Russell Vale Underground Expansion

I object to Wollongong Coal Ltd's Russell Vale Underground Expansion
Proposal, Revised Preferred Project.
I understand that the revised project is to use bord and pillar mining
instead of longwall mining. However, it involves mining under two
previously mined seams. Triple seam mining has little precedent, with
impacts difficult to predict, which is worrying. In the proposal it is
admitted that instability in the overlaying old Bulli seam workings
may cause pillar collapse and subsequent subsidence. It is also stated
in the proposal that large areas of the surface within the proposed
area are on the verge on moving, as a result of previous mining,
having not stabilised since the mining of longwalls 4, 5 and 6,
several years ago. So, clearly it is possible for the proposed
bord-and-pillar mining to cause further subsidence. I am worried that
with current instability and possible further subsidence, what could
be the impact too of possible increased weather events, as predicted
as we see the effects of climate change, eg possible tremors or more
serious floods, like those of 1998?
Of course, of great concern are the potential impacts of more mining
in our drinking water catchment areas. The revised project will cause
more losses of groundwater and surface water, estimated to be 298ML
per year, which is the annual equivalent of water usage of 2500
people. In addition water is draining into Russell Vale mine from the
closed Cordeau and Corrimal mines. Wollongong Coal proposes to only
manage the outflow from the accumulating water for 10 years. What
happens then?
The Russell Vale coal mine is situated in a large residential area and
therefore there are impacts on local residents. It is proposed that
coal will now be processed on site, with action to be taken to reduce
the impacts. However, as in the past conditions have not always been
honoured, I think there is reason to be concerned about this.
There will also be increased trucks constantly going to and from the
mine, through the local area. Traffic has already increased
considerably in the area and will continue to grow. The addition of
many more trucks daily will add to noise, fuel pollution and traffic
flow problems.
I am most concerned that questions have been raised about Wollongong
Coal's solvency, with an auditor saying its debts far outstrip its
assets. Wollongong Coal has declared a loss of $379 million for the
year, lodging its annual report with the Australian Securities
Exchange. Liabilities are reported to be around $1 billion. Their
auditor, UHY Haines Norton is quoted as saying, "A material
uncertainty exists that may cast significant doubt on the group's
ability to continue as a going concern and therefore, the group may be
unable to realise its assets and discharge its liabilities in the
normal course of business". Wollongong Coal says it is restructuring
its debt payment arrangements and has a loan facility from parent
company Jindal Steel and Power. (https://www.illawarramercury.com.au/story/6294659/wollongong-coal-has-a-1-billion-debt-problem-auditor/)
Questions raised by the NSW Resources Regulator in 2016 as to whether
Wollongong Coal was a `fit and proper' entity to hold a mining licence
are not yet answered.

I am also very concerned that the company has a history of
non-compliance with approval conditions, including the illegal
stockpiling of 200,000 tonnes of coal and the still outstanding
realignment of Bellambi Creek, meant to protect it from pollution and
flooding. Their failings to honour some past compliance requirements
and their current reported financial situation does little to inspire
confidence in this current project.

Climate change is now broadly accepted as a reality and that serious
action needs to be taken without further delay. We must urgently take
extreme steps to reduce our overall GHG emissions, including being
accountable for all Scope 1, 2 and 3 emissions caused by coal mining.
A sustainable future depends on it and every new coal project takes us
in the wrong direction.
Also, in NSW we are experiencing drought, we have water restrictions
in place and the desalination plant is now operating (which will only
supply around15% of Sydney's needs). How can we risk more water loss
in the catchments? We are seeing towns in NSW running out of water and
others with imminent serious issues. Once again, with climate change
being a reality, security of our water has to be a top priority. It
makes no sense to allow new coal projects in the drinking water
catchments that provide drinking water to over five million people.
Water must be acknowledged as being our most precious resource.
I oppose this proposed expansion.

I object

I object to the Wollongong Coal's Revised Preferred Project Report (PPR)
to the Russell Vale Underground Expansion Project 09-0013.

Some of the reasons for my objection are listed below.

Climate change and Greenhouse Gas (GHG) Emissions

Coal mining, whether for energy or steelmaking, produces the GHG
Emissions that are causing dangerous climate change. This project is
estimated to result in 11,624,000 tonnes of GHG emissions through the
mining and the burning of the coal.
A risk to Greater Sydney Water Catchment

The mining will take place in the Special Areas of the Greater Sydney
Water Catchment - areas that forbid public access because of their
sensitivity and strategic importance - and up to the shores of the
Cataract Reservoir.
Not only will the mining infrastructure, such as access roads and vent
shafts, disturb and damage the catchment, the proposal for Bord and
Pillar mining will result in up to 100 mm in subsidence.
The extraction for the Wonga Central Development Mains extends under
the Cataract Reservoir itself. Cataract is severely affected by
drought and is currently at only 29% of capacity. Mining should not be
permitted anywhere near Great Sydney water supply reservoirs.
Triple seam mining

The mining is particularly risky because a third seam of coal is being
mined beneath two previously mined seams. Triple seam mining has
little precedent and impacts are difficult to predict.
The proponent admits that instability in the overlaying old Bulli seam
workings may cause pillar collapse and subsequent subsidence of 1 to 2
metres. It is unacceptable of the NSW government to allow such risky
mining in the water catchment for 5 million people of Greater Sydney
in a time of drought.
The proponent is not fit and proper to hold a mining licence

Wollongong Coal and its parent company Jindal Steel and Power Ltd, are
currently the subject of an investigation by the NSW government's
Resources Regulator into whether or not they are a `fit and proper'
entity to hold a mining license. The company has a history of failing
to comply with conditions of approval. Even its auditors have
questioned its capacity to continue as a going concern; its current
liabilities exceed its current assets by nearly A$1 billion.
Wollongong Coal is not a `fit and proper' entity to operate a coal
mine in the water catchment of Australia's largest city.
Impacts on local community

The colliery site at Russell Vale is closer to dense residential areas
than any mine in Australia. Residential communities have suffered the
impacts from this mine over many years, including noise and
particulate pollution. In this day and age, Russell Vale is not a
suitable location for a colliery.
Wollongong Coal plans to build a coal processing plant at the Russell
Vale Colliery and process coal on site. The Russell Vale mine is the
closest mine to any built up residential area in Australia and is not
a suitable area for coal processing. Moreover, the proponent has been
unable or unwilling to comply with many conditions of past approvals
and the NSW government has proven to be unable or unwilling to enforce
compliance. Residents have no confidence in "conditions" or
"commitments" to operate the processing plant according to suitable
standards.
The proponent has a history of non-compliance with approval conditions

Previous applications and approvals promised numerous items to protect
the community and environment that have never been met by the
proponent. These include but are not limited to: truck loading
facilities, sound walls, covered conveyors, limited stockpiles, sealed
roadways and realignment of Bellambi Creek. Now in this new revised
project, Wollongong Coal is promising the same or similar things.
Wollongong Coal is currently operating right at this moment under
three non-compliances: the realignment of Bellambi Creek to protect it
from pollution and flooding (due Oct 2012); the removal of 200,000
tonnes of oversize coal that was illegally stockpiled on the adjoining
slag heap (due July 2019); and, the dedication of land to Council in a
1989 approval from Wollongong City Council (due 1990). All of these
obligations still have not been met.
A proponent with such a poor record of compliance should not be
considered for, let alone granted, approval to mine. The NSW
Department of Planning's inability or unwillingness to enforce
compliance (with the conditions that it itself has stipulated)
undermines confidence in the planning system.
We ask that you reject this application from Wollongong Coal and
commence a process to close the mine at Russell Vale permanently.

Thank you for considering this submission.

Yours sincerely,

I OBJECT

I object, fundamentally and completely.

As someone living in the area and directly downstream from the colliery,
I am opposed to the expansion of mining activity that impacts local
waterways and drinking water catchments. The public do not want more
coal mines. And we do not want them in our backyard. I'm sad that we
are selling out our kids' future and our local environment by
investing in outdated and environmentally destructive technology.

I am deeply concerned about the impact the expansion of the Russel Vale
mine will have on nearby water reserves and on people's health. I also
object to the mine because of its contribution to climate change.
Instead of allowing a dodgy company to make more money, the government
should be investing in a transition plan for mine workers and be
considering the health and well-being of local residents who have to
drink the water and breath the air being affected by Russell Vale
mine.

Thank you for the opportunity to make a submission to the Russell Vale
Underground Expansion Project.
I strongly oppose this project for the following reasons.
1/ Threat to Sydney & Illawarra Drinking Water
We are currently in a very serious drought & the total water in all
the dams supplying Sydney, the Illawarra plus the Blue Mtns etc, as of
today, is just 49.7% capacity. The Russell Vale mine expansion is in
the catchment of the Cataract Dam which as of today is at just 28.6%
capacity. There is no doubt in my mind that the extent of the proposal
& that it will add a 3rd level of mining under old mined out coal
seams, will escalate the loss & contamination of water from the
Special Areas of Sydney's Drinking Water catchment. The proponent
readily admits that the old Bulli seam is unstable, & the planned
extension under it is likely to cause collapse of the pillars
resulting in subsidence of 1 to 2 metres. (Russell Vale Revised
Underground Expansion Project 3687_R05 RtPAC Second Review FINAL
Revised Preferred Project Environmental Assessment, p. 62)
At a time when the population of Sydney & the surrounding areas is
rapidly expanding & our climate is trending to more droughts of
greater severity, expansion of mining that threatens the dams of the
Special Areas which supply water to the largest number of people of
any water catchment in Australia, is truly senseless. Coal mining
under the Special Areas has a proven history of subsidence that
undermines the water holding capacity of the upland swamps & drains
the waterways that feed our dams. Our NSW state government has a duty
of care to the people of NSW, & to our future generations to secure
our drinking water. Without water there is no life. Security of
drinking water now & into the future far outweighs any income the
government may earn from royalties from this mining. A previous NSW
government Chief Scientist has stated that there is nowhere else in
the world where mining is allowed in a public drinking water
catchment. It is time to apply the precautionary principle & protect
our water.
2/ Threat to our climate
The proposed coal to be extracted from this expansion has a large
carbon foot print particularly when the carbon released to the
atmosphere is taken into account when it is burnt. The responsibility
for the impact of these emissions on our climate sits squarely with
the miner & the permitting public authority, in this case the NSW
government. Approximately 50% only of the coal to be mined is for
steel making, so even the justification that steel is an essential is
a weak argument here, particularly as we progressively move towards
greener construction alternatives to steel, more recycling of steel &
cleaner manufacturing methods. All of the Russell Vale mine coal is
intended for export, but as global demand is reducing there is
potential for this project to become yet again nonviable & a risk it
will become a stranded asset. The IPCC has warned repeatedly that if
we are to keep temperature rise at 1.5c we must stop mining coal now.
All of our governments including NSW state government have a duty of
care to the people of NSW, & to our future generations to protect our
climate.
3/Local Economic Benefits
There are very little. The mine has been in Care & Maintenance mode
for some time supplying just a few jobs. When it was operating there
were a number of times it was unable to pay its workers properly. All
of the coal will be exported; none will be used for local steel
making.
4/ Is the mining company fit to operate in Australia?
Wollongong Coal have a very bad record, the company is currently under
investigation by the NSW government Resources Regulator. It has a
history of non compliance to its approval conditions, its illegal coal
slag stock pile & the length of time it took to deal with it was
particularly contentious as were the pollution incidents of Bellambi
Creek & the long time of unpaid debt to Wollongong City Council. It
has yet to prove economic viability to ASIC & is suspended on the ASX.
That its assets are outweighed by almost $1 billion liabilities
suggest that it is a very bad bet indeed & should anything go wrong at
its mine under the Sydney Drinking Water Catchment Special Areas, it
would be in a position of bankruptcy leaving the cost of remedial
works to the public purse. Naveen Jindal the chairman of its parent
company Jindal Steel & Power Ltd is facing corruption charges in
India. (http://www.newindianexpress.com/nation/2019/jul/01/delhi-court-orders-framing-of-charges-against-naveen-jindal-and-four-others-in-coal-scam-case-1997865.html)
5/ Risk to Wollongong
The Russell Vale mine is the closest of any coal mine to urban
development in Australia. At the end of Bellambi Lane it is just above
the suburban area. The miner is planning to build a coal processing
plant at this mine site, just metres from houses. Its coal trucks will
travel through intervening suburbs between the mine & Port Kembla at
an estimated rate of 32 an hour. The threat of air, water & noise
pollution is unacceptable as is the traffic congestion on already
extremely busy roads.
The people of NSW will pay a very high price should this mine
expansion go ahead. Our water & our climate need urgent protection.
Please do not approve the Russell Vale mine expansion.

I object to the Wollongong Coal's Revised Preferred Project Report (PPR)
to the Russell Vale Underground Expansion Project 09-0013.

Some of the reasons for my objection are listed below.

**Climate change and Greenhouse Gas (GHG) Emissions

Coal mining, whether for energy or steelmaking, produces the GHG
Emissions that are causing dangerous climate change. This project is
estimated to result in 11,624,000 tonnes of GHG emissions through the
mining and the burning of the coal.

**A risk to Greater Sydney Water Catchment

The mining will take place in the Special Areas of the Greater Sydney
Water Catchment - areas that forbid public access because of their
sensitivity and strategic importance - and up to the shores of the
Cataract Reservoir.

Not only will the mining infrastructure, such as access roads and vent
shafts, disturb and damage the catchment, the proposal for Bord and
Pillar mining will result in up to 100 mm in subsidence.

The extraction for the Wonga Central Development Mains extends under
the Cataract Reservoir itself. Cataract is severely affected by
drought and is currently at only 29% of capacity. Mining should not be
permitted anywhere near Great Sydney water supply reservoirs.

**Triple seam mining

The mining is particularly risky because a third seam of coal is being
mined beneath two previously mined seams. Triple seam mining has
little precedent and impacts are difficult to predict.

The proponent admits that instability in the overlaying old Bulli seam
workings may cause pillar collapse and subsequent subsidence of 1 to 2
metres. It is unacceptable of the NSW government to allow such risky
mining in the water catchment for 5 million people of Greater Sydney
in a time of drought.

**The proponent is not fit and proper to hold a mining licence

Wollongong Coal and its parent company Jindal Steel and Power Ltd, are
currently the subject of an investigation by the NSW government's
Resources Regulator into whether or not they are a `fit and proper'
entity to hold a mining license. The company has a history of failing
to comply with conditions of approval. Even its auditors have
questioned its capacity to continue as a going concern; its current
liabilities exceed its current assets by nearly A$1 billion.
Wollongong Coal is not a `fit and proper' entity to operate a coal
mine in the water catchment of Australia's largest city.

**Impacts on local community

The colliery site at Russell Vale is closer to dense residential areas
than any mine in Australia. Residential communities have suffered the
impacts from this mine over many years, including noise and
particulate pollution. In this day and age, Russell Vale is not a
suitable location for a colliery.

Wollongong Coal plans to build a coal processing plant at the Russell
Vale Colliery and process coal on site. The Russell Vale mine is the
closest mine to any built up residential area in Australia and is not
a suitable area for coal processing. Moreover, the proponent has been
unable or unwilling to comply with many conditions of past approvals
and the NSW government has proven to be unable or unwilling to enforce
compliance. Residents have no confidence in "conditions" or
"commitments" to operate the processing plant according to suitable
standards.

**The proponent has a history of non-compliance with approval
conditions

Previous applications and approvals promised numerous items to protect
the community and environment that have never been met by the
proponent. These include but are not limited to: truck loading
facilities, sound walls, covered conveyors, limited stockpiles, sealed
roadways and realignment of Bellambi Creek. Now in this new revised
project, Wollongong Coal is promising the same or similar things.

Wollongong Coal is currently operating right at this moment under
three non-compliances: the realignment of Bellambi Creek to protect it
from pollution and flooding (due Oct 2012); the removal of 200,000
tonnes of oversize coal that was illegally stockpiled on the adjoining
slag heap (due July 2019); and, the dedication of land to Council in a
1989 approval from Wollongong City Council (due 1990). All of these
obligations still have not been met.

A proponent with such a poor record of compliance should not be
considered for, let alone granted, approval to mine. The NSW
Department of Planning's inability or unwillingness to enforce
compliance (with the conditions that it itself has stipulated)
undermines confidence in the planning system.

We ask that you reject this application from Wollongong Coal and
commence a process to close the mine at Russell Vale permanently.

Thank you for considering this submission.

Yours sincerely,

The proposed workings of the mine are far too close to the Cataract Dam.
This area is full of fault planes !
This could lead to a direct hydraulic connection between the mine and
the dam.
And this would quickly flood the mine and pour down the street
flooding the residents and in particular the school at the bottom !
Dr Keith Tognetti, BE Coal Mining Engineering.

Further objections
Allowing further long-wall mining to occur under the Sydney Water
Catchment Special Area is both irresponsible and dangerous. We refer
to Illawarra Residents for Responsible Mining (IRRM). The land around
the proposed mining is unstable. It is rather ironic that the general
public risk a heavy fine if they enter the Water Catchment area yet
earth moving is permitted.
In a time of extreme drought (the Dam is at present 29% capacity) and
climate change, serious consideration must be given to loss of both
ground and surface water.
Serious damage has been done already with previous mining yet
Wollongong Coal will increase risk and damage even further with this
proposal .
The wetlands in the Catchment are seriously degraded and once damage
occurs in the wetlands it will never be restored.
According to IRRM Greenhouse Gas Emissions are considerable,
especially taking into account coal usage.
Regarding employment, if approval is granted, it would make very
little difference overall to the local economy, jobs and the flow on
affect from this reckless mining proposal.
Coal processing plant on surface at Russell Vale Colliery
It is outrageous that, on top of the other pollution from the mine,
you would be adding such a plant at the Colliery .
We remind you that Russell Vale Mine is the closest mine to any built
up residential area in Australia !
With the proponent's past irresponsible record in compliance and
standards, why should the community have any faith in the Company
complying with this proposed plan to operate a processing plant?
Truck Movements
There have been grave community concerns with coal trucking over many
years, along Bellambi Lane, Northern Distributor to Port Kembla Coal
Terminal.
The projected coal truck movements from Russell Vale six days a week
with 16 laden trucks per hour Monday to Saturday, 32 truck movements
per hour, or one truck every 112 seconds is an absurdity.
In addition, there is trucking of coal mine waste.
We ask - how will the community cope as Memorial Drive is extremely
busy now with heavy build up of traffic?
Mt. Ousley Road F6 (Wollongong's only corridor) has heavy build up of
coal trucks carrying 5 million tonnes per annum with numbers projected
to double. Car carrying vehicles will rise with the expansion of Port
Kembla Harbour. As well, there are truck movements from Bass Point
Quarry (Boral), grain and haulage of goods generally.
Trucks are subsidised by lower fuel taxation as well as fixed annual
registration.
The community picks up the cost of road safety/risks noise and air
pollution and heavy road congestion.

We ask that this outrageous application be rejected and that Russell
Vale mine site is closed.

See Attached.

I am lodging my strong oipposition to this project.
My submission is attached.

The Wollongong branch of the Australian Youth Climate Coalition objects
to this proposed expansion.
Please see the attachment.

Illawarra Residents for Responsible Mining object to this proposal.

Please find attached Lock the Gate's submission objecting to this
proposal.

Please find my submission attached.

We object to the proposal from Wollongong Coal to mine beneath the
Cataract Dam catchment. Within drinking water catchments nil impacts
on water resources, ecological integrity and catchment functionality
is the only acceptable scenario. The proponent has admitted there will
be serious negative impacts should their proposal proceed and
therefore they should be denied an approval. Our arguements are set
out in the attached PDF.

Preliminary comment attached.

Supporting Submission for the Russell Vale Underground Expansion Project

Our national, state and local economy relies heavily on coal mining so
coal mining benefits all Australians.

Coal is one of Australia's and NSW's most important and valuable
exports.

Coking coal from coal mines in the southern coalfield, such as Russell
Vale Colliery, has ideal qualities for steel production and it has
fewer impurities, such as sulphur, than coal from other countries. So
the use of our coal is reducing pollution, such as sulphur dioxide, on
a worldwide basis.

The employment of several hundred direct employees in the coal mine is
at stake at Russell Vale Colliery.

The federal government's tables of multiplier effects shows that more
than three times as many indirect jobs are created for every person
employed in a coal mine.
Australia and NSW need to focus on the positive aspects of coal mining
and its many benefits so as not be distracted by ideologically driven
anti-mining activists.
Dozens of longwalls have extracted coal beneath the stored waters of
the catchment areas without any loss of drinking water since the 1974
Stored Waters Inquiry by Justice Reynolds.
There have been at least 17 longwalls extracted by Russell Vale
Colliery (formerly called South Bulli Colliery) beneath the stored
water of Cataract Reservoir without any loss of water. Not one drop of
drinking water was "lost". A plan showing many of those longwalls is
attached from page 337 of Book 2 on the "History of Coal Mining in the
Illawarra" published by the Mineral Heritage Subcommittee of the
Illawarra Branch of the Australasian Institute of Mining and
Metallurgy (AusIMM) in 2016, Editor R A Cairns..

Further, the process of mining under stored water is controlled by the
Dam Safety Committee established in 1978 by the state government for
that purpose.

The people who are scaremongering about the security of our drinking
water have caused a great deal of baseless community concern.
We should all be proud of what coal mining is doing for Australia, NSW
and the Illawarra region.
The report submitted by Russell Vale Colliery demonstrates its
comprehensive coverage of all environmental issues. The benefits from
the continuation of this coal mine are immense.

For all of these reasons I fully support the Russell Vale Underground
Expansion Project.

please see attached PDF file