Modification 6 - underground mining extension

I object to Modification 6 on the basis that it challenges Glencore, the owner and operator of Ulan coal operations, who made a commitment to net zero emissions by 2050. This proposal if it goes ahead will increase carbon emissions and totally invalidate their commitments.
More than 40 First Nations sites of cultural significance will be impacted by this proposal
Another impact will be loss of habitat for critically endangered species such as the Koala, Regent Honeyeater and the Long eared Oied Bat.
Groundwater drawdown from mining operations will result in the loss of base flows of water to both the Goulburn River and the Talbragar River further away to the west.
I wish to register my objection to Modification 6 of Ulan Coal Operations.

I object to the proposed …

I write as an individual deeply concerned over many years by the adverse impact of coal mining. on the future welfare of people and the planets natural systems which sustain us.

Locally, the impacts of the mining operation have already impinged directly on the landscape, including adjacent and nearby land of high cultural significance reserved also to protect wildlife under the New South Wales National Parks and Wildlife Act. Any further expansion will only compound these adverse impacts

Sadly extensive mine operations have already affected the nature of the valley including through clearing, distortion of natural water flow patterns, disruptive sound and light pollution, traffic and alienation of former rural and natural landscapes.

Globally, burning coal, from where-ever sourced, is well recognised as a contributor to climate change – a point long highlighted by Australia’s Pacific nation neighbours as evidenced in calls to cease coal mining made at the IUCN conference by leaders from Kiribati and other countries at the 2014 World Parks Congress held in Sydney, More recently this issue has been specifically recognised in a number of legal cases. The coal mining industry has had more than enough time to adjust to the need to wind down and out of the business. Offsetting of carbon emissions is not the answer, and indeed is increasingly being shown as a furphy, not even truly delivering a ‘no net loss’ but rather a failed diversionary exercise of pretence.

The just released 2022 State of the Climate Report by the Bureau of Meteorology in conjunction with CSIRO reinforces this concern, noting inter alia that many of the climate changes are being driven by rising levels of greenhouse gases in the atmosphere caused mostly by the burning of fossil fuels with consequent implications for matters protected under the EPBC Act.

As a conservationist of long standing, with backgrounds in science, local government and environmental advocacy I consider it would be wrong to approve any expansions that further entrench and facilitate an increase in greenhouse gas emissions.

To whom it may concern,

I am writing today to express my support for the Ulan Coal Continued Operations Project Modification. As a resident of Mudgee, I support the extension of the mine, and therefore extending mine life to 2035. Ulan Coal has been providing local jobs and supporting the community for over 100 years, approval of the modification will continue to provide economic benefits to the region.

Thank you.

See attached PDF letter submission

Refer attached

I support the Mod 6 Project as it will allow Ulan Coal Mines to provide security of employment for over 650 employees and continuation of its significant contribution of the local and regional economy. This Project does not provide any major changes to the current environmental and social impact of mining activities and requires only minor changes to current infrastructure.

Objection attached

Submission objecting to project attached

Inland Rivers Network submission of objection attached

My objections are in the attached submission

Objection to Ulan Coalmine Mod 6
Background
Ulan Coal Mine is one of the oldest coal mines in Australia, dating back to the 1920s. It is located near the village of Ulan in the central west of NSW, approximately 45 kilometers north-east of Mudgee and 25 kilometers north-east of Gulgong. Ulan Coal operations is 100% owned and managed by Glencore. It comprises two underground mining operations – Ulan Underground and Ulan West Operations. Glencore is a Swiss-based multinational corporation, one of the world’s largest mining companies. Ulan Mine has current approval to produce 20 million tonnes of thermal coal per annum until 2033 from their three large adjacent coalmining operations.
The proposed new workings will provide continuation access to a large area of coal to the north of current operations. The modification aims to extend underground longwall panels to extract a further 25 million tonnes of thermal coal and extend the mine life by two years to 2035. Existing approvals should not be easily extended. Ulan Coal Mine produces thermal coal for export. So it is not needed for any use within Australia. Thermal coal is produced for use in electricity production. Thermal coal with a high carbon and sulphur content means it is also a major contributor to greenhouse gas emissions and global warming. There are other cheaper methods for power generation, mainly renewables. Despite Glencore’s commitment to net zero emissions by 2050, this proposal will continue to increase global carbon emissions. This is greenwash.
1. Water impacts
a) Ulan Mine is located at the headwaters of the Goulburn River Catchment. The cumulative impact of underground longwall mining of current approvals has caused permanent loss of irreplaceable groundwater sources.
b) The iconic groundwater dependent ecosystem on the Goulburn River known as ‘The Drip’ is incorrectly described with no recognition of the connection to the regional groundwater system. Areas such as The Drip have special historical, social and Indigenous significance to residents and will be placed in significant risk through expanded mining.
c) The Ulan Coal Mine is still polluting the Goulburn River with salty discharges into the river. No monitoring of the salt levels of these discharges has taken place.
d) The flora and fauna habitat in the region relies on the availability of water resources, both above and underground. The risks and impacts to good water flow to the Goulburn River and associated areas have not been adequately investigated.
e) Cumulative groundwater drawdown will cause loss of additional base flows to both the Goulburn River to the east and the Talbragar River to the west for up to 3,000 years.
2. Biodiversity
a) The mining complex covers more than120 km2 (12,000 hectares) of sensitive environments with significant cultural heritage values and straddles the Great Dividing Range. An additional area of 993.2 hectares will be impacted by mine subsidence including cumulative impact on significant sandstone cliff lines, if the extension goes ahead.
b) Loss of 24.7 ha of woodland vegetation including 9.5 ha of critically endangered White Box – Yellow Box – Blakely’s Red Gum Woodland ecological community providing habitat for numerous threatened fauna and flora species
c) Removal and disturbance of habitat for critically endangered animals and birds: Regent Honeyeater, Swift Parrot; endangered Koala and Long-eared Pied Bat and numerous other threatened fauna species.
3. Past Failures to apply Environmental Offsets.
a) In was reported in the Guardian in 2021, that Ulan Coal mine was granted eight extensions over eight years to the deadline by which it had to secure offsets to compensate for the destruction of box gum woodland and habitat for the swift parrot, regent honeyeater and large-eared pied bat. But 10 hectares remained outstanding a decade after the mine was approved. It has only recently been carried out.
b) The pattern of delays had set a precedent for mining companies securing offsets only when it’s convenient for them, apparently without consequences.
c) Offsets facilitate environmental destruction while kicking the claimed compensatory measures down the road. The federal environment department has never fined a coal company for failing to secure an offset on time.
d) However, in light of this history, it is clear no one can trust Glencore to fulfil its environmental obligations.
4) First Nations Culture
An additional 48 sites with First Nations cultural values will be impacted. The cumulative loss of cultural heritage across the Ulan Mine is highly significant. There has been no official audit of the sacred sites and heritage objects in the area.
It is imperative that coal mining cease at the Ulan operation no later than 2033 to allow for the necessary global decarbonisation for the management of climate extremes. It would be preferable that the Ulan Coal Mining company cease its operations immediately, if they cannot mitigate their environmental impact. The Rylstone community has suffered enough.

see attached file

Wellington Valley Wiradjuri Aboriginal Corporation Elders, Members and Knowledge Holders have been consulted and agree to the proposed modification application.

Please see the attached submission for a snapshot of some of the reasons Lock the Gate objects to this Project.

Glencoe Ulan Coal have fully consulted with me as an interested party and I support the application for Modification 6.

See attachment

Ibrahim Farag
1072 Blue Springs Road Cope
Lot 72 DP 750742

Objection to Ulan Coalmine Mod 6 Application

Ulan Coalmine is a very large coal extractor operating within the Mid-Western Regional Council LGA, in close proximity to the Goulburn River, it is one of three large coalmining operations operating in the immediate area.

UCMPL currently has consent to extract in excess of 22 million tones of thermal coal per annually until 2033. With three large longwall underground operations mines and previously an open cut mine, it covers an area of almost 150 km2, much of which is environmentally sensitive pristine wooded forest with many indigenous cultural heritage areas. As landholders we have no idea of the total volume of coal been extracted by the three companies, the cumulative impacts on surface and Ground water or impacts of subsidence on the region. I believe it is incumbent on the department to make those facts known to the property owners.

The original Mod 6 application proposed an extension of the MOD 3 approval over my property Lot 72 DP 750742. In the absence of the mandatory environmental assessments prior to the MOD 3 application I strenuously objected till those studies were performed and completed. UCMPL elected to amend the MOD 6 application by deleting the proposed extensions over my property.

It is my contention and strong submission that it is totally remiss and negligent of the Department to continue to consider applications by UCMPL until the mandatory environmental studies associated with MOD 3 are performed.

Those studies were not performed due to the submission of FALSE & MISLEADING Information in the EA's prepared by UMWELT on behalf of UCMPL, the Department is very conversant with the entire matter and has to date failed to ensure those studies are performed.

SURFACE AND GROUND WATER:

It is disturbing that comprehensive studies have not been performed on the cumulative impacts of all the current approvals on our surface and ground water, {our water resources are the life line of the entire area}.

As a consequence the immeasurable loss of our priceless Surface & groundwater "an essential NATURAL resource", has never been quantified, I am in doubt this is because to do so would be detrimental to the future operations of UCMPL and the other two mine companies in our district.

SUBSIDENCE:

In addition, it is of great concern that the subsidence modeling submitted and accepted by the Department has proven to be totally inaccurate and flawed.

The sad reality that the subsidence and surface cracking resultant from extraction beneath the property known as "Woodbury" has proven that the modeling is totally erroneous and flawed. That property has suffered from at least one SINK HOLE and the subsidence cracking to the surface has by far exceeded the modeling. While the predicted surface cracking was less than 20omm wide, it has in fact exceeded 1.4m in width.
Any reasonable person would anticipate that the consent authority would halt all operations and have the subsidence and water modeling peer reviewed by a SUITABLY qualified experts in addition to an internal review / investigation.

The disparity between the predicated surface cracking and the resultant surface cracking is not what could be regarded or viewed as "within the margin of error". The disparity in the surface cracking can only be described as dire if not catastrophic, and reinforces the dangers of relying on modeling.

It would be beyond alarming if the Department has been made aware of the disparity and not commissioned independent consultants to conduct site visits so and to prepare an impartial report on the failures of the modeling.

As landholders we are at the mercy of the Department in the hope they will always do the right thing and as the consent authority will act to protect of the interests of the landowners impacted by mining activities.

Finally the flawed modeling will undoubtedly have an impact on the veracity of the other EA studies. In simple words, had the modeling predicted there could be surface cracks well in excess of a meter in width:
1. Would the Department have approved the applications?
2. What impact would this have had on the reports by other consultants preparing studies on threatened species, natural habitats, creeks, indigenous cultural artifacts and heritage?
3. Sandstone outcrops, caves and cliffs?
4. The draw down levels ground water, aquifers and spring fed dams?
5. Water bores?
6. The loss of natural surface water into the catchments
7. Creeks, dams, billabongs, natural springs and swamps?

IMPACTS OF SUBSIDENCE ON SURFACE AND GROUND WATER:

Given the matters raised above, there is no doubt that the flawed subsidence modeling will directly impacted the water modeling which included impacts on aquifers and surface runoff. Given that "Woodbury" is the first privately owned property that UCMPL is extracting coal from beneath, the Department must revisit all the modeling prior to permitting extraction from beneath other privately owned land holdings.

To that end it I ask the Department and assessing officers the following questions:

1. Are they able to inform the land owners with any degree of certainty if the surface cracking and subsidence will be consistent with the modeling they relied upon prior to granting the UCMPL consents for underground wall mining?
2. That their properties will not suffer surface cracking mirroring that of Woodbury?
3. If the Surface cracking and subsidence will exceed the modeling what impact will that have on their surface water, runoff to catchment, aquifers and bores?
4. What are the current daily / weekly / monthly water pump outs rates from all the longwalls currently been mined?
5. Will the Department revisit and have the subsidence and water modeling they relied upon peer reviewed by totally independent experts in the respective fields?
6. What will the impacts on the ground be as a direct consequence of the loss of surface and ground water?
7. Does the Department accept that loss of surface and ground waters will have a permanent, irreversible and dire impact on threatened species, their natural habitat, and indigenous cultural artifacts and sandstone and cliff collapses.
OTHER MATTERS OF SERIOUS CONCERN:

1. Why has the Department accepted a Modification application that is silent on the cumulative impacts of subsidence, Ground and surface water as they do not acknowledge that the subsidence modeling has proven fundamentally flawed and erroneous?

2. It is my very strong submission that the Department can not approve any further extension to the Ulan operation beyond what has been approved no 2033.

3. The Department has a duty to acknowledge and ensure that their consideration of any coal application includes global decarbonisation targets for the management of climate extremes are met.

Annexures:

In support of the matters I raise I have attached a number of scientific papers and other relevant material:
1. A plan of the areas ALREADY declared within a Mine Subsidence District for Mudgee.

2. Scientific paper on "IMPACT OF LONGWALL MINING ON SURFACE WATER-GROUND WATER INTERACTION AND CHANGES IN CHEMICAL COMPOSITION OF CREEK WATER"

3. Scientific paper on " SURFACE WATER–GROUNDWATER INTERACTION IN THE FRACTURED SANDSTONE AQUIFER IMPACTED BY MINING-INDUCED SUBSIDENCE: 1. HYDROLOGY AND HYDROGEOLOGY"

4. Scientific paper on "SURFACE WATER-GROUNDWATER INTERACTIONS IN A CATCHMENT IMPACTED BY LONGWALL MINING "

5. Scientific paper on "THE INVESTIGATION OF GROUNDWATER-SURFACE WATER LINKAGES USING ENVIRONMENTAL AND APPLIED TRACERS: A CASE STUDY FROM A MINING-IMPACTED CATCHMENT"

6. Scientific Paper on "SURFACE WATER-GROUNDWATER CONNECTIVITY IN A LONGWALL MINING IMPACTED CATCHMENT IN THE SOUTHERN COALFIELD, NSW, AUSTRALIA"

7. Scientific Paper on "CHANGES OF WATER QUALITY IN A STREAM IMPACTED BY LONGWALL MINING SUBSIDENCE"

8. UCML Plan showing extent of "Catchment Boundaries and Remnant Ponding Impacts"

9. I have also attached my Social Impact survey response as UCML have NOT attached it in full as originally discussed and agreed. I object profoundly to their attempts to bury my responses.

I wish to express my support for Ulan Coal’s Modification 6 and the continuation of coal mining activities. In my view, the modification sustains regional employment, supports local industry, and ensures ongoing environmental management.
Ulan Coal is one of the largest employers in the Mid‑Western Region, and Modification 6 helps secure long‑term employment for local workers and contractors. The mine’s operations underpin a wide supply chain, benefiting transport operators, trades, service providers, and small businesses across the region. Continued employment helps retain families in the region, supporting schools, health services, and community vitality.
Maintaining production levels ensures continued royalties and economic contributions to NSW, which support public services and infrastructure.
Ulan Coal has a long record of operating under strict environmental conditions. The Company also contributes to local initiatives, sporting groups, education programs, and community infrastructure.