“There is no effective form of restoration once a swamp has been undermined,” Dr. Mason explains.
• The roots of swamp vegetation require waterlogged conditions. If mining disrupts the shallow sandstone aquifers, the water in the root zone will drain, leading the swamps to dry out.
• Upland swamps are essential for Sydney’s drinking water catchment, storing and gradually releasing water, filtering nutrients, and reducing erosion from storms.
• These swamps support high biodiversity, including threatened species like the Giant Dragonfly and Prickly Bush-pea, which depend on stable swamp conditions.
• Dr. Mason asserts that the most effective way to protect endangered upland swamps from mining-related drying is to avoid longwall mining beneath them.
Further Scientific Reports
Concern has been further raised by WaterNSW in a submission to the Independent Expert Panel looking into mining in the catchment. WaterNSW wrote [5]
“An issue which particularly concerns WaterNSW is that it is anticipated that any additional increases in iron, manganese and possibly aluminum and other species dissolved from undermined catchments will impact on raw water quality delivered to Sydney Water and other customers…metals transported to reservoirs in particulate and/or dissolved forms are more likely to be precipitated and build up in the lake sediments over time.” (seep.24)

In addition, further concerns were expressed by over 20 independent scientists who have questioned the ‘science’ that has been applied to justify the mining. They have called for this mining to be suspended “until the cumulative impacts and consequences of mining to date can be reliably assessed and quantified.” They have noted the government’s “dependence on assessment reports prepared by consultants selected and funded by mining companies”, and have stated that “such reports cannot be regarded as independent”. None of this was mentioned in the 2020 parliamentary debate. [6]
Given the role of upland swamps in maintaining water systems and supporting endangered species, our organisation believes that their destruction alone justifies rejecting this proposal.
History of Pollution Events
The Metropolitan Mine has discharged polluted waste into the Hacking River catchment, which flows through Royal National Park. Black sludge was observed in the Hacking River several times in 2022 and again in January 2023.
In August 2023, a mine embankment next to the creek collapsed, causing coal waste to spill again into the creek and the Hacking River. No effective emergency response was taken to stop the pollution. Peabody was ordered to pay $500,000 after being found guilty of allowing coal sludge to flow into Camp Gully Creek and the Hacking River.
The modification report references remediation efforts for a section of embankment at the Surface Facilities area, following slumping after heavy rainfall in 2022 and 2023.
Our organisation asks: Why will remediation of slumping and pollution that occurred in 2022 and 2023 not be addressed until the 2030s as part of this Modification? We are also mindful that climate change is making extreme rainfall more frequent, meaning further major events could happen at any time.
Please view this alarming video of black sludge in the river system:
https://www.ssec.org.au/help-protect-the-royal-national-park-submission-guide-for-the-epa-review-of-peabodys-metropolitan-colliery/
Again, pollution history should alone be grounds for rejection of this proposal.
Our organisation is stating in the strongest possible terms that this proposal must be not be allowed and it is incumbent on NSW Government authorities to act in the best interests of its citizens and have regard for the extensive independent scientific reports and reject this proposal.

[1] https://knittingnannas.org/sydney/
[2] sydneywater.com.au/water-the-environment/how-we-manage-sydneys-water/water-network.html
[3] Metropolitan Coal Mine – independent review of environmental performance to 2022
[4] https://www.unsw.edu.au/news/2021/03/restricting-longwall-mining-in-sydneys-drinking-water-catchment-
[5] https://www.chiefscientist.nsw.gov.au/__data/assets/pdf_file/0017/160118/2-WaterNSW-submission.PDF
[6] https://www.ssec.org.au/our-campaigns/stop-woronora-mining-petition/

Protect Our Water Alliance objects to the project. Please see attached.

I object to the project. Please see submission attached.

Submission:
Peabody’s application for modification longwall 317 and 318

I oppose Peabody Energy’s application for a modification to its mining licence. This manoeuvre would avoid the requirement of oversight by the Independent Planning Panel.

Any application for changes to longwalls 317 and 318 should be brought before the Independent Planning Panel.

The modification has the potential to contaminate clean drinking water supplies for Sydney and also to threaten the local survival of five threatened species – Giant Dragonfly, two species of frog, Eastern Ground Parrot and Koala - and the food supply of macroinvertebrates on which the Platypus relies.

Access to clean, uncontaminated water is a basic right of humans (but sadly is not available in many countries). There is absolutely no reason why an affluent country like Australia should have to accept less than a supply of clean uncontaminated water for the benefit of an overseas-owned company mining our coal.

I do not trust Peabody Energy to comply with licence conditions.

Hacking River. Peabody Energy’s mining activities have already polluted waterways. It failed to comply with licence conditions on two separate occasions in 2022, resulting in contaminated water containing coal waste, flowing into the Hacking River. These were serious enough to result in being ordered to pay more than half a million dollars in penalties and legal fees. Despite the penalties, further pollution events occurred in 2023.

The effects of the coal waste contamination are still present in the Hacking River which flows through the Royal National Park and there is no guarantee that it won’t re-occur. In August 2023 an embankment at the mine site collapsed, releasing more coal waste into the river system but Peabody Energy still does not have adequate risk management plans in place to prevent further contamination.

In April 2024 I joined a bushwalk from Gray’s Point to Audley, along the Hacking River, and saw evidence at first hand, of contamination from coal waste in the river.

The NSW Government has lauded the release of platypus into the Hacking River Catchment but the survival of these is threatened by the continuing presence of coal fines which can kill the macroinvertebrates that are essential in the diet of the platypus.

Coastal Upland Swamps. Longwall mining beneath a catchment area is unacceptable. It has already resulted in subsidence leading to surface rocks cracking and hence loss of water from coastal upland swamps, streams and creeks within the catchment area of Woronora Reservoir. It can also lead to metal contamination leaching into groundwater flowing into the Reservoir.

I have participated in macroinvertebrate surveys in the River Health Program in upland swamps on the Woronora Plateau and attended talks by sandstone geomorphologist, Dr Anne Young on the threats to the viability of Coastal Upland Swamps.

Coastal upland swamps are classified as an Endangered Ecological Community. Coastal Upland Swamps are vital for the natural filtering of water before it flows into the Woronora Reservoir. Once damaged, they cannot be remediated.

I have made previous submissions (2013, 2014, 2020, 2023) opposing mining activities affecting catchment areas south of Sydney and the Hacking River. I am frustrated and angry that we have to continue to fight to protect clean water and threatened species and ecological communities in the Greater Sydney region.

With our increasing population, a guaranteed supply of clean water and protection of national parks for recuperative leisure become even more important.

Elizabeth Cameron, Hurstville Grove NSW

I object to this Modification

Please refer to the attached letter of support for further detail.

I object to the mining under our water supply. I believe the area should be preserved and protected from mining as it’s such an important and valued source for water supply in the Illawarra and Sydney.
Peabody mine has a terrible track record for polluting our waterways and damaging land. The Hacking River and Waratah Rivulet are just two examples. They get a tap on the wrist and a tiny fine when they damage land or pollute waterways or kill threatened species such as platypus and are able to continue.
I think the land in, around and under Woronora dam should be kept and preserved for the use of storing our water for our future and for the future of all the animals and plants that co exist around this area. The impact would be disastrous if this were to proceed and water escaped through cracks caused by movement and coal washed into waterways again at the risk of health to animals as it has done in the Hacking.
Please stop this preposterous proposal!

The Mining and Energy Union South Western District (MEU) is proud to represent coal mineworkers in the NSW southern coalfields including at Helensburgh’s Metropolitan Mine. The Metropolitan Mine has a long history as Australia’s oldest continually operating coal mine; and today deploys cutting-edge mining technology to produce world-class steel-making coal for local and global markets.
The MEU supports the longwall modification proposed by Peabody (MP08_0149-Mod-4) as a sensible response to discovered geological challenges which would otherwise prevent the continued operation of the mine through to its existing approved mine life.
The proposed extension of Longwall 317 and addition of Longwall 318 would allow for continued mine operation until 2031 as opposed to premature cessation of operation in 2029. It would allow for the recovery of high-quality coal that would otherwise be sterilised, supporting local steelmaking at Port Kembla, generating economic activity including royalties for NSW and maintaining good local jobs for an additional two years.
This modification would see mining continue within the existing approved footprint, while prioritising safe operation of the mine and minimising environmental impacts.
Coal mining has co-existed with our unique environment and been an important provider of secure, well-paid jobs in the Illawarra region for generations. With the industry now under pressure on a number of fronts, the opportunity to provide an additional two years of certainty to 400 local families and the many downstream businesses reliant on the activity generated by the Metropolitan Mine should not be dismissed.
Early closure of the mine in 2029 as foreshadowed if the modification does not proceed would hurt local families and businesses and negatively impact the Illawarra’s industrial ecosystem including Port Kembla Steelworks and Port Kembla Coal Terminal.
The modification should be treated consistently with the existing Project Approval (08_0149) conditions under which the mine operates.

I am writing to say that I oppose the proposed modifications to the licence for Peabody’s Metropolitan Mine in Helensburgh (Mod 4: 317-318).

Longwall mining in the Woronora catchment has already caused environmental damage in the area, with upland swamps running dry due to cracking and subsidence. Metal contaminants can leak into surface and groundwater, too. These problems not only affect the land itself. Woronora Reservoir supplies drinking water to the surrounding areas (including Helensburgh, where I live); any risk of contaminated water entering our drinking supply should not be tolerated.

Part of the proposal involves clearing four hectares of bushland for a ventilation shaft. It seems crazy that this should even be considered, especially since local bushwalkers, like myself, would receive a $44,000 for entering the area. If a site is so important that even walking poses a threat commensurate with a $44,000 fine, then clearing vegetation for a ventilation shaft should be out of the question.

Unfortunately, Peabody and the Metropolitan Mine have not demonstrated a strong track record when it comes to environmental protection; the recent flows of materials into Camp Gully Creek and subsequently into the Royal National Park’s Hacking River were appalling, and show that the company cannot be simply given the benefit of the doubt when it comes to environmental management.

In short, this proposed modification to the Metropolitan Mine’s licence should not be allowed.