Modification 4 Longwall 317 and 318 Modification

Please see attached submission.

The Peabody Energy mine is threatening not only the drinking water catchment in Woronora, but it threatens the ecosystems in the Royal National Park, which is my local backyard. I value this natural area and spend a lot of time hiking and swimming there with family and friends, 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. This seems like a slap on the wrist with little consequence. How can we even contemplate allowing them to expand their operations when they show such negligence.
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 are already drying up.
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 long distances through aquifers and fractured rock.
Peabody has proposed clearing 4 hectares of vegetation for the construction of the modification proposal in a 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.
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 am also interested to see the environmental impact statement associated with the modification proposal.

To Whom It May Concern,

I am writing to formally object to the proposed extension of the Peabody Energy Mine under the Woronora Dam, a critical source of drinking water for our community. This proposal presents unacceptable risks to our environment, water security, and the long-term health of the ecosystem and residents who depend on this vital catchment.

1. Threat to Drinking Water Supply and Catchment Integrity
The Woronora Dam forms an essential part of the region’s drinking water infrastructure, supplying clean water to the Sutherland Shire (and other regions). Extending mining operations beneath or near the dam and its catchment area poses a severe threat to the structural integrity of the catchment and the quality of the water it provides.

Subsidence from longwall mining, even when controlled, can fracture rock layers and alter natural water flows. This can lead to:
- Irreversible loss of water from the dam through underground cracks and seepage, permanently reducing its capacity.
- Contamination of groundwater and surface water through the release of heavy metals and mining by-products.
- Increased turbidity and sedimentation in the water supply, leading to higher treatment costs and potential health risks.
- The precautionary principle must apply when the risks involve drinking water relied upon by thousands, if not millions, of people.

2. Impact on Threatened Species and Sensitive Ecosystems
The dam catchment area supports a range of flora and fauna, including species listed as threatened under both state and federal legislation.
Endangered ecological communities dependent on stable hydrology and undisturbed habitats.
Mining activities, including clearing, blasting, and changes to groundwater tables, are likely to:
- Destroy habitat critical to the survival of these species.
- Disrupt breeding cycles, feeding grounds, and migration paths.
- Introduce invasive species and increase edge effects from fragmentation.

Allowing mining under the dam would contradict Australia's obligations under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) and state biodiversity conservation laws.

3. Risk of Pollution and Irreversible Environmental Harm
Mining operations frequently involve the use of toxic chemicals and create waste products, including tailings and slurry, which can leach into water systems. The potential for:
- Heavy metal contamination (e.g., arsenic, lead, selenium);
- Acid mine drainage;
- Leakage of pollutants into the catchment during high rainfall or equipment failure;

This presents an unacceptable pollution risk to the region’s water supply and natural environment.
Past cases across Australia have shown that once this type of damage occurs, it is either extremely costly and impossible to remediate. In light of the increasing unpredictability of climate change and more frequent extreme weather events, the potential for environmental disasters increases substantially.

The proposed extension of the Peabody Mine under the Woronora Dam is not just a poor environmental decision—it is a deeply irresponsible one. It places short-term economic interests ahead of long-term water security, ecological stability, and public health.

I urge the relevant authorities to reject this application outright. Our water supply and ecosystems are not expendable, and once damaged, they may never recover.

Yours sincerely,
Sara Farynski.

Please see submission letter attached

If we are to preserve the natural wonders of Australia, it will be important that many of us continue to live in dense urban areas such as Sydney. I well remember [from the previous century] the Cryptosporidiosis scare that drove western Sydney residents to only trust bottled water.... clearly a disastrous waste and pollution issue just on its own.

Now we know more about what challenges await us and the coming generations.
Surely by now we understand that an extractive operation, based on single-bottom line accounting and short-term re-turns, is not worth the risking the essential aqueous supply to all terrestrial life in the Sydney basin and the Illawarra.

Water quality is mighty important to NSW residents anywhere near the Metropolitan Coal Mine, but maintaining the crucial mix of gasses in our atmosphere is vital to all life in New South Wales and far beyond. The methane that will be released by the proposed mine modification, whilst shorter lived than CO2 pollution, is an acute accelerant of global warming effects and by orders of magnitude.

The sooner we cease seeking underground for the seeds of our destruction, the sooner we can help to ease the burden of repair faced by future generations.

For the reasons above, I strongly object to Modification 4 Longwall 317 and 318
Modification of the Metropolitan Mine. I urge the Minister to reject this proposal in
order to protect our water, environment, and climate.

The Mining and Energy Union South Western District (MEU) is proud to represent coal mineworkers in the NSW southern coalfields including at Helensburgh’s Metropolitan Mine. The Metropolitan Mine has a long history as Australia’s oldest continually operating coal mine; and today deploys cutting-edge mining technology to produce world-class steel-making coal for local and global markets.
The MEU supports the longwall modification proposed by Peabody (MP08_0149-Mod-4) as a sensible response to discovered geological challenges which would otherwise prevent the continued operation of the mine through to its existing approved mine life.
The proposed extension of Longwall 317 and addition of Longwall 318 would allow for continued mine operation until 2031 as opposed to premature cessation of operation in 2029. It would allow for the recovery of high-quality coal that would otherwise be sterilised, supporting local steelmaking at Port Kembla, generating economic activity including royalties for NSW and maintaining good local jobs for an additional two years.
This modification would see mining continue within the existing approved footprint, while prioritising safe operation of the mine and minimising environmental impacts.
Coal mining has co-existed with our unique environment and been an important provider of secure, well-paid jobs in the Illawarra region for generations. With the industry now under pressure on a number of fronts, the opportunity to provide an additional two years of certainty to 400 local families and the many downstream businesses reliant on the activity generated by the Metropolitan Mine should not be dismissed.
Early closure of the mine in 2029 as foreshadowed if the modification does not proceed would hurt local families and businesses and negatively impact the Illawarra’s industrial ecosystem including Port Kembla Steelworks and Port Kembla Coal Terminal.
The modification should be treated consistently with the existing Project Approval (08_0149) conditions under which the mine operates.

I object to the mining under our water supply. I believe the area should be preserved and protected from mining as it’s such an important and valued source for water supply in the Illawarra and Sydney.
Peabody mine has a terrible track record for polluting our waterways and damaging land. The Hacking River and Waratah Rivulet are just two examples. They get a tap on the wrist and a tiny fine when they damage land or pollute waterways or kill threatened species such as platypus and are able to continue.
I think the land in, around and under Woronora dam should be kept and preserved for the use of storing our water for our future and for the future of all the animals and plants that co exist around this area. The impact would be disastrous if this were to proceed and water escaped through cracks caused by movement and coal washed into waterways again at the risk of health to animals as it has done in the Hacking.
Please stop this preposterous proposal!

I am a health worker in the Illawarra and my father was a coal truck driver. I understand that coal mining was important for employment in the area in our past however, coal does not belong in our future. I strongly object to Modification 4 Longwall 317 and 318 Modification of the Metropolitan Mine. I urge the Minister to reject this proposal to protect our water, environment, and climate.

This mine produces significant methane and contradicts the NSW Government’s Net Zero targets. NSW is not on track to meet its net zero targets. Continuing to approve expansions of high-emission mines undermines our climate commitments.We are facing increasing climate extremes, it is unacceptable to expand a high emission coal mine. We need to support the Illawarra and all coal communities to move away from damaging fossil fuels not lock us into more years of damaging mining. Expanding this mine only benefits Peabody Energy, is a U.S.-based multinational company that pays no corporate tax in Australia.

This modification proposes continued coal mining within the Special Areas of the Woronora Catchment which is a critical drinking water source for over 5 million people. As a health worker I am I am concerned that the proposed mine expansion risks the long-term security of our drinking water supply.

We need to prioritise our health not foreign profits.

I strongly support this project because steel making coal is essential to energy transition.
This project not only supports direct local jobs and jobs at the local steelworks while upholding strong environmental standards.
Mine has been operating for over 130 years and supported generations of workers and there is no reason why this should not continue.

Please note. This submission attached is slightly corrected and should replace previous submission on behalf of the Sydney Knitting Nannas.

I object to any expansion of long wall mining due to the harmful and irreversible impacts on the terrain and wildlife and potential harms to human health.

Peabody has previously shown disregard for the environment by allowing coal waste to pollute port hacking.

Please consider my children, and all future generations and do not jeopardize our water catchments.

I support the extension of Metropolitan Mine to continue the employment of 100's of people in the local community.

1. Given that global temperatures have already increased 1.5 degrees as a result of burning fossil fuels, coal mining needs to be phased out, not extended.
2. As neither the Government of New South Wales nor the Australian Government are on track to reach their carbon neutral targets, it is irresponsible for the New South Wales Government to allow the extension of the Metropolitan mine into an area not previously gazetted for mining.
3. Water on earth is finite, the human population is increasing and water catchments need protection.
4. There is a significant body of evidence to show that long wall mining in the Royal National Park and the Illawarra has caused irreparable rock cracking, subsidence affecting stream flows, and has released and is continuing to release copious amounts of methane and carbon dioxide into the atmosphere. Metropolitan is now the fifth highest Scope 1 emitter among all NSW coal mines.
5. Upland Swamp S 106 is at risk from this mine extension. Given the increasing likelihood of increased torrential downpours interspersed with droughts caused by climate change, upland swamps are essential to store water during wets and release it during dry times.
6. The proposal threatens the ecology of a unique ecological zone that includes six birds vulnerable to extinction and the critically endangered Swift Parrot.
I strongly object to this proposal.

Please see attached PDF for detailed comments in regard to our objection.

Drinking water is a precious and scarce resource. The entire city depends on it. It is unacceptable to risk the health of millions of people and the public's right to access safe, fresh drinking water just to allow long wall mining for profit in the vicinity of crucial catchment areas.

Sydney drinking water already has hazardous to health pollution from so-called "forever chemicals" which can cause cancer. Cataract and Cordeaux dams already have a accumulation of mining sludge that's over 90 times higher than safe allowable levels.

What happens when mining for profit pollutes the drinking water supply and drains some waterways by cracking the rock (as has already happened, see Pool N, previously a permanent water pool of water that flowed into Woronora dam, which survived drought but was drained through cracks caused by mining). WaterNSW has reported that mining in the Woronora catchment area has caused ‘environmental consequences [that] have caused (or are likely to cause) breaches in conditions in the relevant development consents, including performance criteria to protect watercourses and Sydney’s drinking water catchment’ and ‘that there are numerous deficiencies in the manner that analysis and modelling is currently being used to support mining applications in the catchment.’ Recent mining activity has proven itself to be unsafe in the water catchment area.

Please prioritise the public's right to access an essential resource of safe drinking water over a mining company's wish to permanently endanger that life supporting supply. They can't guarantee that they won't irreversibly pollute and deplete important flows in the water catchment area. Please also elevate the crucial environmental values of water in the local habitats in an already dry environment that is suffering threats of increased drought and fire due to human accelerated climate change.

Michael Nicholson Consulting Pty Ltd, together with its subsidiary company Geomatix, has worked with Metropolitan Coal Mine for the past 15 years on numerous subsidence monitoring activities. These works have primarily involved precise survey monitoring of sensitive features within the water catchment area.

Over the past eight years, we have collaborated closely with Metropolitan Coal’s Technical Services Department in the development and implementation of autonomous, high-precision, real-time monitoring instruments. More than 30 of these instruments are currently installed throughout the water catchment area, continuously monitoring three-dimensional positions and ground movements. These instruments are integrated with approved TARPs and configured to issue SMS-triggered alarms directly to the management team if performance criteria are exceeded, enabling immediate action when required.

I have served as a subject matter expert in survey monitoring on numerous Metropolitan Coal technical committees over the past ten years. During this time, we / Metropolitan Coal have consistently demonstrated that our technology and rigorous management practices are capable of meeting all approval conditions.

Ok here's my text:
The Peabody Energy mine is threatening not only the drinking water catchment in Woronora, but it threatens the ecosystems in the Royal National Park, which is my local backyard. I value this natural area and spend a lot of time hiking and swimming there with family and friends, 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. This seems like a slap on the wrist with little consequence. How can we even contemplate allowing them to expand their operations when they show such negligence.
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 are already drying up.
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
Peabody has proposed clearing 4 hectares of vegetation for the construction of the modification proposal in sensitive ecological areas 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.
Lastly, as NSW has a plan to transition to renewable energy, I’d like to know how NSW 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 am also interested in seeing the environmental impact statement associated with the modification proposal.

Peabody Metropolitan Colliery (MP08_0149) Longwall 317 and 318

Current Environmental Protections and the current proposal by Peabody
The current modification, with the 2009 original conditions of approval, would not be passed today and must be brought before the Independent Planning Commission to ensure that all catchments are protected. Approval of this project, will set a precedent to Mining Corporation's that they can mine in Protected Areas and it undermines the WaterNSWs legislated objectives, as demonstrated below;

Irreversible damage to Woronora Reservoir Catchment
Peabody estimates that six, endangered coastal upland, swamps maybe destroyed, 4 hectares in the middle of swampland are required to build an industrial area with a ventilation shaft, trucks will move within the area, a spoil stockpile, waste sediment pond, and carpark will all be located in the protected catchment area. This catchment supplies clean drinking water to Sutherland Shire and Northern Illawarra residents. The proposal is an unacceptable risk to human life and endangered species. Government agencies have identified the risk to our water supply from the damage this mine has already caused. WaterNSW statutory obligations must be upheld, as a matter of public health, safety and for the protection of the environment and all animal species.

Further Implications to the Hacking River Catchment / Royal National Park
The proposal presents an ongoing and unacceptable risk to Royal National Park because the issues with the old Helensburgh train tunnel have still not been addressed by the EPA and a landslide occurred and water disgorged from the tunnel
over the coal stockpile there is nothing to stop further damage to the Royal.

Approval of this project will send a message to residents of both Local Government Areas that our State Government doesn’t have our health and wellbeing or the environment at the heart of its planning decisions. In the interests of the health and wellbeing of residents this proposal must be rejected.

The Peabody Energy mine is threatening not only the drinking water catchment in Woronora, but it threatens the ecosystems in the Royal National Park, which is my local backyard. I value this natural area and spend a lot of time hiking and swimming there with family and friends, 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. This seems like a slap on the wrist with little consequence. How can we even contemplate allowing them to expand their operations when they show such negligence.
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 are already drying up.
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
Peabody has proposed clearing 4 hectares of vegetation for the construction of the modification proposal in sensitive ecological areas surrounded by coastal upland swamps. The reality of a development of this nature being approved on a sensitive ecological area without a buffer zone is truly puzzling and unbelievable that it 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.
Lastly, as NSW has a plan to transition to renewable energy, I’d like to know how NSW 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 also like to see the environmental impact statement associated with the modification proposal.

My name is Harpreet Kaur Dhillon, and I am writing as a concerned community member who has spent many years appreciating and protecting the local environment. I strongly oppose the proposed modification to expand longwall mining beneath the Woronora Catchment.

The Woronora Catchment’s most important role is to provide safe, clean drinking water for the public. Nothing should come before this. Reports by independent scientists, WaterNSW, and government departments all make it clear that longwall mining in this catchment has already caused damage far worse than initially predicted. To knowingly expand mining in such a fragile and vital area is reckless and deeply irresponsible.

The Independent Expert Advisory Panel for Mining (IEAPM) has already raised serious concerns about the existing impacts of the Metropolitan Mine, noting that it “cannot rule out” significant adverse effects on the catchment. WaterNSW also warned as early as 2019 that the damage from longwall mining had exceeded what was predicted, calling for strict limits on future mining. Attempts to fix the damage, such as injecting polyurethane resin into cracked swamps, are limited, uncertain, and sometimes ineffective. An open letter from 20 independent scientists also warned against relying on remediation or treatment after the fact, reminding us that prevention is the only responsible option when it comes to protecting water.

The ecological damage is not abstract, it is ongoing, visible, and in many cases irreversible. A 2024 study confirmed that the loss of upland swamps caused by longwall mining is likely permanent. These swamps are critical natural systems that filter and release water, directly affecting the quality of the drinking supply. Their loss also threatens the survival of endangered species such as the Giant Dragonfly, the Giant Burrowing Frog, Littlejohn’s Tree Frog, and the Red-crowned Toadlet.

What makes this proposal even more concerning is that Peabody also wants to clear four hectares of vegetation to construct an industrial ventilation shaft in an ecologically sensitive area. Ordinary community members risk fines of up to $44,000 for simply walking in this same protected space, yet a coal company is being granted licence to destroy it.

The current licence for this mine is outdated, having been granted back in 2009 before our current knowledge of longwall mining’s impacts. It allows for offsets, meaning priceless natural systems like creeks and swamps could be destroyed and then “replaced” on paper. But no financial offset can ever substitute for the real, living ecosystems that provide us with safe water and biodiversity.

It is also impossible to ignore Peabody’s track record. In 2022, their negligence led to pollution spilling into Camp Gully Creek. They had known for three years that their tailings dam was over capacity, yet failed to act until it overflowed. In 2025, they were fined nearly half a million dollars in total, but for a billion-dollar company this is little more than a minor inconvenience. Their consistent breaches and disregard for environmental protections show they cannot be trusted with the health of our drinking water.

Peabody’s mine has harmed both the Woronora and the Hacking catchments. WaterNSW itself has stated there should be no option to remediate or offset significant impacts on swamps and watercourses. And yet, this proposal continues down a path of short-term profit at the expense of long-term health and safety.

For myself, my community, and future generations, I cannot accept the risk of losing the integrity of the Woronora drinking water catchment. Water is life, and once lost, no amount of money or remediation can bring it back. I urge the Department of Planning, Housing and Infrastructure to reject this proposal and to prioritise the long-term health of our water, our ecosystems, and the communities that depend on them.

Sincerely,
Harpreet Kaur Dhillon