Modification 4 Longwall 317 and 318 Modification

If we are to preserve the natural wonders of Australia, it will be important that many of us continue to live in dense urban areas such as Sydney. I well remember [from the previous century] the Cryptosporidiosis scare that drove western Sydney residents to only trust bottled water.... clearly a disastrous waste and pollution issue just on its own.

Now we know more about what challenges await us and the coming generations.
Surely by now we understand that an extractive operation, based on single-bottom line accounting and short-term re-turns, is not worth the risking the essential aqueous supply to all terrestrial life in the Sydney basin and the Illawarra.

Water quality is mighty important to NSW residents anywhere near the Metropolitan Coal Mine, but maintaining the crucial mix of gasses in our atmosphere is vital to all life in New South Wales and far beyond. The methane that will be released by the proposed mine modification, whilst shorter lived than CO2 pollution, is an acute accelerant of global warming effects and by orders of magnitude.

The sooner we cease seeking underground for the seeds of our destruction, the sooner we can help to ease the burden of repair faced by future generations.

For the reasons above, I strongly object to Modification 4 Longwall 317 and 318
Modification of the Metropolitan Mine. I urge the Minister to reject this proposal in
order to protect our water, environment, and climate.

I strongly object to the Peabody Long Wall Mine Extension under
the Water Catchment as this increases risk to our water resources.

Previous mining by Peabody has already caused irreparable damage to the swamps ecosystems.
Future mining activity will ever increase these risks and the environmental damage is irreversible.

Where in the Western World is mining of coal permitted under the Catchment of potable water?
Peabody must avoid any risk which will affect potable water supplies.

This mining land is adjacent to two National Parks, a State Conservation Area and a Water Conservation Area.
All are of high environmental value and within close proximity to the
Royal National Park which is the second oldest in the World.

Found guilty of two separate pollution events in 2022, Peabody has been ordered to pay more than half a million dollars in penalties and legal fees.
It pleaded guilty in 2024 to two incidents in September and October 2022 that allowed contaminated water to flow into Camp Gully Creek and the Hacking River.
This pollution is described as thick black custard.

In conclusion, I direct that NSW Planning Minister hold an
IPC (Independent Planning Commission) for this Modification as this would provide greater transparency and accountability around the decision outcome - whether approval or rejection.

Thank you for the opportunity to comment on Peabody's Metropolitan mine MP08_0149-Mod-4. I strongly object to this proposal. I have outlined my reasons in my attached submission

I am writing to oppose this project. This project represents an ongoing unacceptable risk to the Royal National Park. With climate change becoming a more pressing issue for everyone around the world, we need to be doing all that we can to protect our natural environments, including our national parks. The mining causes irreversible damage to upland swamps and this project doesn't have a risk management plan to deal with future coal spills. It is unconscionable that NSW would allow this project to move forward. Purchasing offsets to mitigate against irreversible damage is insufficient - what about the flora and fauna in the national park that gets damaged - no amount of offsets will restore the forest to it's earlier homeostasis. I strongly urge the NSW government to oppose this project. We need to protect our natural resources so that we have a healthy planet for future generations.

I'm opposed to extending the longwall mining underneath the Woronora dam catchment. This is meant to be a pristine area that supplies drinking water - supposedly among the best quality in the world, according to Sydney Waters own data. Mining underneath has already been shown to cause subsidence and cracking in surface creeks and upland swamp areas within the catchment, affecting water flows into the dam. While we've had above average rainfall recently, the long term trend may see less water replenishment of the dam, and exacerbating that by physically damaging the areas that do the vital job of topping up our drinking water supply seems to me like a very bad idea. To restrict access to catchment areas, while allowing free rein to dig directly underneath it is hypocritical to say the least.

The Oatley Flora and Fauna Conservation Society strongly objects to this proposal. Due to the detrimental impacts on the environment, especially the treasured Hacking River and Royal National Park, coupled with Peabody’s very poor track record of pollution incidents, OFF is firmly of the view that the risks are far too great, should not be accepted and the proposal should be rejected.

Please see attached Sutherland Shire Council's submission.

As resident who relies on the catchment for water I strongly object to the addition of two more longwalls to the existing colliery. As a modification this means the environmental protections are weaker. This mine is in an coastal upland swap which is listed as an Endangered Ecological Community under the Threaten Species Conservation Act and is home to a number of threatened species. This expansion proposes clearing of 4 hectares in an area closed to the public, even for bushwalking, due to its sensitivity and proximity to a major water source. There is no adequate risk management plans to deal with spills in the Royal National Park or in the water catchment zone. The Woronora Reservoir supplies clean drinking water to the Sutherland Shire and Northern Illawarra. This drinking water is under threat from long wall mining - this will cause subsidence and cracking of the surface, resulting in water loss and contamination. I find this modification being added to the original licence and avoiding the independent planning panel deplorable and corrupt.

To whom it may concern.

Please find attached Aurizon Operation's submission supporting Metropolitan Mine's modification and extension of mining operations.

I fully support this modification on the basis that Metropolitan Colliery has & continues to supply quality coking coal to the Port Kembla Steel Works to make steel for Australia & its people. Combined the 2-businesses support many thousands of men women & children in the Illawarra area & beyond, they support Australia as a whole by supplying quality made steel right here in Australia which is essential for Australia's long running security & to keep manufacturing alive in Australia.

The mine has been in operation since 1888 & for the 137 years of continuous mining the amount of employment over those years has been staggering, the support to the local community has been outstanding, the benefits to the state of NSW as well Australia has been phenomenal, the security of the production of steel within Australia is huge & this is all achieved through very high standards that are set by Australian authorities ...

Given the very significant number of years this Colliery has been in operation & the benefits as a whole as outlined above, the minimal negative effects that this mine has had during that period have always been fully transparent as well addressed 100% to prevent them from happening again to the absolute best of ability ...

The benefits far out way any of the negatives given the majority of the negative claims are very stretched from the truth to say the least.

I have been a Sutherland Shire local my entire life. I have fond memories of time spent at Audley Weir and bushwalking in the Royal National Park. If Peabody's Modification Application is approved, not only will those special places be put at risk of pollution from coal (again!), our precious drinking water in the Woronora Reservoir will be affected.

Peabody have a dreadful reputation for environmental destruction. Purchasing offsets will not save irreversible damage to critical swamps that filtrate water, or bring back endangered species found in the area. The coal mined from this mine will contribute to climate change at a time when we should be closing coal mines, not expanding them!

I do not trust Peabody with the future of the Woronora Reservoir. They have already created major coal waste spills, resulting in thick black sludge covering the waterways of the Royal National Park. As a billion dollar company who pays no tax in Australia, the small fine they paid as a result of this pollution is a slap in the face, and will not help undo the damage they've caused.

Please DO NOT allow their Modification request to be granted.

Tomorrow Movement Wollongong Objection to Metropolitan Mine Modification 4

Introduction

The Tomorrow Movement is a movement of young people fighting for a society with good jobs, great public services and a safe climate for all. In the face of economic and climate crises, we are looking for the government to provide national leadership.
Young people are at the forefront of crises facing our labour markets, our housing system and our climate. We know that to address these challenges, the federal government must take bold and transformational action. That is why young people all over the country are calling for urgent economic reform to create a policy environment which promotes a fast, just transition that creates new jobs in a sustainable, productive, equitable economy.

Executive Summary

Tomorrow Movement objects to the Metropolitan Mine Modification 4 (“the modification application”) proposed by Metropolitan Coal (“the Applicant”), a wholly owned subsidiary of Peabody Energy Australia Pty Ltd (“Peabody”). As young people, we are deeply concerned that current climate and the ever growing expansion of coal mines throughout Australia, including this one. We are the first generation that will live through the consequences of today's decisions on emissions, energy, and land use. From increasingly extreme weather to rising economic risks and social instability, the impacts of a changing climate are already being felt and they will only intensify in the decades to come. We object to this modification application due to its impacts on our:
- Climate
- Water Catchment
- Aboriginal and Cultural Heritage
- Economy

We also raise serious concerns about the credibility of the Applicant to continue an already devasting project.
The NSW Planning Minister, Paul Scully, must refer determination of this Modification project to the Independent Planning Commission (“IPC”) for a public hearing and determination. Not only is this in line with NSW Government Policy and would provide for a more transparent and accountable assessment of the modification application. This is within the power of the Minister.

Climate Change Impacts

The modification application must be refused due to the associated emissions produced on a Scope 1, 2 and 3 basis. The Applicant has measured the emissions as follows between 2028 and 2030 (excluding decommissioning):
Scope 1 emissions: 1.8 Mt CO2-e
Scope 2 emissions: 0.003 Mt CO2-e
Scope 3 emissions: 8.9 Mt CO2-e
Total emissions from the modification: 10.703 Mt CO2-e
Measured with the development consent itself:
Scope 1 emissions: 3.6 Mt CO2-e
Scope 2 emissions: 0.049 Mt CO2-e
Scope 3 emissions: 21.5 Mt CO2-e
Total emissions from the Applicant: 25.149 Mt CO2-e

The modification application represents a 42.5% increase in emissions. Noting that fossil fuel emissions, particularly methane, are notoriously under reported in coal mines, and the modification application is clearly preparation for a further modification into land in which the Applicant has not received consent for (see purple highlight in figure ES-2) this modification application does not represent the cumulative emissions of the Applicant’s mining operations.
However, in considering the impact of these emissions on climate change broadly, its impact to Australia’s commitments on an international and national level, and whether the locality itself will be impacted by the emissions caused, the Applicant only considers Scope 1 and 2 emissions. Consideration of all climate emissions is a mandatory consideration, including scope 3 emissions, as most recently determined in Denman Aberdeen Muswellbrook Scone Healthy Environment Group Inc v MACH Energy Australia Pty Ltd [2025] NSWCA 163.

The Applicant relies on fallacies within their Biodiversity Development Assessment Report (“BDAR”) relying on the exclusion of scope 3 emissions and an argument that due to market forces, coal would be mined anyway. Excluding the fact that fossil fuel development is being phased out of countries globally (source) and is one of the most expensive forms of energy, this argument was refuted in Gloucester Resources Ltd v Minister for Planning (2019) 234 LGERA 257; [2019] NSWLEC 7. Additionally, from the international perspective, the International Court of Justice’s advisory opinion identifies that fossil-fuel production, the granting of exploration licences or the provision of subsidies “may constitute an internationally wrongful act” attributable to the state who approved such projects.

Historically, in just 2024, Metropolitan’s Scope 1 emissions (direct from mining operations) reached nearly 700,000 tonnes of CO₂-equivalent, the mines highest recorded figure 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 making the Applicant’s mining project the fifth highest Scope 1 emitter among all coal mines in NSW.

NSW and Australia are not on track to meet 2030 targets. The Illawarra has already experienced climate impacts which will only worsen in the coming years. This modification application cannot be approved due to the high levels of emissions, in particular methane, the impacts to the Illawarra, the inability for NSW and Australia to meet climate targets.

Aboriginal Cultural Heritage Impacts

The modification application has the potential to impact Aboriginal cultural heritage sites, both known and unknown. The Applicant’s Aboriginal Cultural Heritage Assessment (“ACHA”) comprised a survey area of 455 hectares. However, as admitted within the report “approximately 9% (40.2 ha) of the Subject Area has been subject to surveys which have informed this ACHA.” Of this 9%, 29 cultural heritage sites were identified, 26 of which were known prior to their survey, 3 of which were discovered through this survey. On this basis, the Applicant has not conducted a thorough assessment to identify cultural heritage sites.
Additionally, from the consulted Aboriginal parties identified within ACHA, the submissions prepared by these organisations are not included within the publicly accessibly ACHA, save the Illawarra Local Aboriginal Land Council’s (“Illawarra LALC”) submission which objects to the modification application. As noted by the Illawarra LALC and within this submission, the coal mining process will impact the known cultural heritage items, and those unknown. On this basis, the impacts to cultural heritage sites should warrant refusal of the modification application.

Economic Impacts

The Applicant, as a U.S.-based multinational corporation paying virtually no corporate tax despite substantial profits from its Australian operations, has a track 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.
Most recently, it locked out its workforce following a one-hour protected industrial action.
The modification application report cites 400 jobs at the mine, yet the ACTU reported just 160 workers being locked out. These inconsistencies raise doubts about the economic justification presented.

Additionally, continual investment in coal mining operations over other economic opportunities including sustainable industries is in error. The longer Australia depends on fossil fuel production, and extending the life span of various coal mines such as this, we risk being locked out of renewable energy development amongst other global powers.
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.

Applicant Credibility

The modification application cannot be approved as the Applicant has a proven track record of failing to adhere to, at minimum, conditions of consent to past approved applications, as well as egregious examples of environmental devastation through spills. On numerous occasions, the Applicant has released toxic waste throughout the Roya National Park and been found guilty and fined. Despite these interventions from the NSW Environment Protection Authority (“NSW EPA”), despite alterations to their conditions of consent in response to these incidents, and the Court convictions, the Applicant has continually proven to have little regard for the environment.

I am horrified by this project & absolutely cannot believe the negligence & selfishness of even considering the operation of a coal mine in the Royal National Park. This decision is being made on stolen Dharawal Land & no one, no company, no government has any right to destroy it.

It absolutely cannot go ahead. It will cause significant damage to both ecosystems as well as people since we all depend on its health & biodiversity to survive. It's going to damage the Woronora catchment, pollute the Hacking River catchment, & threaten fragile ecological communities, such as the coastal upland swaps which are at risk of EXTINCTION. It is to degrade the natural environment which in itself has inherent value, but this is also at the detriment of people as we rely on the complexity & ecosystem services provided by a diverse & healthy environment. There has already been spillage which has occurred & more is bound to happen. This is just a small overview of the IRREVERSIBLE horrors it will be responsible for.

The Government is supposed to protect the Royal National Park & the life within, but if this goes ahead it is a betrayal to all life as everything relies on the health of these landscapes. The Peabody cooperation does not give a shit about how much damage they will cause, they lack concern for protecting the environment when all they care about is extracting finite resources from STOLEN LAND for the purposes of greed & wealth. Even if they are meant to be held responsible they will just purchase some void offsets in order to get away with the atrocities they are committing against this land.

There is not a single positive thing that could come out of this project & that's any coal projects for the matter. We are meant to be undergoing a just transition away from coal & yet this government keeps on allowing more extraction & environmental degradation to continue at the expense of a dying industry that even they must know is limited in its days.

If this project goes ahead, which it absolutely cannot, it exists as another clear example which reinforces the legacy of genocide & ecocide which has been ongoing in this country since colonisation.

To Whom It May Concern,

I am writing to formally object to the proposed extension of the Peabody Energy Mine under the Woronora Dam, a critical source of drinking water for our community. This proposal presents unacceptable risks to our environment, water security, and the long-term health of the ecosystem and residents who depend on this vital catchment.

1. Threat to Drinking Water Supply and Catchment Integrity
The Woronora Dam forms an essential part of the region’s drinking water infrastructure, supplying clean water to the Sutherland Shire (and other regions). Extending mining operations beneath or near the dam and its catchment area poses a severe threat to the structural integrity of the catchment and the quality of the water it provides.

Subsidence from longwall mining, even when controlled, can fracture rock layers and alter natural water flows. This can lead to:
- Irreversible loss of water from the dam through underground cracks and seepage, permanently reducing its capacity.
- Contamination of groundwater and surface water through the release of heavy metals and mining by-products.
- Increased turbidity and sedimentation in the water supply, leading to higher treatment costs and potential health risks.
- The precautionary principle must apply when the risks involve drinking water relied upon by thousands, if not millions, of people.

2. Impact on Threatened Species and Sensitive Ecosystems
The dam catchment area supports a range of flora and fauna, including species listed as threatened under both state and federal legislation.
Endangered ecological communities dependent on stable hydrology and undisturbed habitats.
Mining activities, including clearing, blasting, and changes to groundwater tables, are likely to:
- Destroy habitat critical to the survival of these species.
- Disrupt breeding cycles, feeding grounds, and migration paths.
- Introduce invasive species and increase edge effects from fragmentation.

Allowing mining under the dam would contradict Australia's obligations under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) and state biodiversity conservation laws.

3. Risk of Pollution and Irreversible Environmental Harm
Mining operations frequently involve the use of toxic chemicals and create waste products, including tailings and slurry, which can leach into water systems. The potential for:
- Heavy metal contamination (e.g., arsenic, lead, selenium);
- Acid mine drainage;
- Leakage of pollutants into the catchment during high rainfall or equipment failure;

This presents an unacceptable pollution risk to the region’s water supply and natural environment.
Past cases across Australia have shown that once this type of damage occurs, it is either extremely costly and impossible to remediate. In light of the increasing unpredictability of climate change and more frequent extreme weather events, the potential for environmental disasters increases substantially.

The proposed extension of the Peabody Mine under the Woronora Dam is not just a poor environmental decision—it is a deeply irresponsible one. It places short-term economic interests ahead of long-term water security, ecological stability, and public health.

I urge the relevant authorities to reject this application outright. Our water supply and ecosystems are not expendable, and once damaged, they may never recover.

Yours sincerely,
Sara Farynski.

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 long distances through aquifers and fractured rock.
Peabody has proposed clearing 4 hectares of vegetation for the construction of the modification proposal in a sensitive ecological area surrounded by coastal upland swamps. My experience in Canada 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 we 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 to see the environmental impact statement associated with the modification proposal.

⸻

I strongly oppose Peabody’s Modification 4 to extend longwall mining under Woronora Dam. This threatens Sydney’s drinking water supply and has already caused serious environmental damage. Peabody was fined after coal sludge entered Camp Gully Creek and the Royal National Park. Woronora Dam is part of Sydney’s critical infrastructure, a Special Area, and is heritage-listed. Mining beneath it by a foreign-owned company poses unacceptable risks to water quality, public health, and environmental safety. Water is life. Enough is enough. Please reject Modification 4.

I am concerned about the expansion of this mine for a number of reasons. Particularly risks to drinking water supply and irreplaceable ecological systems. In this climate change era this expansion makes no sense. I hope you will consider the cummulative and irreversible impacts of such an extension.

Please see attached submission.

I am a long-term resident of the Sutherland Shire, user of the Royal National Park, user of the Hacking River and Port Hacking catchment, mother and grandmother. My concerns about the existing longwall mining, personal interests and family connections are overshadowed by my concerns about the proposed extension of longwall mining. The proposal will allow further damage to the water catchment, posing significant and irreversible risks to the environment and the vast community who rely on clean drinking water from the catchment.

In my circle, bushwalkers have reported seeing coal in the Hacking River and tributaries. Whilst I have not personally seen what has happened when the mines' turkey nest overflow dam at Helensburgh has been breached, I have seen photos of environmental damage at Camp Creek, wildlife studies (informal- Dr Andrew Brooks Oct 2022). Also, water testing results that indicate excessive salinity at the mine’s discharge site and downstream in Camp Gully Creek together with increased levels of barium, lithium and strontium at the discharge site (Dr Ian Wright, August 2022).

The Metropolitan Colliery, owned by Peabody Energy, has a poor track record of compliance. A conviction and fine in 2025 for polluted discharges into Camp Creek in 2022 should ring warning bells, especially for an approved modification operating under the original licence of 2009. The weaker environmental protection includes allowing the purchase of offsets for irreversible damage to endangered coastal upland swamp ecosystem and the threatened species who reside there-including the red-crowned toadlet, giant burrowing frog, giant dragonfly and eastern ground parrot.

A clean water supply to the growing urban population, in perpetuity, is essential. The protection of endangered ecosystems and threatened species also has primacy. Longwall mining has already caused surface cracking, subsidence and disappearance of swamps. Surface cracking allows discharge water and any contaminants into the reservoir. The ventilation shaft (proposed) would clear 4 hectares of habitat. Peabody’s application to extend the reach of longwalls 317 and 318 should be rejected for these reasons.

Any application to extend the reach of longwall mining should be brought before the Independent Planning Panel. The legislation Peabody relies on is redundant. Water NSW, the authority responsible for management of the drinking water in the greater Sydney catchment, is unequivocally opposed to any longwall mining under water catchment.

I am extremely concerned about the Peabody colliery longwall expansion plans.
Considering the Woronora Reservoir supplies clean drinking water to the residents of the Sutherland shire and Northern Illawarra, it is of the utmost importance that the catchment area is protected from any potential for pollutants from increased mining contaminating our water, for the safety of not only the residents but also our wildlife and creeks.
It is already on record that the Colliery has had too many wastes spills in recent years which has polluted waterways in the National Park. Although Peabody was fined in March 2025, for two incidents of polluting Camp Gully Creek, they cannot be trusted to prevent this happening again.
I believe the go ahead for this proposal will severely affect the chances of the Platypus that have just been re-introduced into the waterways of Sutherland Shire surviving. A tragedy Peabody from pass track record would have no duty of care in preventing.
The proposal of clearing 4 hectares to construct a ventilation shaft site is a sensitive ecological area is not acceptable.
In my opinion the existing colliery should be shut down due to the pass pollution of our precious waterways, the idea that Peabody will be allowed to expand operations is outrageous. Please put an end to this proposal.