Modification 4 Longwall 317 and 318 Modification

Based on past experience I wholeheartedly agree with the assessment that the extension of the mine is likely to result in
" ... irreversible damage to the quality and quantity of Greater Sydney's drinking water supply."
I also maintain that, in the present context, expansion of any coal mining activity is highly undesirable.

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.

Metropolitan Mine is an important local employer and has taken significant steps to minimise its environmental footprint. I support continued operations at the mine.

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.

I support the extension of the Metropolitan Colliery project. The future of coal is in the Illawarra, with a steady stream of talent coming from the surrounding universities and towns, it is a key location for future job security in the region.

Peabody and Metropolitan Mine plays an active role in the Helensburgh community as a sponsor of the Helensburgh Tigers Rugby League team, and supports environment programs at Holy Cross and Helensburgh Public Schools. They also Support a 400 strong local Metropolitan workforce.
• Spend $217 million annually with local suppliers.
• Injected $324 million directly into the NSW economy
last year.
• Spend $73.5 million in wages annually.
• Have invested over $1 million in community grants
and sponsorship over the past 10 years.
• Paid $49 million in royalties to government last year.
• Develop a skilled regional workforce with 10
trade apprentices onsite annually through our
intake program.
• Invested nearly $1 million in local conservation,
supporting reintroduction of platypus and stuttering
frog into Royal National Park.*

It is utterly incomprehensible that mining activity could be allowed to proceed in the vicinity of our community’s water catchment area and national parks. The mine operator has a history of making errors causing environmental damage and water contamination. Mining operations within our drinking water catchment area should never never never be considered.

I am writing on behalf of members of the Shire Climate Action Network (ShireCAN), based in the Sutherland Shire, Sydney, to object to Modification 4 – Longwalls 317 and 318, Metropolitan Colliery. I will be outlining the key areas of concern as to why this submission is an objection in the attachment.

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

Objection to the Peabody Energy Metropolitan Coal Mine Expansion
RE: Modification 4 – Longwalls 317 and 318

Enough is Enough!
I’m a resident of the local area and an ecologist. I am writing to advise you of my strong opposition to the currently proposed - Modification 4 – Longwalls 317 and 318 - and any other expansion of the Metropolitan Coal Mine.
It is unacceptable, now we are well into the 21st Century, to be continuing to mine coal. We have energy alternatives and the technology to deliver them.
The location of this mine – beneath the Sydney Water Catchment Area, including parts of the Woronora Dam – is totally inappropriate if our natural heritage and drinking water quality are to be preserved.
This proposal to extend mining deep inside the Woronora Special Area – a protected drinking water catchment, with the proposed areas being just upstream of the Woronora Reservoir - where my drinking water comes from, must not be allowed.
This particular project also threatens irreplaceable upland swamps, and the unique plants and animals that live there.
Metropolitan Coal Mine has already shown all of us that it cannot be trusted with environmental stewardship, with previous operations in this mine being responsible for cracking of creekbeds in the water catchment area, and the particularly shocking coal sludge contamination of Camp Gully Creek in the Royal National Park in 2022.
People can place lines on a map to delineate property boundaries, or to suggest that there is an impermeable barrier between surface lands and below-surface lands, but as an ecologist I know everything is connected.

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.

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.

I believe this project is going to increase the short and long term damage of the surrounding areas. It will affect the surrounding habitats and any runoff from works are likely to impact the Platypus conservation and rehabilitation program in the south Sydney/south coast region.

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

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

The waterways will be polluted

Trading as TLE Wollongong, we are a key supplier of electrical goods to the Metropolitan Mine in Helensburgh.

We strongly support the submission to extend the mine’s steelmaking coal operations by two years, until 2031.

Our Wollongong business employs 35 full-time and 3 part-time staff, including salespeople, delivery drivers, and administrative personnel. Any decision not to approve this extension would have a significant impact on our operations, potentially leading to job losses.

I wish to lend my support to the Metropolitan Mine Modification Project in Sydney' Southern Outskirts. This country needs to maintain a healthy coal industry to be able to prosper.

I object to the project. Please see submission attached.

See attached - pdf document