Modification 4 Longwall 317 and 318 Modification

I strongly disagree with any expansion of the mining under the Dam. Woronora Dam is an important source of clean water to the Sutherland Shire and Illawarra. We have already seen pollution from the Peabody mine into our once pristine Royal National Park. This has never been completely remediated. This is not good enough and the fine imposed on the mine was negligible. The mining under the Dam has caused fractures in the nearby rock formation. This can cause leeching of dangerous chemicals into our water supply. No other country allows mining under their water supply and neither should we ! This is not acceptable! Expansion is also not acceptable on the nearby environment. Our government should be ashamed for allowing a mine under a Dam any where in Australia. Therefore I would like to strongly condemn any future expansion of a mine that has several times already caused pollution into our Royal National Park. Also the cause of fracturing of rock associated with the Dam. This could cause dangerous poisons to enter out water supply.

I have been working in the industry for over 15 years and have been working at Metropolitan Mine for over 8 years. Metropolitan Mine is a wonderful place to work. It supports local suppliers, and in turn, we support the local community. By promoting local employment and economic stability, the mine provides sustained jobs and income for workers and their families.
Metropolitan Mine's commitment to constant monitoring and safeguarding the environment and the surrounding area is paramount to ensure air and noise quality, water resources, biodiversity and rehabilitation objectives are protected.
Metropolitan Mine has worked meticulously to engage all stakeholders to promote transparency in its operations, keeping the interests of everyone involved at the forefront.

I oppose this coal mine expansion because it worsens the climate crisis at the very moment we need to cut emissions. Coal is the dirtiest fossil fuel, and expanding mining operations locks us into decades of carbon pollution, delaying the transition to cleaner, cheaper energy sources like wind and solar.

Coal mining also brings serious local harm. It destroys land, contaminates water, and pollutes the air, putting nearby communities at greater risk of respiratory illness and reduced quality of life.

Metrop provides countless locals with vital employment. The continuation, development and investment in this mine is crucial to the growth of Helensburgh.

In 2022 Peabody Energy’s Metropolitan Colliery polluted Camp Gully Creek and in 2025 the company was convicted and fined. This shows clearly that Peabody cannot be trusted to safeguard our most sensitive environments.

The greatest risk is water quality. Subsidence and contamination threaten Sydney’s drinking water catchment at a time when PFAS and other pressures are already undermining public confidence. The cost benefit is completely unbalanced. A short term coal extension is not worth the risk to the water supply that millions of people rely on.

The proposal also requires clearing land in the Woronora Special Area which is off limits to the public because of its ecological and drinking water value. If the public would be fined for stepping into this land then a mining company should not be allowed to clear it.

There are also ongoing pollution risks downstream into the Royal National Park and the Port Hacking River where our community fishes, kayaks, and swim with our children. This is our backyard and the impacts are unacceptable.

While Peabody may have mitigation plans drafted, their actions show that they put profits over people. As a community we want a clean environment and safe water for ourselves and our children. The risks far outweigh any possible benefits and this modification should not proceed.

Thank you for the opportunity to comment on Modification 4 Longwall 317 and 318 Modification.

I object to the proposed Modification.

Before going to the reasons for my objection, I would like to note that I find it difficult to understand why this application is being made as Modification, rather than an application for a Mine Extension. In the initial modification scoping letter, the following statement is made:

“As a result of ongoing evaluation of the coal resource and detailed mine planning, Metropolitan Coal has identified an opportunity for the continuation of the Metropolitan Coal Mine by reconfiguring Longwall 317 and adding an additional longwall (i.e. Longwall 318).”

A reasonable person would conclude that more than doubling the size of one longwall and adding an additional longwall is an expansion, not the modification of an existing approval. The fact that the proposed longwalls are proposed for an area in the Special Area of Greater Sydney and the Illawarra’s water catchment, include the construction of an additional ventilation shaft requiring a construction zone of more than three hectares and including a sediment pond, are close to Woronora Reservoir and impact a named waterway, and add further destabilisation to an already significantly undermined area, only add to the need for a conservative planning approach to this proposal.

I note also that the company have included the remediation of an embankment in this modification, “following the slumping of a section of the embankment following heavy rainfall events in 2022 and 2023.”

Remediation of this embankment should not be conditional upon the approval of what is effectively the expansion of the mine. Embankment remediation is required as a result of past mining activity and should be undertaken regardless of whether the company’s plans to expand the mine are approved. If these remediation works are needed, they should be undertaken without waiting for the outcome of this Modification proposal.

I move now to the reasons for my objection.

The Surface Water Management Plan for the construction of a ventilation shaft in this Modification proposes that water collected in the Settlement Basin would be pumped into the mine workings to be treated in the existing water treatment plant for the mine. The history of water pollution incidents at this mine leave me with questions regarding the capacity of existing water treatment systems at this mine to handle increased volumes of water from an additional sediment pond, particularly water that has run through mine workings and is likely to have picked up pollutants as a result.

Since the publication of NSW Government’s Strategic Statement on Coal Exploration and Mining in NSW five years ago in 2020, the coal mining and steel manufacturing sector has seen significant change, with a drop in the price of metallurgical coal, and significant shifts globally in the transition to more efficient and less polluting methods of steelmaking, such as electric arc.

Since the publication of the 2020 ‘Strategic Statement’, the NSW Government’s Independent Planning Commission made a finding rejecting the expansion of Dendrobium Mine, also located in Greater Sydney’s Water Catchment, citing the fact that the expansion “risks long-term and irreversible damage to Greater Sydney and the Illawarra's drinking water catchment.” The location of Metropolitan Mine in relation to Woronora Reservoir makes this proposal as, or more sensitive than the mine expansion previously rejected by the IPC.

The supply of coal from Metropolitan Mine is not essential for steelmaking in the region. The company’s own subsidence predictions show that this mine expansion will result in impacts on the quantity and quality of drinking water, to irreplaceable upland swamps, ecosystems that provide natural water filtration, bushfire risk reduction services, and carbon dioxide drawdown services in addition to their inherent value as living systems, and impacts on Aboriginal Cultural Heritage sites..

The subsidence report notes that, because the mine will be bigger, there will be increased subsidence effects when compared to the current approval. In the subsidence report, the data provided by the company places the emphasis on the fact that subsidence in the proposed additional longwalls will not be greater in magnitude than subsidence caused by existing mining. However, this is of little relevance to the decision of whether or not to approve this mine expansion. Subsidence of the same magnitude over a greater area is effectively greater subsidence.

The affected area includes 29 Aboriginal Cultural Heritage sites. Past mining has resulted in impacts on Aboriginal Cultural Heritage sites. The subsidence report “the maximum tilt and curvatures are similar to or less than the maxima predicted for other Aboriginal heritage sites located above the previously extracted longwalls at Metropolitan Coal Mine. The potential impacts for these sites based on the Modified Layout, therefore, are similar to or less than those assessed based on the Approved Layout.”
I note that the subsidence report indicates that there have been impacts reported at 13 of 143 identified Aboriginal Heritage sites as a result of past mining activities.

It is well established that, once cracking occurs, coastal upland swamps cannot be remediated. A Trigger Action Response plan is not an adequate management system for these sites. For this reason, avoidance of all upland swamps is the only effective management plan – monitoring and recording damage already done is not adequate for these ecosystems. These sites cannot be offset, as there are a limited number of upland swamps, and they rely on specific geological conditions for their formation. An upland swamp cannot be made and cannot be repaired once cracking occurs. Upland swamps must be preserved. This modification – effectively a mine expansion – should not be approved.

I note that the Subsidence report recommends that coordinates for Survey Control Marks will need to be “on the completion of Longwalls 317 and 318, when the ground has stabilised.“ This indicates the potential for significant de-stabilisation of the ground, and attendant risks to Upland Swamps, Aboriginal Heritage Sites, and the water catchment.

Throughout the Subsidence report, there is an emphasis on the fact that the subsidence parameters would not be greater than that of the existing approval. However, this is of little relevance when it comes to approval – the AREA is increased, therefore, the impact is increased, compared to current approval.

Metropolitan Coal’s 2024 Annual Review report includes the following statements:

“The visual and photographic surveys have recorded observations of mining impacts including surface cracking, iron staining, gas releases and water discoloration/opacity.”

“The cracking and dilation of bedrock and associated diversion of surface flow and leakage of water through rock bars at pools which has occurred on the Eastern Tributary, including at the location of the stream which was the subject of the exceedance of the Eastern Tributary watercourse performance measure (the Eastern Tributary Incident), has resulted in increases in dissolved manganese and iron.”

“Total iron exceeded the baseline 10 Year ARI exceedance curve for 95% of the reporting period and exceeded the baseline 20 Year ARI exceedance curve for approximately 80% of the reporting period (Chart 62). Total aluminium exceeded the baseline 10 Year and 20 Year ARI exceedance curves for 100% of the reporting period (Chart 63). Total manganese exceeded the baseline 10 Year exceedance curve for 40% of the reporting period and marginally exceeded the baseline 20 Year ARI exceedance curve for approximately 5% of the reporting period (Chart 64). The results for total iron and total aluminium equate to a Level 3 significance and for total manganese equate to Level 2 significance.”

“The upland swamp groundwater performance indicator has been exceeded at Swamp 20 since 2012. Swamp 20 substrate water levels changed from being permanently saturated to being periodically saturated as a result of the passing of Longwall 21”

https://www.peabodyenergy.com/Peabody/media/MediaLibrary/Operations/Australia%20Mining/New%20South%20Wales%20Mining/Metropolitan%20Mine/Metropolitan-Coal-2024-Annual-Review_1.pdf

I include these extracts here to demonstrate that, despite Scientific Panel reports, IPC determinations, independent scientific research and EPA prosecution, Metropolitan Coal continues to observe these issues, and yet makes application to expand longwall mining in the water catchment.

A deeply concerning aspect of this proposal is that Metropolitan Coal indicates that it will seek further approvals for future longwalls in the area. The cumulative impact of continuing to longwall mine in the Special Area of Sydney and Wollongong’s water catchment, with more impact on waterways and potentially the reservoir itself, an increased need to manage polluted water and to manage mine waste and silt from sediment ponds, an increased need to destroy bushland for ventilation shafts, and to the finite and irreplaceable resource of upland swamps is very deeply troubling.

We are in a slow and unnecessarily painful process of energy and manufacturing transition. This process is being made much more difficult, and is resulting in an unfair impact on workers in the industry, as a result of continued delay in plans to close and rehabilitate mines. Ultimately, the heaviest impact of this delay lands on workers and communities. The recent lockout of Metropolitan Coal’s workforce is a very good example of this unfairness. It is simply not feasible to continue to accept predicted impacts on both the quality and quantity of our drinking water that are the result of mining in our water catchment.

I strongly object to the Peabody mine due to the extensive environmental damage and the impact to the Sydney catchment drinking water. The mine has been previously been responsible for coal effluent running into the national park with minimal repercussions. Why are we allowing a coal mine owned by an overseas entity to pollute our drinking water and a national park next to our biggest city?

Please do not allow this mine to go ahead.

My family and I live in the Sutherland Shire and drink from the Woronora catchment.
I feel this project will be detrimental to the cleanliness of the water supply that my family lives off.
I can’t trust Peabody to do the right thing as there has been pollution into the catchment and Royal National Park before.
Please don’t do this.
Please do the right thing.
Our livelihood depends on this water.
Thankyou for your time.

I strongly object to and oppose this proposal by Peabody Energy to mine longwalls 317 and 318 under the Woronora reservoir for multiple reasons.

Coal mining in the special catchment area has been proven to permanently damage the special catchment area on multiple occasions, including in the 2019 independent expert panel report and reported by the sydney morning herald. Mining of the coal seam causes irreversible damage to the overlying rock strata. This diverts water away from the dam and is lost to the mine works, mobilises heavy metals which contaminate the local ecosystems, and compromises the water supply - causing SydneyWater to spend more money to prevent supplying contaminated water. The permanent cracking of the rock strata caused by underground coal mining also results in the permanent drying of the upland swamps which destroys their function as natural water purification systems, results in permanent drying of the swamps which creates a bushfire risk, and destroys endangered ecosystems which provide shelter for threatened species such as the Giant Dragonfly and Eastern Ground Parrot. These damages are compounded by Peabody's plan to construct an industrial ventilation shaft in the special catchment area. In addition, coal mining activities result in fugitive emissions of carbon dioxide and methane, contributing to anthropogenic climate change, which will continue in perpetuity after mining work has ceased; Peabody Energy has no adequate plans to address this. Furthermore, Peabody Energy's activities in the special catchment area have resulted in the release of pollution, coal waste and sludge, into the Port Hacking river and Royal National Park on multiple occasions, which is home to newly re-introduced endangered platypus species. Peabody Energy, a foreign-owned company, have proven to be an irresponsible entity in their mining activities, and furthermore pay no tax to the Australian government due to deliberate tax minimisation strategies (https://michaelwest.com.au/peabody-australia-holdco-pty-ltd/). There is also legitimate concern that Peabody Energy will have insufficient capital to remediate the site upon completion of their mining activities.

Personally, from the above reasons and my professional experience as a research scientist, I am strongly concerned that Peabody Energy's existing and proposed activities are incompatible with the environment in which they are conducted. Peabody Energy has:
- caused permanent damage to Australia's native environment and water resources by deliberately cracking rock strata through their mining activities
- caused permanent pollution of Australia's natural waterways and Royal National Park, threating the existence of globally unique flora and fauna due to coal pollution
- threated contamination of my, my family's, and my community's drinking water supply
- abrogated their duty as a responsible corporate entity by paying no tax to Australian governments through deliberate tax minimisation strategies

For the above reasons I strongly object to and oppose this proposal by Peabody Energy.

Dr Edwin Clatworthy
PhD in Chemistry
Member of the Royal Australian Chemical Society

For the reasons listed in the atttached letter, 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.”

To Whom it May Concern
Peabody mining is planning to extend their operations deeper into the Woronora Catchment and I find this very deserving and of major concern. The mining operations have been in the catchment for over 100years at the time the area was not highly populated and developed as is in 2025. The area has changed dramatically and to allow the mine to operate and expand its operations is not viable. The Peabody mine does not have a solid history of environmental duty of care and has been responsible for a number of environmental accidents over its lifetime. Erosions which have led to landslides, a threat to the reservoirs of drinking water that supports large populations sustainability, polluting of water ways and river systems through already sensitive pristine bushland. The Peabody mining has been allowed to get away with little major accountability by the authorities. Also, its closeness to Australia's Oldest Royal National Park just adds a further major concern. This is a major commercial operation whose main objective is shareholders and profits. This is a conflict of interest for Peabody trying to juggle the balance sheet and their reasonability to the environment and its community. Peabody has not shown to be proactive in protecting the environment that it operates within and has little concern to appease the communities' issues and concerns. It's already a problem that the mine is operating in its current location, and its proposed expansion will only magnify the environmental issues that have become far more often in recent years.

I object very deeply to the Peabody mine extension. The Woronora is a true natural treasure for all of Sydney. I walk and swim there almost every week. I have seen koalas and all sorts of wildlife; the plant life is stupendous. By modifying and extending the mine, the health of the river will be endangered. Coal mining is not appropriate in this region at all, and to even consider increasing it is irrational. Peabody has a terrible record. Nobody will want coal in a few years and to sacrifice the Woronora for a few more dollars of Peabody profit would be a tragedy.

Activity of this nature in a national park, where a a critical drinking water source is nearby, and undertaken by an operator with a track record of carelessness in the local area is obviously a bad idea.

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.

The proposal for mining company to "Modify" the coal mining in the Woronora Catchment is disgusting. Mainly because it is NOT a Modification but a new project - which if reviewed as a new project it would not comply with current Environmental guidelines.

The American company undertaking the coal mining, Peabody, pays NO Tax to Australia, it pays a small royalty - but makes billions from mining. I demand my Government explain why permission would be given to an overseas company to pollute the water I drink; to ruin the environment - the destruction is well documented; and to expand mining activities without proper consultation. This company has a terrible track record when it comes to Environmental aspects.

I voted for a Government to govern and rule for the betterment of Australia; not overseas mining companies. Many people are concerned that our Government is not meeting legislative requirements for water and environmental protections. More and more people are becoming concerned about destruction of environment and the Government must act upon its electorate's concerns.

The company, Peabody, make very weak claims that they "fix" damaged swamp lands - which is impossible; and that they do Carbon Offsets. Carbon Offsets are not meant to counteract DAMAGE - they are to help reach net zero for carbon emissions; they do not negate damage and pollution .
The project should NOT go ahead - it is so bad it is hardly believable that any Government Department or sector of Government could consider giving permission for any expansion. It should be wound back, not expanded.
Lyn Farmer

The ecological responsibility of this mine is questionable as its history has shown.
Allowing continued mining in and under the water catchment is dangerous to our future.
Please do not allow this to go ahead .

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.

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.

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 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.