Modification 4 Longwall 317 and 318 Modification

The mining company supports a large number of local workforce and uses local suppliers where possible. The company invests in local conservation as well as investment in local sporting and education programs.

This project will support local jobs and will allow more investments in the local conservation.

I support this project to secure ongoing employment for the Illawarra local region workforce. I also believe that coal production is essential to support the NSW and Australian economy with coal that is used for steel making for Australian housing and government infrastructure projects.

Please find my submission attached

Cooper Riach
26th August 2025
RE: Peabody Metropolitan Mine, Modification 4 Longwalls 317 and 318

I am writing as a concerned resident of the Sutherland Shire to express my strong opposition to Peabody’s proposed Mod 4. I live in the town of Bundeena, one of the localities which relies on the Woronora Catchment for drinking water. For the last 3 years, alongside other locals, I have been documenting many of the major instances of pollution released into the Royal National Park from the surface facilities of the Peabody Metropolitan Colliery.

The severity and frequency of these releases of coal waste is unacceptable, and it is clear that this mine is unable to operate without causing significant adverse effects to the local environment.

With my own hands I have held the thick, black, tar-like coal waste product which has been released into Camp Gully Creek on numerous occasions. This coal sludge took up to a week to be scrubbed clean from under my nails. It is a horrifying sight, and one can only imagine the damage it is doing to the sensitive organisms which call this creek, and the Hacking River which it flows into, home. This is of particular concern when considering the recent release of Platypus into the Hacking River. Such large quantities of coal fines can smother the gills of the sensitive macroinvertebrates which platypus feed on. Should another major spill event occur, which is entirely likely since there are currently no adequate risk management plans in place to prevent such events, it could pose an existential threat to the platypus.

In March, 2025, Peabody was convicted in the Land and Environment Court and fined $196,560 for the pollution events of 2022. For a company which makes billions in income in Australia and pays zero tax, this is a wholly inconsequential amount. In the caselaw documents relevant to this court case, Peabody admitted that they were aware of their tailings dams being oversilted and that they were aware of the possibility of an overflow event for at least over a year before the September 2022 spill event occurred. With this in mind I call into question the good faith that this company purports to have in regard to protecting the local environment in which it is operating. It seems the company decided that it would be cheaper to accept a fine in court than it would be to properly remediate their waste storage facilities and appropriately dispose of their waste product. Still to this day there are countless chunks of coal to be found littered along the bed and banks of the Hacking River all the way down to Audley Weir, and even beyond.

The environmental damage to the river will never be properly remediated, and a fine cannot undo the amount of damage this company has caused. If Peabody cannot operate without causing significant pollution in Australia’s Oldest National Park, then it should not be allowed to operate further. It should certainly not be allowed to expand its operations as proposed in Modification 4.

The Wornora Catchment is a critical public asset. The catchment’s primary function as a drinking water supply is unequivocally the most important short, medium, and long term use for this area. Coal mining on the other hand provides only short to medium term economic benefits to the region. 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. While Peabody likes to downplay the damage that they are doing to these swamps, they are also quite open in their reporting that these swamps will suffer adverse impacts as a result of their longwall mining.

The Coastal Upland Swamps, aside from being a critical natural resource for the filtration of water flowing into the catchment, are also 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 and nullify all of the invaluable ecosystem services they provide.

These vital ecosystems are also home to numerous threatened species, such as the Giant Dragonfly (Petalura gigantea), Giant Burrowing Frog (Heleioporus australiacus), Littlejohn’s Tree Frog (Litoria littlejohni), and Red-crowned Toadlet (Pseudophryne australis).

The original planning consent for the longwalls, which this modification proposes to add to, was granted in 2009. Environmental regulations, as well as our scientific understanding of the damage which longwall mining causes to water catchment areas, have improved significantly since 2009. Peabody’s proposal to add new longwalls further in the protected Woronora Catchment area should be brought before the Independent Planning Panel.
Should the modification be approved under the original 2009 conditions, Peabody would be legally allowed to purchase offsets to justify irreversible damage to the protected water catchment. That is unacceptable, and something which the community at large will no longer tolerate. Public awareness about the impacts of mining under catchments has significantly increased in recent years, and so I would predict some significant public outcry should this modification be approved. I sincerely hope that the department chooses the long-term safety and security of such a critical piece of public infrastructure, over the short-term profits of an American mining giant.

Thank you for the opportunity to make submissions.

Warmly, and with hope
Cooper

Sydney’s water supply is too precious and vital to allow any additional longwall coal mining or other underground mining anywhere near our water storage. We are all aware of the damage done to sections of some of the Warragamba inflows due to cracking as a result of mine subsidence , I have family in lithgow who have seen sinkholes near their house, and the risks cannot be justified. The extension of the longwall propsed is purely for commercial gain; between underground and open pit coal mining anywhere near, our state is being plundered. Additionally, fossil fuels are responsible for much of climate change we are experiencing, and it is worsening. Please do not all the proposal to proceed, water storage is an essential, profits can be made in other ways and other areas

I am writing in support of this project, which represents a vital opportunity for continued investment in the local workforce and economy. The extension will secure stable, long-term employment for hundreds of local workers, ensuring financial security for families and sustaining the livelihoods of many in our region. The project will also generate significant economic flow-on effects for local businesses, including contractors, suppliers, and service providers. This continued investment strengthens the foundation of the community, encouraging further growth, innovation, and resilience in the local economy.

This extension is not just a project—it's a commitment to the future of our workforce and local industries. I fully support its approval and implementation.

Please see attached letter of support

the contribution to the local area (Helensburgh) and Illawarra in general, in respect to continued employment for the current workforce, contribution to NSW revenue through royalties paid is worthy of a positive response to this application. Additionally, it is an extension of a current approval. The mine is already established in the area of the application and it would be a waste of our resources to walk away from the remaining coal.

No profit is worth risking contamination of drinking water, creeks and habitat. This proposal is utter madness. Nowhere in the entire world is mining being conducted under a drinking water reservoir. Please. Think of anything else besides dollars. Anything. Its disgraceful, shameful and preposterously that this is even being considered.

I live and work in the Wollongong region, and have a deep connection with our land and community. Me, my family, and my friends rely on the water from the Woronora Reservoir, and I have grown up being astutely aware of the need for good water resource management and the horrific impacts of droughts on my community.

With this in mind, I unreservedly object to Modification 4 – Longwalls 317 and 318.

This modification proposed continued coal mining within the Special Areas of the Woronora Catchment - a critical drinking water source for over 5 million people. The longwall panels proposed are located worryingly close to the Woronora Reservoir - a crucial asset for regional water security. Longwall mining is well known to cause subsidence, fracturing of rock layers, and irreversible damage to watercourses, reservoirs, and upland swamps. This is a well documented and publicised fact.

In a country known for its droughts, and as a Wollongong local who was raised on water wise campaigns and now sees similar campaigns on saving water being run by Sydney Water, I find it ridiculously hypocritical that such damaging proposals could be considered.

The proponent, Peabody Energy, is a US-based multinational that pays no corporate tax in Australia, despite earning substantial profits from its Australian operations. As a company, Peabody also has a record of treating its workers poorly including unfair dismissals (as ruled by the High Court) and poor reactions to industrial actions. I recognise that mining is an important employer in our region, but it is unjustafiable to compromise a vital water source for limited short-term employment, especially when workers could be supported to transition into sustainable industries. This company clearly has no meaningful connection and feels no responsibility to our region, apart from wanting to wring it dry to increase their profits.

All this is setting aside the climate implications of increasing coal mining efforts. The international court of justice has ruled that we have an obligation under international law to prevent climate change, and that Australia may be liable to pay compensation to disproportionately impacted states if we fail to do so. NSW is not on track to meet its net zero targets. Continuing to approve the expansion of high-emissions mines (Metropolitan's scope 1 emissions in FY2024 were its highest on record), regardless of coal type, undermines our climate commitments and our responsibility to those vulnerable neighbours both in Australia and more broadly in the Pacific region.

These water, biodiversity and climate impacts and responsibilities were far less well known when the current mine footprint was originally approved in 2009. The ongoing use of modification pathways to prolong irresponsible mining operations under an outdated approval process is completely unacceptable. A proposal such as this that has serious environmental and public interest concerns should unquestionably be subject to 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.

In summary, this proposal is irresponsible and approving it would be placing overseas profits ahead of the welfare of our local community, both present day and future. As such, I unreservedly object to Modification 4 – Longwalls 317 and 318. I implore you to deny this application, and take a step in the right direction and towards securing a prosperous and long-lived Wollongong community.

Met coal is critical to support the energy transition whilst also supporting thousands of jobs across various industries.

I have worked with Metropolitan Colliery for the past 18 years, managing drilling projects, rock bar remediation, carrying out water sampling and inspections within the WaterNSW Special Area. Over this time, I have seen first hand the effort and care that goes into ensuring the mine meets its environmental responsibilities.

In all my years of involvement, Peabody has never taken shortcuts. They are thorough, transparent, and always committed to doing things the right way. The protection of the catchment has consistently been treated as a priority, and environmental obligations are always met.

The modification being proposed is a straightforward extension of existing operations by two years, until 2031. It does not involve any increase in activity or expansion of the mine’s footprint. From my experience, this extension will allow Metropolitan to continue operating responsibly, while maintaining the same high standards of environmental performance that I have observed over nearly two decades.

Good for the local community, good for the greater Illawarra & the state of NSW.
I'd like to see this proposal approved to help support my family and the thousands of other people / small businesses that benefit from the mine.

I support the proposed extension of operations at Metropolitan Mine. The project will maintain regional employment, secure the livelihoods of over 400 workers, and continue to provide significant contributions to the Illawarra economy. Extending operations while reducing the overall footprint strikes an important balance between economic sustainability and responsible resource management.

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/

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.

Hi,
I live in the Sutherland Shire and deeply value the Royal National Park and the
critical role the Woronora Reservoir plays in providing safe drinking water to the
region. I am seriously concerned that the proposed mine expansion poses an
unacceptable risk to the long-term security of our drinking water supply.
The Woronora Reservoir is a critical part of Sydney’s drinking water supply. I
believe coal mining so close to, and even underneath, our catchment land is
irresponsible. The risks to water quality and supply are too high.
Upland swamps are fragile and vital ecosystems. Mining underneath them puts
them at extreme risk of drying out or collapsing. These swamps cannot be replaced.
As we face increasing climate extremes, it’s unacceptable to expand a high
emission coal mine. This mine produces significant methane and contradicts the
NSW Government’s Net Zero targets.
We need to support coal communities in a fair transition, not lock them into more
years of damaging mining. Expanding this mine benefits a foreign-owned company
while putting our local environment and future at risk.
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.
Kind regards,
Linda Gotvik-Dobson

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.

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.