Modification 4 Longwall 317 and 318 Modification

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.

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.

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.

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 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.

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 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 strongly oppose the submission because:
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.
2. Biodiversity and Threatened Species at Risk
This modification threatens the habitat of several vulnerable and critically
endangered species
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:
4. Climate Impact of Ongoing Coal Extraction
While the Metropolitan Mine extracts metallurgical coal used in steel production, its
climate impact remains significant
5. Planning Integrity and Approval Process
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.

Expansion of mining into a key water catchment area is unacceptable and not consistent with current environmental best practice. The Woronora Catchment and the Royal National Park should be preserved as a priority. The threat to biodiversity and water quality in such an important area, that services a significant number of people, should not be tolerated.

I support the submission to extend operations at Metropolitan Mine. The mine employs hundreds of local workers providing job opportunities, training, career progression and financial security for them and their families. The benefit of this extension also impacts a wider workforce that supports this operation. Furthermore, as a regional operation, it is supported by hundreds of suppliers, many of which are local and/or supported by local branches- therefore impacting even more jobs in the local community. The benefits of this operation are far reaching, and due consideration should be given to the positive impact the operation has on the prosperity of workers and businesses locally and in the broader economy.

Peabody Energy's Modification 4 Proposal

There has been significant damage to the woronora catchment. The Metropolitan Colliery is a longwall mine. Longwall mine causes subsidence & cracking of the surface level stone, which has already lead to many of the fragile upland swamps, creeks & streams above the existing longwalls to run dry. These surface cracks result in metal contaminants leeching into the surface water. This catchment supplies clean drinking water to the Sutherland Shire & Northern Illawarra.
The coastal upland swamps found in the woronora catchment are nature's water filteration systems. Damage to upland swamps is irreversible & can not be remediated. Coastal upland swamps are classified as an endangered ecological community at risk of extinction. Peabody has proseed clearing of 4ha of vegetation for the construction of an industral ventilation shaft site, in a senstive ecological area surrounded by coastal upland swamp. This is in the same area where bushwalkers will be fined $44k for risk of contamination to the catchment. In this same area endangered ecological community under the threatened species conservation act include - giant dragonfly (petalura gigantea)- eastern ground parrot (Pezoporus wallicus) - Giant Burrowing Frog (Heleioporus australiacus) - Littlejohn Tree Frog - Red-crowned Toadlet - Koala many also inhabit the area.
Numerous major coal waste spills in the last few years, each of which has resulted in thick black coal sludge contamination the waters of The Royal National Park. The environment damage to the river will never be properly remediated. A fine can not undo the amount of damage this pollution has caused. The risk to the RNP is ongoing and coal is still littered along the banks of the Hacking River. In March 2025, Peabody was convicted in the Land & Environment Court and fined $196,560 for the pollution events in 2022, a pitiful fine for a company which makes billions in income in Australia. Should another spoil occur, it could pose an existential risk to the platypus which have been reintroduced to the Hacking River Catchment. Coal fines can smother & kill sensitive aquatic macroinvertebrates which platypus feed on. The mines surface facilities are not suitable to deal with an operation this size. Peabody stll has no adequate risk management plans to deal with further coal spills into thr RNP. This is simply an unsuitable location for the coal mine.
I live near these areas and I am deeply protective of the ecosystem. The Woronora Catchment, Royal National Park, and the surrounding upland swamps are irreplaceable natural assets that provide vital clean drinking water, biodiversity, and habitat for endangered species.
It is unacceptable that operations of this scale, with a proven record of environmental harm, are permitted to continue in such a sensitive and critical area. The long-term risks to our water supply, native species, and protected ecological communities far outweigh any short-term economic gain.
I urge you to take immediate action to protect the Woronora Catchment and the Royal National Park by rejecting further expansion or approvals for Peabody’s operations in this region. Stronger protections, stricter enforcement, and genuine accountability are urgently needed to safeguard these ecosystems for future generations.
Thank you for your attention to this important matter.

Metropolitan Colliery provides ongoing employment for the 400-strong workforce, as well as supporting local businesses, including over $200 million spent with local suppliers last year and a $324 million economic return to NSW.
Peabody 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.
The reason for the modification application is to mitigate any risk to the environment, by reducing the Mine's footprint and avoiding any environmentallly sensitive Surface areas.

I support the Metropolitan Mine Modification Extension for its vital contribution to the Illawarra economy and its role in sustaining local jobs. The mine provides essential coking coal for BlueScope Steel, enabling the production of Australian steel that is critical for building and maintaining our nation’s infrastructure. This project ensures that Australian industries can continue to source high-quality raw materials domestically, strengthening both our regional economy and national self-reliance.

Peabody has already done considerable damage to the catchment of the Woronora dam and this expansion will continue the destruction of a unique source of unpolluted drinking water for a growing Sydney.
The company has a poor record covering environmental spills, worker relations and pays little tax in Australia from vast revenues.
The building of a 4 ha ventilation shaft in the middle of the catchment along with numerous access roads is totally destructive when they failed to build a similar proposal from their original submission in a far less intrusive area.
This proposal should not be treated as a modification but submitted as a new proposal with full and proper review of the full impact on the catchment of the Woronora and the many upstream swamps and creeks.
The fact that they can use this modification to expand into areas under their adjoining mining exploration area circumvents proper state overview of what is a major intrusion into what is supposed to be a protected area.
Under current state management Peabody Metropolitan Colliery seems to work with State Authorities to allow pollution and irreparable damage for a slap on the wrist. Their "repair" to extensive cracking by using a "gap filler" is a joke and is a telling indictment of the company and state government authorities. Their should be an ICAC investigation into the process.
If they were required to lodge a bond with the state government that will cover the billions of future dollars to remediate the destruction of this mining on the Hacking and Woronora we would see a true cost that the community will bear.

The Peabody Energy mine is threatening not only the drinking water catchment in Woronora, but it threatens the ecosystems in the Royal National Park and all the living organisms within that park, which is my local backyard. As a scientist and a resident of Sydney, I value this natural area. I spend a lot of time hiking and swimming there with family and friends while 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 - that fine is an embarrassment as it's not even a slap on the wrist and has no consequences for their operation. They must be held accountable. How can we even contemplate allowing them to expand their operations when they show such negligence in human and non-human health.

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 have are already drying up. This is going to irreparably damage Sydney and cause major health concerns. 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 through aquifers and fractured rock long distances. This will eventually lead to a class action lawsuit. It is not worth the damage that this will cause, especially given the fact that solar and wind are about to take over the energy generation. This mine is not needed and it is an embarrassment that our government is even considering it.

Peabody has proposed clearing 4 hectares of vegetation for the construction of the modification proposal in 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.

As a scientist (evolutionary biologist and ecologist), I cannot believe that my government - that represents me, my children and my future children - is not considereing the extraordinary impact that this will make on the health of current and future Sydney residents. I have spent a large amount of time exploring and researching the animals around Sydney, and this will lead to their eventual demise.

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 would like to see the environmental impact statement associated with the modification proposal as I cannot believe that this has been done properly.

The project creates jobs and supports the local economy.

The project is crucial to jobs and businesses within the Illawarra

To whom it may concern.

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