Moolarben Stage 1 MOD 15 - UG4 Ancillary Works

What do we the citizens of Australia have to do to convince the current government that the burning of coal is destroying the world's climate?
I object totally to this project.

The continual expansion of the Moolarben mine poses an unacceptable risk to the future of "The Drip". There have been guarantees given that mining activity in the area must have nil impact on this significant and much valued site. The dewatering bores proposed in such close proximity to The Drip must not be approved. The ground water drawdown they would cause has been shown in new modelling to be greater than previously assessed. This is not "nil impact". Other reasons for objection are : Surface area disturbance in biodiversity offset area; Surface disturbance to Bora Creek, and the Goulburn River; Disturbance to Aboriginal cultural heritage. The contribution of continued mining expansion to the threat to the future of the Planet, as recognised by the Rocky Hill judgement, and the rejection of the Bylong mine proposal must also be considered . This modification must not be approved.

I object to this proposal to drill the three dewatering boreholes 250 m from the Goulburn River at a total of 4 sites across Underground No 4 Mine (UG4). This borefield and associated longwall mining would significantly lower groundwater levels for kilometres around, thus permanently altering the groundwater system and potentially the water supply to the highly important natural feature of The Drip opposite.
These impacts are totally unacceptable, given that Moolarben's own modelling has shown current greater drawdown of groundwater than previously assessed. Hence the real impact would need to be fully assessed before Mod 15 can even be considered. The Drip is a rare and irreplaceable feature and must not be placed under further threat, and this proposal does not allow for adequate monitoring or managing for 'nil impact' on The Drip, which is the only outcome acceptable.
That there would be surface disturbance in the biodiversity offset area is not acceptable either, as that is the opposite of the intention of an offset area.
And it is unconscionable to allow the disturbance of significant Aboriginal cultural heritage by this proposal.
The Goulburn River is already substantially impacted by this mine, so the surface disturbance on Bora Creek will increase the threats to it, which should not be permitted.
Hence for the above very good reasons this modification should be rejected.

As I understand from the application, Moolarben Coal mine Complex (MCC) is seeking approval to drill a cluster of 3 dewatering boreholes (nominal diameter ~700mm) opposite The Drip, 250 m from the Goulburn River; at a total of 4 sites across Underground No 4 Mine (UG4). This borefield and associated longwall mining will significantly lower groundwater levels for many kilometres permanently altering the groundwater system and potentially the water supply to The Drip.
Firstly, dewatering the bore opposite The Drip is not acceptable. This is a magnificent piece of environmental heritage and will clearly be destroyed.
Secondly, new modelling for Moolarben has identified greater drawdown of groundwater than previously assessed. This needs to be fully assessed before Mod 15 can be considered. The conditions in Moolarben's submission do not adequately monitor or manage for 'nil impact' on The Drip.
Furthermore, surface disturbance in biodiversity offset area is not acceptable. Why are biodiversity offsets made if they are going to be ruined?
In the midst of the worst drought in living memory, surface disturbance on Bora Creek will increase threats to Goulburn River which is unacceptable and downright dangerous for all the human businesses, let alone flora and fauna ecosystems that depend on the water.
Finally, disturbance of significant Aboriginal cultural heritage is not acceptable.
I sincerely hope you reject this proposal which is only going to be ruinous to the environment and ultimately the future of our state.

1. De-watering bore opposite The Drip is not acceptable
2. New modelling for Moolarben has identified greater draw-down of groundwater than previously assessed. This needs to be fully assessed before Mod 15 can be considered.
3. Conditions do not adequately monitor or manage for 'nil impact' on The Drip
4. Surface disturbance in biodiversity offset area is not acceptable
5. Surface disturbance on Bora Creek will increase threats to Goulburn River
6. Disturbance of significant Aboriginal cultural heritage site is not acceptable

As a visitor to the The Drip for forty years, I believe that this significant Aboriginal cultural site and now National Park attraction deserves more protection from coal mining than the current Moolarben Coal Modification affords . The proposed bores opposite and in close proximity to The Drip have the potential to depressurise and draw down groundwater for many kilometers.
Also, the effect of surface disturbance in the biodiversity offset area, on Bora Creek and of the significant Aboriginal cultural heritage is not acceptable.
I believe, as the Conditions do not adequately monitor or manage for 'nil impact' on The Drip, this Modification shouldn't proceed.

1. De-watering bore opposite The Drip is not acceptable

2. New modelling for Moolarben has identified greater draw-down of groundwater than previously assessed. This needs to be fully assessed before Mod 15 can be considered.

3. Conditions do not adequately monitor or manage for 'nil impact' on The Drip

Additional points

4. Surface disturbance in biodiversity offset area is not acceptable

5. Surface disturbance on Bora Creek will increase threats to Goulburn River

6. Disturbance of significant Aboriginal cultural heritage site is not acceptable

Having a dewatering bore opposite The Drip is not acceptable. New modelling for Moolarben has identified that there will be a greater drawdown of groundwater than previously assessed. This needs to be fully assessed before Mod 15 can be considered. 'Nil impact' on The Drip cannot be adequately monitored or managed by current conditions. The surface disturbance in a biodiversity offset area is not acceptable. Surface disturbance on Bora Creek will increase threats to Goulburn River and disturbance of significant Aboriginal cultural heritage is not acceptable.

The Department of Primary Industries has reviewed the proposal and has no comments.

Please see attached

Please find attached the EPA's letter commenting on Stage 1 MOD 15

attached is the Submission of Objection from Mudgee District Environment Group

As per submission on mp05_0117 in 2006, I still hold the same concerns of our fresh water bore being drained of its 450 gallons per hour contents in which my family and our animals rely upon.
Another concern is the constant 24 hour noise made by the mine especially during the night, with little or no improvement when complaints are made to the Moolarben complaints hotline.
Increased traffic with related noise as well as road safety issues.
Lack of care in maintenance of peripheral roads or even upgrading them as many miners live on these roads.

I object to the project due to the potential impact on dewatering bores as outlined below.

The location of the northern bore sites opposite The Drip, and approximately 250 m from the Goulburn River is of great concern considering the close proximity to significant natural features and the potential interception and depressurisation of the Triassic/upper Permian groundwater system. This dewatering borefield and subsidence from the long-wall mining (UG4) will significantly lower groundwater levels for many kilometres, permanently altering the groundwater system and potentially the water supply to The Drip and Goulburn River National Park.
I make the following points in summary:
1. De-watering bore opposite The Drip is not acceptable
2. New modelling for Moolarben has identified greater draw-down of groundwater than previously assessed. This needs to be fully assessed before Mod 15 can be considered.
3. Conditions do not adequately monitor or manage for 'nil impact' on The Drip
4. Surface disturbance in biodiversity offset area is not acceptable
5. Surface disturbance on Bora Creek will increase threats to Goulburn River
6. Disturbance of significant Aboriginal cultural heritage site is not acceptable

Thank you

The Drip is an amazing landform and has provided a natural recreational setting for the people of Mudgee and others in the know for generations and millennia for cultural practices of Aboriginal people. As I Science teacher I took my seniors there to do their field work, so they could know one of the best bush places I know. When we started going there, we were away from the coal mines so ravaging the upper Hunter landscape.
It is the landform, with the water, that makes this place exceptional. Interfering with the supply of water by dewatering a bore opposite The Drip sounds ludicrous i against the big picture of drought and climate change, let alone the impact and degradation of the Drip.
Off set land needs to be properly protected not used when it becomes convenient.

Letter received from Ms Burnett uploaded by Andrew Rode (Departmental officer) on their behalf.

Submission uploaded by Andrew Rode (Departmental officer) on behalf of Mid-Western Regional Council.

Please refer to my attached Submission
It is my expert opinion that outstanding uncertainties around the impacts of UG4 mine depressurisation on Triassic/Upper Permian aquifers; potential interaction with the Goulburn River, degradation of a valuable groundwater resource and interference to The Drip groundwater supply must be considered before the impact of these dewatering bores (MOD 15) can be confidently assessed. A comprehensive groundwater assessment and review of monitoring data is needed by an independent scientific organisation to inform this approval application. The proposed construction of the dewatering borefield from 2023 allows a reasonable period for this to be completed. Failure to fully assess these impacts and act on the outcomes could result in a potentially permanent and devastating degradation of the groundwater system and dependent ecosystems along the Goulburn River with the long term costs being borne by future generations breaching NSW Protection of the Environment Act ESD –intergenerational equity and the precautionary principle.

See attached pdf Submission – Moolarben Coal Stage 1 Mod 15

I was raised on the Goulburn River, while I now work in Sydney this landscape that includes the Drip and Corner gorges is an important part of my life that I and my friends regularly enjoy and highly value. One day I hope to return to my family property and take over the eco-tourism business we run there, with expansion in mind; but I am concerned the economy of the area is under threat from rampant coal mining at the expense of all other business and economic activity. Will we still have a healthy and viable Goulburn River fed by an irreplaceable groundwater system in 30 years?

The Moolarben Coal MOD 15 is planning to drill a cluster of 3 dewatering boreholes opposite The Drip at another 3 sites across the Underground No 4 Mine. The location of the dewatering borefield - opposite The Drip, and approximately 250 m from the Goulburn River forms an unacceptable risk affecting potentially irreversible damage to these significant natural features.

The depressurisation and dewatering of the groundwater system by underground mining so close to the Goulburn River will significantly lower groundwater levels for many kilometres permanently altering the groundwater system and potentially the water supply to The Drip and Goulburn River National Park.

In summary I object to MOD 15 on the following grounds

1. De-watering bore opposite The Drip is not acceptable

2. New modelling for Moolarben has identified greater draw-down of groundwater than previously assessed. There must be an independent and comprehensive groundwater assessment on the impacts of UG4 before Mod 15 can be considered.

3. Moolarben mine is not adequately monitoring or managing for 'nil impact' on The Drip

4. The underground mine (UG4) project breaches NSW Protection of the Environment Act ESD –intergenerational equity and the precautionary principle as irreversible damage will not be avoided if this project proceeds.
5. The contribution this modification will make to climate change, and the detrimental economic effects this will have on our society and community.

Thank you
Adair Imrie