Modification 4 Longwall 317 and 318 Modification

NSW has a multi faceted state economy, and mining is a key part of this. Direct and indirect employment is significant, while the technological spin off businesses are also adding high value / high wage employment. The royalties and income from mining are a significant part of the state budget, and getting to net zero emissions by 2050, will still require coal in the meantime (according to all scenarios from the IEA).
Ensuring high paying direct and indirect employment is maintained in NSW is part of the needed decisions to keep living standards at acceptable levels while we pay for changes to the economy. Russia, Canada or Australia will supply this coal, let's make sure we get some of the wealth, while ensuring acceptable environmental outcomes.

I'm sure that the conditions of any approval, and the monitoring of the mining operation's environmental and safety performance can be managed in an acceptable way.

Regards

Protect Our Water Alliance objects to the project. Please see attached.

I am very concerned about the potential of the project to increase subsidence under water catchments and possibly the Royal National Park (which was formed in 1879 and is the second oldest national park in the world), and other sensitive areas.
An official NSW Government 1998 publication called Action for Transport 2010 foreshadowed an 11 km rail tunnel from near Waterfall/Helensburgh to Coledale. It is important that this option remains viable.
I can still recall coal mining (not necessarily by the applicant_ that occurred in 1985 that led to the need to close the South Coast Railway line to undergo expensive repairs to the Stanwell Park Viaduct.
40 years on, in 2025, the applicant for this modification in Court admitted to a breach of licence conditions, and was ordered to pay $500,000 in costs and fines for Royal National Park pollution. (see below)

The NSW Government has committed to the Climate Change Act 2023, and the approval of this project would cause significant reputational damage to the government as it would undoubtedly go against our commitment to achieving the goals of the Act, by contributing large volumes of greenhouse gas emissions. As a state, the government has committed to moving towards sustainable energy production, and we can no longer afford to allow any expansions in the fossil fuel industry.

As a long term resident of Thirroul i am appalled that extension to long wall mining in our catchment can even be considered with the public acknowledgment by Peabody that some damage will occur to swamps and watercourses. I am not anti mining but the catchment is a priceless asset for flora, fauna and our very sustainability into the future.
Mine where appropriate, no risk taking with our most precious resource.

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

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

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

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

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

I object to this project because it pushes damaging long wall mining further west under the Sydney water catchment. Sydney is the only major city in the world where long wall mining is allowed beneath its water catchment. The negative impacts of long wall mining on upland swamps and waterways that feed into Sydney's water supply are irreversible; a previously approved long wall mine has resulted in devastating and irreversible negative impacts on Waratah Rivulet (see https://www.abc.net.au/news/2012-09-26/riverbed-cracking-2/4281346 and https://www.ssec.org.au/our-campaigns/stop-woronora-mining-petition/).
In a climate emergency where there are increases in temperature and risks of extended drought, it is too risky to allow any additional long wall mining in Sydney's water catchment.
Coal mining also results in increased carbon emissions, both through the mining process and as a result of burning the coal thus mined. In a climate emergency where every country in the world needs to rapidly reduce carbon emissions to zero, no new coal mines should be approved, including this proposed extension.
I also object to the proposed modification because the proponent has repeatedly failed to adhere to the conditions of its license. For example, it was found guilty of two separate pollution events in 2022 and fined over $500,000 (https://www.abc.net.au/news/2025-03-24/coal-mine-polluter-peabody-ordered-to-pay-half-million-dollars/104658030). The Environment Protection Authority of NSW reviewed the proponent's license in 2022 (https://www.abc.net.au/news/2022-11-18/epa-threatens-to-suspend-peabody-energy-licence-after-pollution/101670658), due to concerns over the pollution incidents, which resulted in tighter conditions being imposed on the license (https://www.abc.net.au/news/2023-08-18/royal-national-park-platypus-health-fears-peabody-mine/102742268).
Additionally, Platypus have now been successfully reintroduced into the Hacking River, and there is risk that ongoing mining may jeopardise their future (see https://www.abc.net.au/news/2023-08-18/royal-national-park-platypus-health-fears-peabody-mine/102742268).
On all the above grounds, I believe that the project should be rejected.

This is a vital extension to the current workings that will provide jobs and income for the local community and NSW as a whole

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

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

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

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

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

I support the ongoing mining of metalurgical coal in the Illawarra for reasons such as:
- Continued local employment directly at mine sites and head offices
-Flow on effect to local community i.e small business, suppliers, contract partners etc
-Ability to keep making world leading quality Australian steel with minimal impact to infrastructure and environment with the ability to rail coal directly into the steel works
-Allowing ongoing investment in local Mine Rescue/coal services operations and access for mining graduates from Wollongong university and UNSW
-Peabody has shown an ongoing commitment to best practice underground coal mining with minimal impact to environment and world leading mine site re-hab initives
-Local made steel is vital for construction and essential infrastructure we rely on each and everyday
-Why would we risk having to use anything other than domestic coal or risk another shutdown steel works like Whyalla?
-The Illawarra has a rich history in coal and steel and thsi needs to be recognised and endorsed as we move forward with best practice to a greener future

Essential SSP for the Illawarra and beyond. Support local industry and economy whilst protecting the environment.

Tomorrow Movement Wollongong Objection to Metropolitan Mine Modification 4

Introduction

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

Executive Summary

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

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

Climate Change Impacts

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

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

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

Historically, in just 2024, Metropolitan’s Scope 1 emissions (direct from mining operations) reached nearly 700,000 tonnes of CO₂-equivalent, the mines highest recorded figure since the Safeguard Mechanism began in 2016. Over 80% of these emissions were methane, a potent greenhouse gas with 86 times the warming potential of CO₂ over 20 years making the Applicant’s mining project the fifth highest Scope 1 emitter among all coal mines in NSW.

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

Aboriginal Cultural Heritage Impacts

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

Economic Impacts

The Applicant, as a U.S.-based multinational corporation paying virtually no corporate tax despite substantial profits from its Australian operations, has a track record of poor treatment of workers.

In 2020, it unlawfully dismissed workers at the Metropolitan Mine — a case the High Court ruled was unfair dismissal.
Most recently, it locked out its workforce following a one-hour protected industrial action.
The modification application report cites 400 jobs at the mine, yet the ACTU reported just 160 workers being locked out. These inconsistencies raise doubts about the economic justification presented.

Additionally, continual investment in coal mining operations over other economic opportunities including sustainable industries is in error. The longer Australia depends on fossil fuel production, and extending the life span of various coal mines such as this, we risk being locked out of renewable energy development amongst other global powers.
We recognise the value of employment in the region. However, it is unjustifiable to compromise a vital water catchment for limited short-term employment, especially when workers could be supported to transition into sustainable industries.

Applicant Credibility

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

Coal mining is one of the Illawarra’s oldest and proudest industries and we’ve been part of this community for 138 years. The coal we produce is vital for local and international steelmaking – steel that builds our homes, schools, hospitals, and other essential infrastructure we all rely on every day.

Coal remains a vital resource, underpinning many aspects of our lives. From cars and phones to essential infrastructure and more importantly local and national jobs. Without Metropolitans contribution of Metallurgical coal to steelmaking, many people's lives will be impacted.
The coal industry’s impact extends far beyond its immediate operations. At a local level, Metropolitan directly employs around 400 people, providing stable, well-paying jobs that support families and strengthen the regional economy. However, the benefits do not stop there. The mine’s operations generate a flow-on effect, supporting numerous suppliers, contractors, and service providers in the community. These businesses, in turn, employ their own staff, further multiplying the economic benefit.
On a broader scale, the coal produced contributes to industries and projects across the nation and internationally, reinforcing its significance to economic development and global trade. Metropolitan’s role in this chain ensures not only the supply of a critical resource for steelmaking but also the sustainability of livelihoods in the local community. In this way, coal from Metropolitan is both an industrial cornerstone and a driver of social and economic wellbeing.

Metropolitan Mine supports local suppliers and the community. Metropolitain budget for environmental sustainability protection. Example of this is investing in the structural upgrades of the surface water management. Our product supports steel production in the Illawarra as well as supplying customers overseas. Employs 400 local workforce and spends money with local suppliers.

I would like to support the mine. The contributions the mine makes to the Helensburgh community is appreciated.

I believe the extension of the metropolitan mine will keep many people in the job for a few years, including myself as an outside supplier.
it is a great business for the economy.

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

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

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

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

Please DO NOT allow their Modification request to be granted.

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

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

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

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