Moolarben OC3 Extension Project

Warrabinga NTCAC would object to the Mining

See attached letter submission

This is a personal submission exampling just one person in this community – The social impact, intertwined with economic, employment, aboriginal culture, environmental and health impacts. They are inextricably linked
• Most people have little inkling of the challenges involved in fending off a major development, such as the proposed Moolarben OC3 “Extension” for 4 new pits!! in a sensitive environmental region for “run-of-mine (ROM) coal to be exported. This is an Australian resource that is being exported to further add to the world’s pollution.
• Where is the “promised PRIA PROCESS? This after all is “NEW” under the guise of an extension. This only further encourages my mistrust for the NSW government – NSW government doesn’t have a good record for transparency.
An economic value is place on the Coal resources, but what value is place on our community? How do you value people? Aren’t our people our greatest resource? Do you value them through what they given, or do you value them for their economic output in today’s dollars? Does that mean we place no value on our elders? Our children? Our artists? ....the list goes on. One may argue that in an advanced economy, people have the highest value, and they are not expendable and continue to add value to our society in non- quantifiable ways, albeit they may not be creating any direct output.
What value is placed on the aboriginal people and their sites and culture? Or have you thrown them a bit of money and placed a “gag order” on them. You pick up a few artifacts, put them in a shed and say you are being culturally sensitive. This demonstrates a complete lack of understanding for our elders and culture. These people cared for the land for thousands of years without the type of destruction coal mining causes. The fact you say you will rehabilitate it is a joke. You may fill the pit in, but you cannot return the top soil and ecological systems that you destroy in the open cut process. This is all for what ….. a few export dollars. A very small short-term reward for a for-ever destruction, not to mention your contribution to greenhouse gases on our planet.
There presents many aspects of what will be impacted should the proposed Coal Extension and subsequent Coal mines proceed:
• We will lose community – a community that our government needs to support and encourage for the benefit of all Australians.
• We will lose more agricultural enterprises that provides food and fibre in a sustainable and respectful way to both land and animals.
• We will lose our natural native environment that provides refuge to our animals, our birdlife and our people
• We will lose the health restoring environments so desperately needed in these high stress times
• We will lose aboriginal cultural sites, ceremony places and opportunity for ceremony, their connection and ability to care for country, and our opportunity to work together, and share that learning with our visitors, creating a greater reach of understanding – again very needed in our country. Working together and embracing the learning, goes way beyond a “government apology.”
• Families will lose their opportunities to create “grounding” experiences for their family, their holidays away from screens and man-made noise, where they are able to nurture their relationships
• We will lose the “time out” opportunity, time to “chill,” and take stock
• We will lose our visitor group – our connections to their world and their connection to this world
There are so many reasons why this Coal Extension project should be abandoned:
• The critical risk to waterways, streams, springs, swamps, wells, and bores
• The extraordinary loss of water for this community and all downstream
towns and enterprises – 653 litres/tonne of coal
• The pollution with the noise, light, and dust
• The extra heavy traffic in what is currently a rural region and a rural region embraced by tourist for those qualities
• The damage to Country and it’s connections
• The destruction of habitat to wildlife especially endangered and threaten
species
• The loss of pristine natural environments
• The annihilation of aboriginal culture with the destruction of country – you
give them another funeral, continuing the trauma leaving no sacred land
unscathed
• The displacement of people, especially generational families who represent
the history of the region
• The displacement and upheaval of people who have come recently, moving
away from cities for lifestyle reasons
• The job losses, the small business failures
• The increased emissions and Climate change
• The medium-term impacts of relying upon new coal activity to generate
income. In a few years, governments will need to develop transition plans to
re-employ workers into new jobs not related to the closed mines
• The unsuitable timing, given people are just recovering from Lockdown, focused on their health
& safety, many will be completely unaware this opportunity for consultation has come and gone, almost stealthily
• The unsuitability of the consultation for this community with poor connectivity and low technology skills
This just to name a few, but I go back to drawing your attention to the value of people. This submission isn’t referenced with data and case studies. I simply ask that you NOT proceed with this project because of the people.
Above all, please place value on the people. As a reference, please come and meet the people, talk to the people, and develop an understanding of an asset far greater than the Coal Reserves.

The unacceptable damage to the social fabric of the community and poor mental health implications of mining is wrong. It has to stop. The greed is unsustainable. There is enough coal in our mines for our Australia consumption. Our water is to precious and it can’t be wasted in support of mining anymore. No more extensions

Objection to Moolarben Coalmine Extension to Open Cut 3
[Pdf file is also attached to faciltate your access to links to further information]
I object to this proposed coalmine extension. I am gravely concerned to consider the certain consequences of increased coal extraction and burning for energy on our greenhouse gas levels and increasing global heating. It is totally inappropriate to approve this proposal to produce an additional 40 million tonnes of coal and increase greenhouse gas emissions by 86.59 Mt CO2-e when the imperative is to cut emissions.
The International Energy Agency issued the clear directive late in 2021 that the world cannot afford to approve any more extraction of fossil fuels if we want a chance of holding warming to 1.5 degrees. We have already seen and felt the havoc wreaked by the extreme weather events precipitated by climate chaos with our current level of ocean and atmospheric warming. This proposal should be refused on the basis of climate change impacts alone.
Further reasons to refuse this proposal clearly include the impact on biodiversity. It is absolutely outrageous to consider clearing nearly 480 hectares of the Critically Endangered Ecological Community Box-Gum Grassy Woodland and a further 140 hectares of native vegetation also. Critically endangered means precisely that. This ecosystem and the habitat it provides to support biodiversity is in danger of extinction. Destruction of this vegetation cannot be offset, there is simply not enough of this ecological community in existence. If the threatening processes such as clearing and anthropogenic induced climate change are not abated this ecological community will become extinct.

The loss of over 620 hectares of native vegetation by this proposal in an area already heavily impacted by current approvals should not be approved. There would be ecosystem habitat loss for 22 threatened fauna species including: Regent Honeyeater (Anthochaera phrygia), Koala (Phascolarctos cinereus), Squirrel Glider (Petaurus norfolcensis), Large-eared Pied Bat (Chalinolobus dwyeri). The Regent Honeyeater population could be down to 300 individuals.
https://www.theguardian.com/environment/2021/mar/17/how-an-endangered-australian-songbird-regent-honeyeater-is-forgetting-its-love-songs?CMP=Share_iOSApp_Other&fbclid=IwAR1tJo4VDdRa2l-VJqZHLHgx3Fy_Nj5ZXXnn79bjTvkRiBXDLUp3NbBtETw

The Koala population was so affected by Black Summer both directly and indirectly by being burnt to death and having extensive areas of habitat burnt that it is now listed as endangered. IT is in danger of extinction.
https://www.edo.org.au/2022/06/27/nsw-follows-suit-and-lists-koalas-as-endangered/

There is also a predicted loss of baseflows to the Goulburn River of between 180 – 225 million litres /year and 600 million litres in wet years. This is an unacceptable impact on river health and downstream water users, including Goulburn River National Park. This is so clearly also not in the public interest.
The proposal should be rejected.

I am objecting to the new mine open cut extension for the following reasons:

The mine is owned and operated by Yancoal, a Chinese owned multinational.
The mining complex covers over 80 sq. kms of sensitive environments with significant cultural heritage values. The cumulative impact of current approvals has caused a major loss of threatened species habitat and First Nations culture, sandstone cliff removal and collapse, and permanent loss of irreplaceable water sources.
The proposed expansion on exhibition intrudes further into the upper Moolarben valley, an area rich in biodiversity, ringed by natural springs and bounded on three sides by the outstanding Munghorn Gap Nature Reserve that straddles the Great Dividing Range.
The new mine will introduce an increase in greenhouse gas emissions by 86.59 Mt CO2-e
130 first nations cultural heritage sites were identified within or overlapping the proposed area including shelters with artefacts (one with possible burial), and axe grinding groove site and, given miners lack of respect for First Nations sites, these will be at critical risk of destruction or limited access.
The likely permanent loss of potable, good quality (low salinity) groundwater from springs that provide fresh flows to creeks and the Goulburn River including a predicted loss of baseflows to the Goulburn River between 180 – 225 million litres /year and 600 million litres in wet years. This will impact on river health and downstream water users, including Goulburn River National Park.
The extended mining operations will come within 100m of the Munghorn Gap Nature Reserve threatening important conservation values especially native bird and Koala habitat including noise, dust and lights from the 24 hour operations will disrupt the many identified threatened and endangered birds, mammals and bat species that live in and around the valley.
Massive clearance of irreplaceable native vegetation that cannot be adequately offset.

For all the above reasons, the proposal should not be allowed to proceed.

Our organization opposes this project on environmental grounds which include land clearing impacts on biodiverity, impacts on water, especially groundwater and impacts on claimate change through fossil fule production.

MCC must relinquish the right to mine the northern section of EL6288 surrounding the environmentally sensitive and culturally significant "sacred country" - The Drip and Corner Gorge and river corridor, Goulburn River NP. This includes withdrawing from UG4 long-wall panels 9-14. Underground mining this area risks irreparable damage to the groundwater system, cliff stability and public access to this highly valued conservation landscape.
MCC must increase the buffer zone around Moolarben and Murdering Creek and between the Munghorn Gap Nature Reserve to 400 metres, with no mine activities to occur within this zone. Management to commence immediately to encourage natural native re-vegetation with selective replanting and weed control.
The proposed new open cut areas will come unacceptably close to the Munghorn Gap Nature
The government must ensure that mines abandon rights to mine the Northern area EL6288 – an area of high significance, highly valued conservation landscape and The Drip and corner Gorge of the Goulburn River. Mines must withdraw from UG4 longwall panels 9-14.
It is evident that the danger to impacting the groundwater system and sandstone viability and public access to this place of significance and importance to the community.

41 Spenser St
Iluka 2466
14th December2022
NSW Planning Department

Re Moolarben Coal project
I object in the strongest possible terms to this project which will create 86.59 million tonnes of greenhouse gas emissions.
Having been a resident of Lismore for 16 years I am intimately aware of the extraordinary suffering of our community because of the floods in February of this year. It is incontrovertible that this flood, 2.4 metres higher than any previously recorded was in large part due to extreme weather as a result of greenhouse gas emissions causing climate change. This is not to forget for a moment the terrible impacts of record floods on the people of western NSW.
In addition to enormous human costs, including lives lost is the enormous economic cost of the floods, currently conservatively estimated at $5 billion. Then of course there is the huge environmental cost in terms of fish kills, habitat destruction and loss of species.
It is inconceivable that a government with the interests of its citizens and the environment at heart would even consider allowing a coal project of this nature to proceed.
Ironically this proposed mine is located within the NSW Government’s renewable energy zone for the Central West.
There of course will be other negative impacts of the proposed development including the depletion of the groundwater in the area, the destruction of koala habitat, and reduced future opportunities for agriculture.
Yours sincerely,
Simon Clough

The OC3 expansion will allow continued employment and industry investment in the mid-west region during the transition to a lower carbon economy.

No further expansions of thermal coal mines can be approved, the science has been telling us that for a long time now. The DPIE need to now act on this knowledge and conclude that this proposal is not in the best interest of the people of NSW.
The key concerns around green house gas emissions, damage to water courses, clearing of native vegetation, loss of habitat and social dislocation, are all areas that cannot be successfully offset, require that this proposal not be approved.
These arguments are not novel, the fact that they keep being highlighted in every submission for new expansions of thermal coal mines proves that they have never been successfully overcome. It is time for the DPIE to act and protect our environment for future generations. There is only one way to start the transition, away from thermal coal towards renewable energy generation, is to start. To start requires the refusal to approve further expansions.
Clearing of native vegetation is an example of the failure of current methods to overcome the harmful impacts created by these proposals. A 3 year old could explain why offsets cannot achieve their confected benefit. If you require the company to buy offsets to counter their destructive clearing of 624.18ha of native vegetation, the net result to the state of NSW is 624.18ha less native vegetation. The offset vegetation is currently there, the company is not going out and planting another 624.18ha
This is just one example of the nonsense DPIE have construed in order to get to yes.
It is time to stop this nonsense and find that this proposal cannot be approved.

Key points for a submission of objection:
1. Climate Change impacts:
The proposal is to produce an additional 40 million tonnes of coal and increase greenhouse gas emissions by 86.59 Mt CO2-e
2. First Nations heritage impacts:
A total of 130 first nations cultural heritage sites were identified within or overlapping the subject area including shelters with artefacts (one with possible burial), and axe grinding groove site
3. Water impacts:
• The permanent loss of potable, good quality (low salinity) groundwater from springs that provide fresh flows to creeks and the Goulburn River
• A predicted loss of baseflows to the Goulburn River between 180 – 225 million litres /year and 600 million litres in wet years. This will impact on river health and downstream water users, including Goulburn River National Park.
• A 200m buffer zone to Moolarben and Murdering Creeks (aimed at protecting them from mining) includes mine haul roads and other infrastructure impacting crucial riparian vegetation.
4. Biodiversity impacts:
• The extended mining operations will come within 100m of the Munghorn Gap Nature Reserve threatening important conservation values especially native bird and Koala habitat.
• Noise, dust and lights from the 24 hour operations will disrupt the many identified threatened and endangered birds, mammals and bat species that live in and around the valley.
• The project would result in the clearing of 624.18 ha native vegetation including
477.75 ha of Box-Gum Woodland Critically Endangered Ecological Communities. This is irreplaceable and cannot be adequately offset.
• Ecosystem habitat loss for 22 threatened fauna species including: Regent Honeyeater (Anthochaera phrygia), Koala (Phascolarctos cinereus), Squirrel Glider (Petaurus norfolcensis), Large-eared Pied Bat (Chalinolobus dwyeri)
5. Agricultural impacts:
Loss of food production potential on large areas of prime agricultural land that previously supported many farming families. This land should be assessed as Biophysical Strategic Agricultural Land (BSAL) and assessed through the Gateway process.

I object to the Moolarben OC3 Extension Project because the cumulative impact on the Goulburn River, biodiversity, Aboriginal cultural heritage and community has not been adequately assessed.
I am a downstream landholder on the Goulburn River and have been impacted by the large water releases from the Moolarben Mine combined with those from the Ulan and Wilpinjong Mines.
The recent exemption to the Moolarben EPL allowing discharge of 65 ML/d of untreated mine water until 31 December 2022 with 20 ML/d treated water combined with the 71 ML/d exempt untreated mine water release from Wilpinjong Mine during October and November, plus the 30 ML/d regular release of treated water from Ulan Mine is a significant volume of additional flow in the Goulburn River.
I am a member of the Moolarben Community Consultation Committee. There was no consultation with the community over the application for an exemption to the EPL. This impact on the environment and community is a demonstration that Moolarben Mine predictive water modelling is not capable of allowing for extreme wet weather events. The water holding capacity on the mine site is not adequate for increasing climate change driven extreme weather events.
I am also a member of the Central West Orana Renewable Energy Zone Community Reference Group and note that Moolarben Mine falls within the boundary of the REZ. It is counterproductive for the NSW Government to continue approving increased coal extraction while pushing forward on establishing large-scale renewable energy projects.
There are major issues in the region with labour and accommodation shortages. The justification of providing more work at Moolarben Mine is not rational if the region is to transition into other more sustainable industries.
The social, environmental and economic impacts of climate change are already being experienced by communities across NSW. These costs have not been included in the assessment of the proposed Moolarben OC3 Extension Project.
The further release of greenhouse gas emissions is dangerous. The Project must be rejected.

Allow me to express my concerns at the prospect of the Yancoal mining extension in the Goulburn River area. A project such as this, where explosives are frequently used, generally have unintended consequences. This is an important relatively pristine area close to an important river system. As such the potential for the contamination to the Goulburn River system is very real. Further the Goulburn River is a major catchment for the Hunter River therefore downstream consequences are likely.

I note that this project has been declared a project of State Significance. It seems to me that many projects of “State Significance” for example this one and the number in the Snowy Mountains are only significant due to the amount of exploiting areas of NSW rather than improving them. In this instance, among several natural areas, is the potential for the destruction of an important Aboriginal site that is also a major local tourist icon in the area . The risk to The Drip” is very real because of its fragile nature.

For many years my wife and I, usually in April, holiday in this area with 2 of our grandsons at the “Stone Cottages on the Goulburn River near Ulan and close to the Drip. The reason we holiday there is because of the pristine nature of the river and its precious surroundings including pleasant walking along the river to The Drip. I am fully aware of the massive destruction to the landscape in the Ulan area and along the Bylong Road. This project will only increase that destruction. At the end of mining, the miners will leave and go home and NSW (Australia) will be left with the carnage in the area that will take centuries to recover.

This project would be worrying enough if the company involved was an Australian one. Yancoal is a Chinese company whose sole intent is to exploit the Australian countryside purely for the benefit of Chinese citizens with no serious consequences involved for them and only a dubious benefit to Australia. Further there is little benefit to the Australian taxpayer for this as Yancoal, in my opinion, either does not pay tax or as I understand, “pay tax” under current cosmetic tax arrangements under one provision of the Tax Act and have the amount refunded under a different provision. Even more concerning is in the event of destruction of the Drip as a result of explosive activity Yancoal would suffer no consequences as restitution would be impossible.

Finally, I remain disgusted at the obvious hypocrisy and contradiction here (and other such coal projects around Australia) with Government (State and Federal) policy regarding “climate change” over projects such as this and similar. On one hand Australia is apparently phasing out the use of coal in Australia so that we can pat ourselves on the back over reducing our carbon impact. Then, on the other hand, we are exporting millions of tons of coal overseas allowing other Countries to burn the stuff and massively undo what little good our country does. To me, a clear example of what “Projects of State Significance” mean regarding “climate change”.

The proposed extension OC3 will cause climate change effects increasing greenhouse gas emissions by 86 59 Mt CO2-e.
There will also be First Nations heritage impacts with over 100 cultural sites identified in the proposed extension area.
Impacts on ground and surface water.
Base flows to the Goulburn River will be lost with an estimated loss of 180-200 million litres per year. This further causes issues to river health and water users downstream from the mine site.
Impacts on local flora and fauna.
The proposed extension will come within 100 meters of Munghorn Gap Nature Reserve with the noise,dust and lights from 24 hr operations causing disruption to species of mammals and birds that live near the proposed extension area.
I voice my objection to this proposal OC3

This development is sited next to a critical wildlife reserve at Munghorn Gap. This development will hinder the movement of wildlife especially birds, as the area for movement will be an open cut pit. The dust will affect the reserve. The noise will devalue the reserve to visitors. And when they blast this Will seriously affect wildlife and bird life in the vicinity. It is totally irresponsible to approve this mine on environmental grounds.
Secondly, the world is supposed to be heading to a zero emissions future with no new coal and gas. This is in obvious contravention to global interests and the global position to approve no new mines. This is totally unwarranted and is a case first of greed over need, and secondly totally irresponsible mining activity with global environmental consequences.
I totally oppose this development in every way, and it is a total travesty that such a proposal has even made it this far. It is greed and madness. Not planning for the well-being and sustainability of the future

The Munghorn Gap Nature Reserve and surrounding areas are special places that deserve to be protected . It is a place for the local community as well as the tourists to visit. Its proximity to Mudgee and other areas makes it accessible for everyone to enjoy. Extending a mine to encroach further on the area impacts on the experience of all who visit. Further to this there are real negative impacts not only to people through their connection with this land; though also to native animals - many of them threatened species. There is a negative impact to to the biodiversity of the area from the clearing of land with particular concern regarding the box gum woodland. There will also be a negative impact to First Nations heritage sites.
It is for these reasons that I strongly object to this project proceeding.

This project already covers a very large area and has had a substantial impact on the local environment, flora and fauna and agricultural pursuits. Any extension of this project should be refused, or at the very least, examined closely by having the project subjected to further investigation . The following detrimental effects need to be carefully scrutinized by government as this is a long term project. There will be:
* substantial increased emissions
* loss of baseflows impacting river health and downstream water users including Goulburn River National Park
* only 100m from Munghorn Gap Nature Reserve - disturbance to native bird and koala habitat with 24-hour operations. Athletic and swimming races of 100m are a very short distance as a comparison
* Ecosystem habitat loss for Regent Honey Easter (endangered), Koala, Squirrel Glider and large eared Pied Bat
* 130 First Nation Cultural Heritage sites affected

I strongly object to the Moolarben Coalmine Extension to Open Cut 3.

This extension project will result in irreparable damage to the biodiversity of this area with over 600 hectares of native vegetation to be cleared as part of this project including over 400 hectares of Box Gum Woodland Critically Endangered Ecological Communities.

The extension project will result in ecosystem habitat loss as well as the loss of agricultural land. Losing quality food production land to open cut coal mining is a difficult choice to fathom and witness.

The project will also have a catastrophic impact on groundwater from springs that provide fresh flows to the Goulburn River and a number of creeks in this area.

Our use of and dependence on coal is largely a choice, our dependence on food and water is not.

It is time to stop expanding coal mines in Australia.
This project will damage the environment by increasing greenhouse gas emissions.
Water losses from the Goulburn River system will be significant.
We need agriculture to continue to provide food for the nation, stop destroying farm land.
Reject this application for expansion.