Tahmoor South Coal Project

Summary

The Tahmoor South Coal Project should not proceed before the colliery
pumps stop extracting water produced from the west where earlier
longwall mining approached closest to Thirlmere Lakes. Any delay
stopping the pumps extracting water from below the level of Thirlmere
Lakes delays restoration of the World Heritage status Thirlmere Lakes
National Park.

The Office of Environment and Heritage ongoing research into the
drying of Thirlmere Lakes is the minimum standard of research required
before new areas of coal extraction can proceed. As Undermined Inc
does not want other areas to be damaged as badly as Thirlmere Lakes
and Redbank Creek have been, the documentation supporting this Project
is inadequate.

Tahmoor South Coal Project must not proceed until Tahmoor Coal knows
whether its longwall mining has affected Thirlmere Lakes, Myrtle
Creek, Redbank Creek and dewatered the land it has mined under, and
can confidently say it will not happen again with this Project.

Redbank Creek has subsided so much from past mining that it is
unacceptably dry and polluted. This has happened due to inaccurate
forecasting of the effects of longwall mining, the same forecasting
used to predict the acceptability (to Tahmoor Coal) of the Project.

Redbank Creek is a clearly visible example of damage caused by
longwall mining that can not be remediated. Tahmoor Coal can only stop
mining under creeks if it is to avoid damage that can not be
remediated.

Information on the sustainability and environmental acceptability of
the proposed mining process is not offered to the local community
affected by the mining. Undermined Inc has been asking for daily logs
of produced water from Tahmoor Coal so the community can do its own
autocorrelation and coherence analysis of surface water loss and
rainfall. Monthly aggregated data are insufficiently detailed to
understand whether improvements need to be made to mining methods to
protect the environment.

Mining companies are responsible for rehabilitation of all impacts of
their mining activity including climate change, not just those at the
mine site, yet this proposal does not acknowledge that responsibility.

Environmental assessment and reporting should be on cumulative
impacts, and not on individual incremental impacts.

A robust and independently verified risk assessment framework should
be established, based on probability, impact and mitigation options of
mining damage.

There should be no mining where damage cannot be rehabilitated.

Rehabilitation funding for mine closure should be put in escrow or
similarly secured and not accessible for progressive rehabilitation or
diluted in other ways during mine operation.

A monetary value should be assigned not just to economic but also to
environmental and social impacts and included in Tahmoor Coal's
business plan analysis.

Rehabilitation should target return of the land to pre-mining
conditions and use, not just to "safe, non-polluting and sustainable".

There should be a watertight mechanism for this mining company to
remain responsible for damage cause or discovered after mining
operations cease.

Climate change mitigation by Tahmoor Coal is neither proposed nor
evaluated in the project documents.

Please see attached submission.

Please note submission as attached.

Refer attached.

NB: late submission submitted by Andrew Rode (DPE) online on behalf of
NPA NSW.

Refer attached email and other attachments.

NB: Submitted online by Andrew Rode (DPE) on behalf of Endeavour
Energy.

Refer attached - late submission uploaded by Andrew Rode (DPE) on behalf
of submitter.

Department of Regional NSW - Mining, Exploration & Geoscience response attached.