Rocky Hill Coal Mine

SUBMISSION ON EIS FOR ROCKY HILL COAL PROJECT

DEVELOPMENT APPLICATION NUMBER SSD-5156

BY

JEFFREY KITE



1248 Thunderbolts Way
Bowman (Gloucester) NSW 2422
[email protected]


1. THIS SUBMISSION

I'm a retired water resources engineer, a member of Groundswell Gloucester and president of the Gloucester Environment Group. However, this is my personal submission. As my background is in groundwater, I have gone into some detail in that area.

2. INTRODUCTION & CONTEXT

I strongly object to the Rocky Hill Coal Project (RHCP). I live with my wife in the Gloucester Shire. Our 4 hectare property is about 10km north-west of Gloucester, so we are not directly affected by current developments and plans to the south of Gloucester. However, we chose the Gloucester area for our retirement as the minute we drove into the town, having also looked in the south coast, the southern highlands and the Hunter valley, it felt right. After talking to people who were living in Gloucester and looking at more information about the town, it felt even better. Now having lived here for 10 years, our hunch was right and we love living in this beautiful place. Gloucester has what has been called "a sense of place".

Why does Gloucester have a sense of place? Largely because of its location and beauty. It's in a narrow valley between two magnificent small ranges, the Bucketts and Mograni. It has four significant rivers which confluence closeby then flow into the Manning River. These rivers all have their sources and flow from the Barrington Tops World Heritage Area and surrounding forests. Much of the cleared land surrounding Gloucester is beautiful grazing country that is green most of the year and at its greenest in summer. The drive to Gloucester from any direction is beautiful, with the main road from the Pacific Highway largely following a valley with parallel hills which join up to the Bucketts and Mograni ranges. It passes through beautiful towns and villages with Stroud being the most beautiful.

The beauty of the Gloucester Vale and its sense of place has been recognised the National Trust.

So why under any circumstances would anybody want to put Rocky Hill coal mine so close to town and in a prime visual position on the edge of the valley?

It just does not make any sense.

This mine is far too close to Gloucester and in the wrong landscape.

3. ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

The Environmental Impact Assessment (EIA) in Part 4 of the Environmental Planning and Assessment Act is applied by the Department of Planning and Environment in a very selective way. It only considers the proposal for the RHCP that is in the current Environmental Impact Statement (EIS). As such it should only form part of the Government's decision making process.

It is clear that contrary to what Gloucester Resources Limited (GRL) has said, this should only be considered as `Stage 1'. GRL has mostly been careful not to talk about future stages. (Although it is noted that there is at least one place in the EIS where it is stated "if the mine life is extended....".) This is very deceptive. GRL has given back to the Government part of their original exploration licences, to the north-west, no doubt because this section does not contain a significant coal resource.

However, GRL has kept the licence areas directly to the north and west of the current proposal. Geological mapping clearly shows that some of the same coal seams to be mined as part of the current development (call it Stage 1) are also in these areas. The Department of Planning and Environment (DP&E) has acknowledged that it is almost certain GRL will apply for mines in one or both of these areas if Stage 1 is approved. To get their `foot in the door', GRL chose Stage 1 as it is a little further from town and will have a little less environmental, social and health impacts.

Nevertheless, I believe that the impacts of Stage 1 are totally unacceptable. But the impacts of future stages will be far worse for Gloucester. It is a nonsense and wrong that the EIA process only considers Stage 1. Even though the need to consider cumulative impacts is in the Director-General's requirements, DP&E only requires GRL to address this for the Yancoal mines, i.e. Stratford and Duralie further south in the valley. GRL is not required to look at the likely cumulative impacts for future stages of the Rocky Hill Mine.

If the Government approves Stage 1 without considering the likely impact of future stages, it is clearly complicit in accepting this nonsense of a process.

Although GRL would say that they have no plans for the future stages that can be assessed at this point in time, it is almost certain that they have some initial or notional plans. At least for the flawed AGL Gas Proposal, it was clearly acknowledged that there were in the order of another 220 wells being considered for future stages on top of the 110 wells for Stage 1.

In the case of noise, air quality and groundwater and surface water resources, extension of the mine to these areas would mean that the impacts will be even worse than for the current development due to the location of the likely economic coal seams close to town and the route of the Avon River and associated alluviums.


4. NOISE AND AIR QUALITY

Two fundamental issues for the RHCP are noise and air quality. The EPA's submission on this project is telling. It states:

"However the EPA highlights in relation to noise that:
* DP&E needs to consider in its assessment of this application that if approved many residents and visitors to Gloucester will experience a changed noise environment (hearing mining noise for the first time).
* The Gloucester Valley experiences weather conditions like temperature inversions and southerly breezes reasonable regularly. Those conditions will increase noise from the mine, if approved, within Gloucester and its southern rural-residential estates.
* To achieve the noise contours predicted and shown in the EIS multiple layers of controls will be necessary. The required controls may not be practical to implement, due to the frequency of noise enhancing weather conditions like inversions and southerly breezes.
* Based on the frequency of temperature inversions in the Gloucester Valley, the modelling may have under-predicted noise levels from the mine at residential sensitive receivers.
This means that noise impacts from the mine, if approved, may be greater than suggested by the EIS."

This is a very alarming assessment. I also understand that no matter what the standards might say and how they might be met by the proponent, a very large number of people will have mine noise in the background whenever the mine is operating. This is totally unacceptable and should be enough to reject the project without even considering other issues.

The EPA goes on to say:

"In relation to air, the EPA is concerned about the omission of information in the EIS and specialist studies regarding potential air quality impacts from blast fume. The EIS should have highlighted the importance of ensuring blasting does not occur in the stable atmospheric conditions experienced in the Gloucester Valley in the morning and evening so as to avoid exceedance of air quality criteria."

This has recently been a huge problem for the people of Broke which is near the Warkworth Mine. The impact of blasting is a critical issue and it has not been properly addressed by GRL

The EPA goes on to say that " potential effects from spontaneous combustion, should it occur, is an important consideration for DP&E when considering this development application."

Spontaneous combustion has already been a major problem for the Stratford Mine and a huge issue for a brown coalmine in the Gippsland.

There is no threshold below which particle pollution exposure is not harmful to health according to the World Health Organisation. Gloucester is `perfectly' located relative to the mine for this to be another critical issue.

5. WATER

The EPA then go on to talk about water stating:

"Further information is needed in the following areas: preventing seepage from salty minewater storages; better characterisation of `dirty' (sediment laden) water; clear information on the unit operations that are proposed in the water treatment plant; details of how/where brine will be managed/disposed; an assessment of the ephemeral watercourse that is proposed to receive discharges from the water treatment plant; discussion as to whether the treated water needs to be "conditioned" prior to reuse or discharge; better exploration as to whether the proposed reuse of some saline water onsite is appropriate or not, and an appropriate assessment of discharge limits for the water treatment plant."

It is clear that EPA consider that the EIS is totally inadequate in providing what should be considered essential information by the proponent in relation to water as well as noise and air quality discussed above.

6. GROUNDWATER

Groundwater is an area that I have some expertise in due to my 25 years of working with water utility and water resource management Government Agencies in Western Australia. So I will make some detailed comments with respect to this issue.

Groundwater is addressed in Section 4.6 of the main EIS document. The details of the Groundwater Assessment for Rocky Hill by Australasian Groundwater and Environment Consultants (AGE) are located in Volume 3, Part 4 of the Compendium.

6.1 Analysis of the issue

The environmental impacts of the Rocky Hill Mine Coal Project (RHCP) on groundwater and groundwater related issues are of major concern. `The Environmental Impact Statement (EIS) states that the impacts of developing this mine on groundwater related issues will effectively be negligible. To illustrate this, the Groundwater section of the Executive Summary states that the groundwater assessment "concluded that:
* there would not be any substantial reduction to the shallow groundwater system;
* there would be no impacts to any groundwater dependent ecosystem;
* there would be no measurable impact on flows within Waukivory Creek or the Avon River; and
* groundwater levels would recover within approximately 10 years after the cessation of coal extraction."

The Executive Summary also:
* acknowledges that with respect to aquatic ecology, "....the Avon River system as a whole is significant..." and
* makes "commitments to protecting water quality within Waukivory Creek and the Avon River" and "would ensure the existing aquatic ecology would not be adversely impacted...."

However, there are significant problems with the EIS that cast doubt on these categorical statements. Some of the assumptions made in relation to water resources generally and in particular, the groundwater model that many of these statements are based on, are highly questionable. For instance the groundwater analysis is based on average rainfall over a short period. The critical time for groundwater systems and associated base flows, is during drought conditions and particularly a series of drought years and these have not been properly considered in the EIS. More details are provided in the section on and below.

6.2 Concerns/problems/issues

The EIS identifies a number of risks that could result from the proposed mine in section 4.6.1.and. These risks and ratings identified by the consultants are as follows:
* Reduction in baseflow in the Avon River and Waukivory Creek (rated as medium risk);
* Discharge of poor quality groundwater from the post closure landform (low);
* Reduced water quantities within groundwater systems irrespective of saline quality (high)
* Impact on groundwater (alluvial) biota (low);
* Reduced water quality in groundwater systems (low);
* Noticeable reduction in base flow regimes in the Avon River and Waukivory Creek, with impacts on downstream aquatic ecology and other users (low).

Continuing GRL's theme of no or negligible impacts, most of these risks have been assessed as low. However, perhaps the most important risk, has been set at medium. This is the risk of "Reduction in baseflow.......", which must then, even by GRL's standards, be considered as potentially a very significant impact. This is discussed further below.

Interestingly, the second risk of "Discharge of poor quality groundwater from the post closure landform" is rated in the Amended EIS as low whereas it was rated as medium in the original EIS. To add to this, GRL has included as a high risk something that was not listed at all in the original EIS i.e. "Reduced water quantities within groundwater systems irrespective of saline quality".

It is not at all clear why GRL has done this but it would seem that one factor may be that they are trying to play down the stated risk of discharging poor quality water into the Avon River and Waukivory Creek. GRL should also have very specifically addressed this high risk issue as to what the likely impacts will be.

Section 4.6.4 identifies related "potential environmental impacts". The issues associated with the proponent's identified risks above and the stated potential environmental impacts, together with other issues not specifically listed by the proponent, are addressed below.

6.3 Complex Hydrogeology & Groundwater Modelling

The Mine Area is in a part of the valley where the geology is extremely complex, and therefore the hydrogeology, is also complex As such, accurately modelling of groundwater flow and drawdown at an acceptable scale is extremely difficult.

The modelling package used by AGE can couple groundwater flow with surface water flow. This was touted as a major strength of the package by the consultants. However in section 11.5 (Part 4), it is stated that "the groundwater model should not be used to assess the flow reductions to the surface water system." This is likely to be due to the over simplifications assumed in the model design which are necessary because of the highly complex hydrogeology. However, the assessment of the interaction of groundwater drawdown on surface water base flows is one of the fundamentally important concerns in assessing environmental impacts.

Section 10.4.3 on Transient Calibration of the model states that "The hydrographs show what is considered a good match, and whilst the absolute values of the predicted model do not match, they are all less that 3m different to the observed values, and more often less that 1m different." In GRL's previous response to submissions, it was basically stated that this is accurate enough for this kind of modelling and this was supported by the peer review. This is still challenged as not being sufficiently accurate for the situation where we are looking at impacts on groundwater levels in the alluvium and also in base flows and river pools.

To further illustrate this, the difference between a river having a surface base flow compared to the water table one to three metres below the riverbed is huge when it comes to the protection of aquatic systems and critical riparian trees. You cannot possibly model the impact of groundwater abstraction and pit drainage quantities on water level trigger points using such a coarse level of accuracy.

In Section 4.6.5, the document states that "It is considered that the predicted inflows to the mine, and water to be managed within the pit, is likely to reduce by up to 20% after taking these factors into account. This factor has been incorporated into the overall water balance model." The comment is mainly related to assumed reductions in water quantities through evaporation due to the geometry of the coal seams. To apply such as very large reduction factor on the water quantity to be managed in the pit, based on such limited evidence is remarkable.

The modelling uses historical rainfall to calibrate its steady state condition. However for transient calibration, it only used the period 2011 to February 2016. This is a very short period for such a calibration. As stated above, the critical time for groundwater systems is during extreme drought conditions and especially during a series of drought years. The EIS does not address periods of extreme drought by using the longer historical rainfall records available for Gloucester or simulating a series of years of very low rainfall. This is not acceptable.

To add to this, there is evidence of the Avon River having no flow or minimal flow for extended periods. This has been acknowledged by a consultant who worked on the AGL project, (Dr Richard Evans in Gloucester Water Study Project - Independent Peer Review, May 2014) that it would appear that the calibration of the DPI (Water) main gauging station on the Avon River may not be accurate during low flows and that it shows continuing flow when in fact there may be no flow or very minimal flow. This is likely to have significant implications for the calibration of AGE's model.

As well GRL's groundwater investigations are mostly based on 15 monitoring bores which were drilled in 2011 and appear to have been monitored on approximately a monthly basis. The deepest bore is only 97 metres deep and only 4 bores are actually screened in coal seams. But the main pit will be up to 220m deep. Two bores are screened in the Avon seam, with only one bore each in the Weismantel and Cloverdale seams. AGE might consider that the data collected is as they say "adequate and suitable", however this is a very small dataset to be used for such critical coal mine. Some of AGL's data was used but with the extremely complex geology, it is questionable whether this data is representative.

As indicated above, in Groundswell Gloucester's opinion many of the assumptions made by AGE in relation to the groundwater model and associated investigations are highly questionable and should not be accepted by Government as a suitable basis for approving this mine.


6.4 Water Table Drawdown and impact on river users

The modelling for this project predicts very small drawdowns except immediately adjacent to the pits. The EIS also states that the impacts on the alluvium will be minimal. This is difficult to understand when the alluvial soils actually intersects the open-cut in at least at two places. Why hasn't this fact been acknowledged by GRL. Note that DPI (Water) states in their submission that there should be detailed monitoring "within the area of the intersection of the main pit and the alluvium." The whole western and southern sides of the open-cut are relatively close to the alluvium. No concrete grout curtains or similar are proposed to mitigate impacts on the alluviums, which are directly connected to the Avon River and Waukivory Creek.

It is acknowledged in the EIS that there will be impacts on the flow in the watercourses that will increase the number of days that irrigators are unable to pump. The likely increase in cease to flow conditions is from 13.9% to 16.8% of the time. According to DPI's (Water) submission, the proponent has not done sufficient analysis of the possible impacts on water users, that is, both for licensed use and basic landholder right users.

We note that DPI's submission also states that "The proponent has not sufficiently demonstrated ability to obtain sufficient groundwater entitlement to account for a maximum take of 1100ML/yr." and "The EIS discusses the proponents ability to account for an average loss of alluvium of 100ML/yr but the licensing strategy should be based around the proponents ability to account for its maximum take, which is predicted to be 193ML/yr."

GRL want to convert their surface water licences to groundwater licences to provide water for the operation of the mine. DPI have stated that GRL will "be required to undertake a dealing to convert sufficient entitlement from its currently held unregulated river licences to aquifer category.....". GRL has stated that it will negotiate with Yancoal and AGL to do this. This is clearly not necessarily a `done deal' as GRL seem to indicate in the EIS.

Again, the EIS prepared by GRL is completely inadequate with respect to water licensing and should be rejected. At very least GRL must be required to clear all these matters before the Government makes any determination on this project and should not just be told to deal with it after any approval through a "Water Management Plan" as GRL suggest.


6.5 Reduction in baseflow in the Avon River and Waukivory Creek

The water table drawdown will also cause a reduction in baseflows in the waterways as it is discharge from the alluviums and other aquifers that provides this baseflow when the streamflow is very low. It has been said that there are no free lunches when it comes to removing water from natural water systems ie all abstractions will have some impact downstream. It is very difficult to accept that, given the large quantity of groundwater to be abstracted by GRL and the reductions in the catchment areas for Waukivory Creek and the Avon River, that the reduction in baseflow will be negligible as claimed.

With respect to protecting riverine ecosystems, the worst conditions are similar to what was experienced in late 2013 when the previous EIS was on exhibition. The Avon River stopped flowing and the river was just a series of shallow pools. It can be expected that with climate change and the climatic extremes we are already experiencing, this situation will occur much more often. This is supported in MidCoast Council's submission. These pools and dependent vegetation provide critical habitat to fauna species which are likely to include the platypus. Any reduction in surface and/or groundwater flow at these times will be critical for riverine ecosystems but this is not acknowledged in the EIS and no mitigation is proposed.

6.6 Impact on groundwater dependent ecosystems

The original EIS stated a number of times that the riverine vegetation consists mainly of "River Oak, Cabbage Gum and Broad-leaved Apple. River Oaks are understood to be similar to River Red Gums and these species are likely to rely on groundwater from underlying formations." This is a highly significant comment that does not appear to be repeated in the amended EIS. It appears that GRL is purposely trying to play down this issue.

Riparian River Oak communities play very important roles in all riverine systems where they occur. They provide key habitat in rivers where riverine vegetation has already been impacted by clearing. They also greatly assist with bank stability. Any deaths of the River Oaks as a result of low groundwater levels and reduced flows recharging the alluviums, could have a devastating impact on stream stability and the riverine ecosystems.

These potential impacts on riverine and groundwater dependent ecosystems, and in particular the impact on riparian River Oak communities needs to be considered as a high risk issue that has not been addressed by GRL.

6.7 Inflow of coal seam water into pits and water quality.

It needs to be recognised that coal seam water is the same as `produced water' which is a major problem for coal seam gas abstraction and was a critical issue for the failed AGL proposal. This water is collected in open `wells' at the bottom of the pits and pumped into storages for use in reducing dust, for treatment for irrigation or for river release after the 4th year.

As identified by the NSW Chief Scientist and Engineer in her review dated July 2013, coal seam water is likely to include;
* Dissolved Solids, particularly sodium chloride and sodium bicarbonate
* Oil and grease
* Organic and inorganic chemicals including trace elements of metals including including heavy metals, organic acids and polyaromatic hydrocarbons
* Semi-volatile organic chemical collectively known as BTEX and
* Naturally occurring low levels of radioisotopes such as radium, thorium and uranium.

Like AGL, GRL is proposing to treat their saline water using reverse osmosis to remove the salt. Even with pre-treatment, it is very difficult to ensure that removal of heavy metals, hydrocarbons, BTEX and other contaminants. Testing of coal seams by AGL confirm the presence of all these chemicals.

GRL do not appear to have done any detailed chemical analysis of the coal seams to check for the presence of many of the toxic chemicals. In fact, testing of GRL's monitoring bores have only checked for the normal physio/chemical constituents including a few metals/heavy metals. Even for this suite of chemicals, their deepest monitoring bore is only 97 metres deep whereas GRL plan to mine to a depth of 220 metres. The only sites where they have tested for a wider range of potentially toxic chemicals are at surface water sites. These chemicals should have been tested for in the monitoring bores.

Clearly, this is totally unacceptable. It is this water chemistry that GRL have used to describe typical water qualities for their `saline water' including the raw water which will go to their treatment plant.

GRL is promoting the benefit of the coking coal because it has a high fluidity. This means that it is far more volatile. However, it also means that it has higher levels of some toxic chemicals associated with hydrocarbons including BTEX.


6.8 Treatment and Management of `Saline Water' and Waste Products

GRL are hoping to use up to 50% of its saline water for dust suppression. Presumably this would apply only to use at the minesite. MidCoast Council's submission indicates that the water requirement for dust suppression may in fact be much greater. This effectively disperses all the contaminants and toxic chemicals in the saline water around the minesite. If it also applies to the unsealed sections of the haul road to Stratford, it would be of even greater concern. GRL will no doubt argue that the quantities of the contaminants, except for salt, will be small. However it is up to the proponent to prove that this is the case and that there are no associated problems with spreading these contaminants around.

Then like AGL, GRL is proposing to, during the 4th year of operation, treat the rest of their saline water and use the final treated water for irrigation of pasture for dairy and beef cattle. When there is more saline water coming into the water treatment plant than can be irrigated, GRL propose to discharge the water into the Avon River and Waukivory Creek. Clearly this is totally unacceptable.

GRL is proposing to treat the saline water using reverse osmosis after pre-treatment. Little detail is provided by GRL about the pre-treatment. In their submission, the EPA raised its concerns about water management and specifically states in its covering letter (the whole paragraph is shown here for clarity):
"Further information is needed in the following areas: preventing seepage from salty minewater storages; better characterisation of `dirty' (sediment laden) water; clear information on the unit operations that are proposed in the water treatment plant; details of how/where brine will be managed/disposed; an assessment of the ephemeral watercourse that is proposed to receive discharges from the water treatment plant; discussion as to whether the treated water needs to be "conditioned" prior to reuse or discharge; better exploration as to whether the proposed reuse of some saline water onsite is appropriate or not, and an appropriate assessment of discharge limits for the water treatment plant."

Even with appropriate pre-treatment, it is still very difficult to remove some dissolved metals and other contaminants. AGL identified that sodium, magnesium, silica, manganese, iron and strontium would need to be addressed in pre-treatment design. They also identified that boron is of concern as it appears that RO membranes have had to be specifically developed for produced water to achieve a greater rejection than normal membranes.

For the disposal of the contaminated salt after RO, GRL state that it will go to an authorized waste disposal site/company. AGL never actually identified where their contaminated salt would go. It is understood that in Queensland, this waste is just being stock piled. For GRL to just blandly say it will dispose of the contaminated salt at an authorized site is again totally unacceptable.

GRL does not seem to even consider the various pre-treatment waste that will be produced and where this waste might be disposed of. When it was identified that some of the AGL waste included BTEX chemicals, AGL was not able to find a disposal site in NSW and were forced to take the `flowback' water to Queensland. The EPA must not let itself get trapped in the ridiculous situation that occurred with the AGL Gas Project, where AGL was already producing waste with no place identified for disposal.

The case to dispose of the treated saline water by irrigation of pasture has also not been adequately addressed in the EIS. Although the output from the RO plant will be low in salt, it is far from clear what trace metals and other contaminants might still be in the water. The dairy industry and beef farmers must be very cautious about allowing cattle to graze on pasture being irrigated with this water. GRL needs to address this issue to clearly prove that the final effluent is suitable for this purpose.

GRL needs to specifically address the fate of BTEX chemicals. With the level of concern identified during the AGL debacle, it is up to them is identify the levels of BTEX in various coal seams and what happens to it once it is mobilized.

Clearly, based on EPA's submission and the other issues raised above, GRL's EIS does not address many critically important water issues and should be rejected outright. Groundswell Gloucester totally agrees with concerns listed in the EPA submission.

6.9 Runoff from Irrigated Areas and Discharge of Treated Water to River

Projects such as this that are planned to make large financial gains should not have the right to just discharge potentially contaminated water into local rivers. This is particularly so when there is a major public water supply and domestic/stock riparian rights downstream of the coal mine and associated infrastructure.

In their submission on this proposal, MidCoast Water (MCW) raised a number of key issues that need to be addresses by GRL. Quoting from their submission, "Both Duralie and Stratford mines dispose of excess water through on-site agricultural irrigation...." Even though it is my understanding that this water is not actually being used for irrigation for agriculture, the point is that both mines have "no release" policies regulated through their EPA licence. GRL should be required to apply the same approach.

MidCoast Water go on to say: "The adopted strategy relies too heavily on discharges to local waterways. In addition (the) EIS makes misleading statements around discharges." Two of these misleading statements relates to GRL using the term `a closed' system for the Saline Water Zone and showing in Figure 3.1 that there will be "no discharges to the Avon River". MCW is particularly concerned about these issues because the Saline Water "is likely to have elevated salinities, dissolved metals and hydrocarbons."

Another MidCoast Water concern is that GRL has assumed an application rate for the irrigated water that was used by AGL on its Tiedman property. MCW rightly states that AGL were irrigating during an extremely dry period on heavily modified soils and that this would lead to an "underestimation of the frequency of river discharge...."

However the real point here is that large potentially polluting industrial and mining developments should not be allowed to be developed in such an important public water supply providing high quality domestic water to 75,000 plus people.

Again, the information provided in the EIS is completely inadequate.

6.10 Seepage Water from Overburden Dumps including `Amenity Barriers'

This issue has been addressed in the section on Surface Water in Groundswell Gloucester's submission. However one additional point is that GRL has not clearly stated what materials will be included in the overburden dumps. There will be very large quantities of uneconomical coal from the shallow parts of the targeted coal seams and from the many seams that are not being targeted by GRL. This is in addition to the breaker rejects.

The EIS states that this material will be managed in a similar fashion to the breaker rejects. However, in practice, whether it is possible for this material will be able to be separated out from the `clean' overburden is highly questionable.

The presence of this material in overburden dumps and amenity barriers is very likely to lead to the contaminants from coal, being mobilised and seeping into the Avon River.

6.11 Grounds for refusal related to Groundwater

* The proponent has not adequately addressed groundwater and related issues in the EIS. This proposal should be refused for the reasons outlined below based on the concerns/problems/issued raised in this section.

* The groundwater model is over simplified largely because of the great complexity of the hydrogeology which makes modelling extremely difficult. It is calibrated coarsely using minimal data. It does not provide sufficient precision to analyse the impacts on Waukivory Creek and the Avon River and their associated ecosystems. Specifically it does not address what happens to water levels during drought sequences which are the critical periods.

* The modelling outputs show very small drawdowns in watertables which is different to the modelling in Stratford Coalmine Extension EIS. This is still the case even without the AGL proposal.

* The EIS assesses the impact on the alluviums, which supply groundwater to the baseflows in the watercourses during dry and particularly drought periods, as negligible. This is even though the alluviums are close to the pits on the western and southern side and actually intersect the pits in at least two places, with no mitigation proposed.

* There is inadequate consideration of the risk of impacts of water table drawdown on groundwater dependent ecosystems and in particular, the River Oaks riverine community, which are fundamental in protecting the stability of the rivers and riverine ecosystems.

* As identified in the submission by the MidCoast Council, huge quantities of saline water will need to be used for dust suppression. This saline water will not be treated before being used for dust suppression and will therefore just spread around the contaminants of coal seam water. These contaminants include salinity, heavy metals and BTEX chemicals.

* There is extremely limited information provided about the chemistry of the coal seam water which will be the raw water for the proposed water treatment plant. There is also extremely limited information provided about the pre-treatment processes which would be fundamental to effectively using reverse osmosis to remove salt.

* There is no specific information about the companies where all the wastes from the treatment plant, which will include heavy metals, BTEX chemicals and huge quantities of contaminated salt, will be sent for final disposal.

* The plan that GRL will to dispose of the treatment plant's excess final effluent in the Avon River and Waukivory Creek is completely unacceptable. This is particularly true when you consider that a potable water supply for more than 75,000 people and riparian right water users, as well as the aquatic ecosystems.

* The EIS is completely inadequate in many sections including those related to water. This is particular clear in the EPA's submission which states:

"Further information is needed in the following areas: preventing seepage from salty minewater storages; better characterisation of `dirty' (sediment laden) water; clear information on the unit operations that are proposed in the water treatment plant; details of how/where brine will be managed/disposed; an assessment of the ephemeral watercourse that is proposed to receive discharges from the water treatment plant; discussion as to whether the treated water needs to be "conditioned" prior to reuse or discharge; better exploration as to whether the proposed reuse of some saline water onsite is appropriate or not, and an appropriate assessment of discharge limits for the water treatment plant."



6.12 Consequences of Not Approving the Project

* There will be no further threat to the potable water supply for 75,000 plus users, as well as riparian users.
* The Avon River system, which the EIS acknowledges with respect to aquatic ecology, ".... as a whole is significant..." will be protected, with opportunities for landowners to improve the stability and ecological integrity of the riverine area.
* There will be no threat to the landscape from the mine and also from the poorly considered post-mining landform.
* All GRL's land will be able to be returned to farmers for grazing of dairy and beef cattle consistent with the existing character of Gloucester.
* The tourism industry, which is critical to the economic stability and sustainable growth of Gloucester, will not be threatened.

7. SOCIAL AND ECONOMIC ISSUES

The mine is located far too close to the residential areas of Gloucester and will have major negative impacts on the town's amenity as well as on individual property values. If the mine was to go ahead:
* Surrounding rural and rural residential properties will be made unsaleable
* Long-established agricultural activities are being and will continue to be displaced
* Potential royalties to the State appear to be greatly overestimated
* The net employment increase for Gloucester residents will be small (based on other mines, significantly less than claimed) which will be outweighed by the negative effects on the community
* Noise from the mine - especially intrusive low-frequency noise - will affect large numbers of residences in and around Gloucester, especially in the Forbesdale, Avon and Thunderbolts residential estates
* Dust from the mine would have health and nuisance effects on hundreds of residents
* The scenic values that the important tourism industry depends on would be seriously degraded
* Road traffic to and from the mine would be far greater than the existing local traffic, and would put unacceptable pressure on the Shire Council's road maintenance resources.
* The mine would have impacts on threatened birds and mammals, and would be likely to result in the complete loss of the populations of squirrel gliders and grey-crowned babblers currently in the proposed mine area.

8. CUMULATIVE IMPACT

The impact when Yancoal's Stratford and Duralie Mines, together with the Rocky Hill Mine, continue with their inevitable incremental expansions, would be devastating for the Gloucester - Stroud valley and for the people who live here.

Jeffrey Kite
BE (Civil) GDip Nat Res MIEAust CPEng (Retired)

See attached submission

I strongly oppose the Rocky Hill Coal Project. Please find attached my letter opposing the Rocky Hill Coal Project.

Please find my submission attached.

I am opposed to the Rocky Hill mine. The attached document sets out my reasons

See pdf.

please se attached document

please see attached document

Submission objecting to the Rocky Hill procect is uploaded below.

See attached

Stop this madness!!

Please see letter attached.

Please find my submission opposing this project.

I oppose the Rocky Hill Coal Project. Please see attached submission and also the following link: https://www.facebook.com/plugins/video.php?href=https://www.facebook.com/ABCCapricornia/videos/1403659482980834/&show_text=0&width=560

Please delete my personal information before publication.

Director - Resource Assessments
Planning Services
Department of Planning & Environment
GPO Box 39
Sydney NSW 2001

Rocky Hill Coal Project - Application No SSD-5156
Stratford Coal Extension Project No. SSD 4966 MOD1

Dear Sir/Madam

I oppose the Rocky Hill Coal Project and the modification to the Stratford Coal Extension Project.

I am a Gloucester resident. My husband and I settled here 30 years ago, worked hard to establish a business and raised 6 children, all of whom work in industries other than coal mining. This mine is too close to our town and for ALL the obvious reasons should be opposed. We have much to offer in our beautiful environment, thriving tourism industry, dairy, beef and horticulture industries, incredible biodiversity and expanding population, all of which GRL have failed to address in their amended EIS.

Intelligent people are tired of listening to the same old rubbish that spews out of mining lobbyists, government bodies, coal companies and a handful of mindless twits in our town.

Australia is failing to address the climate action agenda and continues to fall back on an industry that is now no longer needed or welcome. Please tell GRL to pack up and go home, Gloucester is tired of division and hate in our community created by the extractive industries and the NSW government.

I have not made a reportable political donation.

Thank You

Please refer to attached submission.

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