Watermark Coal Mine (Consent Surrendered)

Dear Sir,

Please treat this email as summarising my strong objection to this development after having read the 38 pages of the Earth Systems Report (ESR).

I am a member of the Caroona Coal Action Group. My family company, Winterthur Pty Ltd, owns a property, Bonny Rigg, adjacent to the Warrah Ridge Road at Quirindi.

The ESR discloses so many discrepancies and omissions from the EIS that my overall impression is that Shenhua has treated the preparation of the EIS as an encumbrance (a waste of time) indicating that the company expects that approval for its development is already a foregone conclusion. The chief executive of the company has complained, publicly, of the extensive and detailed Australian environmental considerations (no doubt thinking of his home country of China) which further supports my view.

I draw your attention to the following sections of the ESR which underline that, in the interests of protecting the environment, the whole proposal should be rejected:

3.2. Discrepancy of 2000 ha in the description of the development is quite extraordinary.

3.5. Many gaps in the assessment of the key issues.

3.8. A number of plans relating to the development not provided.

2.2. Drawdown of groundwater to 3.5 additional metres – substantially in excess of previous information provided.

4.4.3. Problems in dealing with, from an environmental point of view, the quantity and quality of site discharge water.

4.4.4. Salinity impacts on the ground and surface waters is most significant.

5.4.7 Management measures. Insufficient information provided.

5.4.8 Insufficient and inconclusive information provided in respect of the justification for the long term impact on agricultural resources and soils.

6.4.1 and 6.4.2. Support documentation not provided for impact assessments.

7.4.3 Assessment to meet requirements of biodiversity offsets not addressed.

8.4.1 Mine closure and remediation – a number of risks that will be faced at that time not addressed.

10.3.1 Aboriginal Archaeology – results of survey unclear.

11.3.1 Waste. The impact of waste generated from the site is not fully addressed.

11.3.2 A number of hazards associated with the proposed use of the site have not been identified or addressed.



Yours sincerely,



E Craig Miller.

Telephone (02) 9498 2969

I am a member of Caroona Coal Action Group
I object to the proposed Shenhua Watermark Coal Mine at Breeza NSW. I have reviewed the submission prepared by Earth Systems for the CCAG and am writing in support of the CCAG submission.

I note that not surprisingly the Shenhua EIS has cherrypicked figures and statistics to suit their
Submission some of which have been mentioned in the Earth Systems report . I hope that it is realised many of them elsewhere are somewhat suspect in reality.
If this is an example of the whole EIS then how credible is the Statement?
I am particularly worried about the lack of realism given to the water , from the mine and run off;
And how Shenhua expects to confine it and deal with it especially with the quantities involved and the salt content and what effect this will have on the river Mouki into which any overspill will no doubt go. What will be the effect not only on the aquatic life but the general environs and then down stream to the Namoi and the Darling system.
How can Shenhua guarantee not to interfere with the excellent aquifers ? We fear they will do irrepairable damage to them and subsequently have a direct effect on the farming and other industries and employment beyond. Will they accept their responsibilities and the principle that the perpetrator pays ?. How do you begin to quantify this sort of damage.?
What assurances will be given to restricting mining to the application only ? How often are there subsequent applications extending and abusing the initial permit to the absolute cost to the locals.
Definitions should be agreed before proceeding any further referring to flood plains and deep or shallow aquifers and other very relevant and extremely pertinent fundamentals. If subsequently the mine is sold on with the permit/licence what assurances at law have the public got to confining the mine to the permissions originally granted only ?
This mine is expected to have a 30 year life span (?) WHERE AS ......
Farming should last for ___thousands__ of years always improving production and quality of crops.
This is an almost unique area to Australia. Very good soils, very good climate with adequate reliable rainfall and with very good water for irrigation easily available. Where else can these be found ?
Please don't' destroy such a rare asset in Australia for " a few shekels of coal "
There are plenty of less fertile and less important agricultural areas in the NW of NSW. In years to come will this decision be remembered as Hazzards Folly? Or should that be Harcher's .( Do we want another Mac's Mine Muck up ??)
Please stand up and do what is right for the long term future .

To the Honourable Brad Hazzard, Minister for Planning, NSW,
As a proud member of the Caroona Coal Action Group, I would like to begin by endorsing the findings of Earth Systems, in their assessment of the Environmental Impact Study prepared by Hansen Bailey for Shenhua Group, on the open-cut coal mine project proposed by the proponent in the Watermark area near Breeza.

As a farmer I must contend I find the
entire proposal quite abhorrent, I believe the planning process is skewed towards developments of State Significance, and is failing to properly measure and test cumulative impacts on surrounding agricultural lands, and water quality and quantity issues. I recently read a collaborative research project, written by a couple of Italian and US academics on the concept of transnational acquisitions
Sent from my iPhone

I support the submission of Earth Systems on behalf of the Caroona Coal Action Group (CCAG), of which I am a I am a member, regarding the proposed Shenhua Watermark Coal Mine at Breeza NSW. I have reviewed the Earth Systems submission, and am most concerned about the number of discrepancies, unresolved issues and potential for environmental and social harm as a result of the mine indicated in Shenhua's EIS.

I live on a farm outside a coal exploration or mining licence area, and have been a resident of the Liverpool Plains for 20 years. I have a well developed understanding of the issues raised in both the EIS and Earth Systems submission, having been professionally involved in primary industry and natural resource management all of my working life. This understanding is supported by a strong technical background. My academic qualifications include a Bachelor of Rural Science (Hons), Post Graduate Diploma in Agricultural Economics, Post Graduate Certificate in Sustainable Agriculture and Master of Business Administration (MBA). I am currently enrolled in a PhD.

I was a member of the Namoi Catchment Water Study Stakeholder Advisory Committee, and Shenhua's Community Reference Groups.

At the first meeting of Shenhua's Community Reference Groups, the consultant charged with developing their EIS introduced himself by stating the number of staff-years his company held in gaining EIS approvals. I inferred from this statement that the consultant was more interested in gaining development approval for his client than preparing an independent statement of potential environmental impacts. This concerned me greatly.

In relation to Shenhua's proposed development, issues which particularly concern me include the following, noting that this list is not exhaustive

- disturbance of white box woodland community and other species listed as endangered or threatened under the EPBC Act. I do not believe in this instance that offsets are appropriate.

- the potential aquifer drawdown.
- impacts on the Mooki floodplain which is in close proximity to the proposed mine site.
- impacts on a valued koala population, and the belief that "re-location" (if this is indeed possible) of such a species is morally and ethically acceptable.
- potential contamination of surface and ground water by salt, chemicals and soil sediments
- the likely extensive erosion
- subsidence

In addition to the issues raised by Earth Systems and others, I raise the issue of climate change. I believe it would be irresponsible of the NSW Government to approve this mine, given the resultant carbon emissions. The support of fossil fuels is contributing to irreversible changes to our global environment, and this will have catastrophic consequenses for our social and economic systems in the future, let alone species which cannot defend themselves. This is in conflict with the principles of Ecological Sustainable Development, and the concept of Triple Bottom Line decision making, in which environmental and social costs are truly accounted for.

Disclose reportable donations: I have made no reportable political donations.

Privacy Statement: I have read the Department's Privacy Statement and agree to the Department using my submission in the ways it describes. I understand this includes full publication on the Department's website of my submission, any attachments, and any of my personal information in those documents, and possible supply to third parties such as state agencies, local government and the proponent.



Yours sincerely,
Katrina McDonald

To the Honourable Minister for Planning, Mr Brad Hazzard, MP,

In a broad, global context we are still fighting for some balance in the `land-grabbing' phenomenon that is beginning to take place closer to home. Transnational acquisitions of land have been happening for a long period of time, however with Shenhua's acquisition of agricultural land at Watermark it has brought home the danger in allowing any land to be purchasable at a price. I recently attended one of Shenhua's community consultations regarding their EIS, and it was very good to hear from local farmers who adjoin the land that is currently being leased-back from Shenhua, of their experience of how it has affected their communities operation, right down to the absence of a local fire truck to fight fires, a couple of farmers noted that the land does not appear to be being managed well for noxious weeds and pests, and I have taken these points on board as I prepare a submission in conjunction with some of the information received from Caroona Coal Action Groups consultant, Earth Systems.

I think neighbours of Shenhua's in the Watermark, Breeza area are experiencing a heightened sense of isolation, since there are less land-holders to constitute a community. I hope you've had time to pen a short submission to the Minister for Planning, into the EIS on the Breeza Open-cut project. Recently at the ADC Futures Summit in Melbourne, the head of Shenhua Watermark spoke about Chinese investment in Australia and noted that the regulatory environment was getting more difficult, he used the term "It's been shifting beneath our feet".

The fact that the Land and Environment Court recently adjudicated in favour of the community of Bulga-Milbrodale, in the case of the Coal and Allied Warkworth mine (a subsidiary of Rio Tinto) versus the Bulga-Milbrodale Progress Association, is a good sign that the tide is turning, and that the planning process is failing in NSW to account properly for displacement of community and enterprise, and also failing to deliver predictable outcomes. This was the criticism that was levelled at the NSW Government and Minister for Planning Brad Hazzard recently by the CEO of Coal and Allied in Australia.

The fact that companies like AGL in Broke or Santos in Marys Mount or Shenhua in Breeza are at their current stages of the planning process, is a good sign that things have not been `working' in planning and environmental legislation, and government generally for a number of years. Companies will not be able to dodge a due planning process forever, one which takes into account that a degree of economic cohesion only occurs in an industry when you have a critical number of enterprises operating side-by-side. It is this way in agriculture.

Senator Fiona Nash recently sent through a paper published on the `land-grabbing' phenomenon, to the NSW Farmers Economics committee, it highlights that acquisitions by transnationals, be they state-owned or otherwise, could be classified as violating human rights when they reduce the availability of irrigation water or other water in surrounding or downstream farmlands, with the potential of causing water stress, social unrest or poorer water quality. It is still not quantified how much water a foreign government or company actually takes out of the system when they purchase land for development or mining. You would be aware that the Ord-Irrigation Project is proceeding with the Chinese investment of $400 million. We are constantly being told that Chinese investment is warranted in a country that is starving for capital, however because water-resources are finite too, we don't want to end up in a situation like Indonesia, where the volume of total `green water' - that water associated with rain-fed agriculture, and the land associated with it has been surrendered for mining or overseas agricultural investment, placing your own countries production in jeopardy. I'll table the paper authored by Maria Rulli and Antonio Saviori et.al. It was an Italian and US collaboration.

I don't believe there is anyway of ameliorating the damage to surrounding agriculture, water resources, or social cohesion by a project of this scale.

The Environmental Impact Assessment is flawed from the outset, as it seeks to address the total output of greenhouse gas emissions of a project of this scope and size, any person on the street in Gunnedah will tell you that as a country we are desiring to move away from carving up the surface of the earth in our quest to extract fossil fuels. The EIS is a mis-representation of the total impact on global greenhouse gas emissions, and the consequential impact on climate change.

I strongly object to the Environmental Impact Study prepared by Hansen Bailey, for the Shenhua Watermark project, the Australian Koala Foundation have stated ad-finitum that they are opposed to the translocation of koala populations by projects of this nature and the resulting coal dust has a pronounced impact on the health of any remaining koalas, as well as human health, and the offsets that are suggested in the report are not of an equal ecological value as the vegetation that is removed in the process of finalizing the mine-plan.

I endorse the entirety of the contents contained within the NSW Farmers Assocation submission, that was submitted by Danica Leys, on behalf of the policy-team at NSW Farmers. I believe the remarks that the outcomes of the Namoi Water Study are not in-line with Hansen Bailey's own `independent' water management plan are spot-on. The Namoi Water study was undertaken to attempt to model what the likely cumulative impacts of a number of proposed coal-mining and coal seam gas projects would be in their entirety. I think most educated people believe that the impacts upon the floodplain, the Mooki River and the surrounding aquifers, despite what Hansen Bailey suggest, are pronounced and not able to be remedied using technology of any kind. The fact that the disturbance boundary and the mines are separated from the Gunnedah Formation by a small buffer zone, does not mean that there will be no impacts on the shallow aquifers and the Gunnedah Formation. It is highly likely and probable that aquifer recharge and run-off, that is surface water flows, will be impeded significantly by the development.

The Department of the Environment, Sustainability and Communities, the portfolio held by Federal Minister, the Hon Tony Burke, MP, publishes the State of the Environment Report annually, in-line with what would be anticipated under the Environment Protection and Biodiversity Conservation Act (1979), recent reports have studied in-depth carbon in soils, categorizing the different types of carbon in soils, that is carbon that is freely available for plant growth, carbon that is locked into soil particles, long-term carbon, and, it is obvious from this kind of reporting that soils of alluvial floodplains, with high carbon contents should not be used as areas of open-cut coal mining.

I was very happy to see the aboriginal representatives that were in attendance at the meeting in the Breeza Community Hall on Friday May 3rd, 2013. Those aboriginal persons present mentioned that it was impossible to retrieve and re-locate the grinding grooves, present in areas of theWatermark project. In other areas of New South Wales grinding grooves and other aboriginal relics, that are of irreplaceable value have been moved and damaged in the process. It is a damning endichtment on previous governments, both State and Federal that companies have been able to damage and destroy some places of significance and some irreplaceable relics in the process of minerals extraction.



I believe the Breeza community and the wider Gunnedah community have spoken quite categorically in their opposition to this project comprised of three separate open-cut mines producing coal at a rate of 10 million tonnes per annum, Run-of-mine Coal for 30 years. No amount of royalties or taxes will account for the damage to the current community, lifestyle, and amenity benefits of the Breeza community. A community founded on the agricultural industries including cotton production, beef cattle and dryland broadacre cropping.



I wish to conclude my submission here.



Angela Martin

To the Honourable Minister for Planning, Mr Brad Hazzard, MP,

I attended the recent meeting with the Breeza community at Breeza Community Hall on Friday May 3rd, and it was apparent that many community members feel some of the information provided in the EIS, and the accompanying graphics are a falsification of the nature of the Breeza community, a community based around agricultural production. Many community members felt the employment data presented in the EIS, was exaggerated and community members are proud of their current employment including with Carroll Cotton Gin, driving trucks which transport cotton from farm to gins and as farm-workers.

The recent Cotton Australia report into cotton production and its inability
to co-exist in any way with open- cut coal mining was timely and relevant to this project. Laser-levelled and capitally-improved land, for irrigated cotton production cannot live comfortably alongside a project comprised of three open- cut coal mines, and the clearing of 4000 ha of vegetation and subsequent subsidence that occurs, the types of subsidence that occurs, have been well articulated elsewhere.

It is clearly in complete contradiction to sustainable, economic agriculture.

I wish to conclude my submission here.

Angela Martin
Sent from my iPhone

My submission is written in the PDF attachment.

See attachment

See file upload below

my submission has been uploaded below.

I have uploaded my submission below as a pfd.file

Submission uploaded

26th April 2013

Submission of Objection
Watermark Coal Mine
SSD - 4975 Watermark Coal Project


Hunter Environment Lobby Inc (HEL) is a community environmental organization which has been commenting on developments mainly within the Hunter catchment for over fifteen years. We have also been regional representatives on committees with government agencies.

Hunter Environment Lobby Inc wishes to object to this development on environmental, social and economic grounds and asks that we may outline these objections more fully in a submission within the next two weeks.

We are hoping that this may be possible and await for a decision by this department in the near future.

The EIS of this project gives an interesting way of presenting the actions that the proponent may go ahead or not, and supplies up to eight alternatives for that. HEL supports the Number 7 option that is set out in the EIS, that is the `do nothing' alternative.

We do this on the grounds that the noise, dust, soil degradation and runoff, issues have not been adequately examined. There is also inadequate rehabilitation information in the documentation.

Environmental impacts of this development are also unacceptable, and the economic impacts have not been adequately examined, especially in the light of the recent Land and Environment Court Case involving the Warkworth Coal modification in the Upper Hunter.

We await your decision on granting more time to outline fully our objections within the next two weeks, and hope that you may advise us of that decision in a timely manner.

Yours Sincerely


Jan Davis (President)

Please refer to attached letter.

Please refer to our submission in the attache letter

My submission is in the pdf file below at attachment 1. Thankyou.

I am a Liverpool Plains landholder. I object to the proposed Shenhua Watermark Coal Mine at Breeza NSW.

This project will have significant impact on our community and region. Some of these impacts include:

1. Koala - One of Australia's Great Iconic animals . The population of these benign creatures in the Liverpool Plain area is to be put under stress from mining their habitat , as well as dust, noise , bright lights and seismic shock waves from blasting. Nobody knows whether the local population will survive prolonged mining operations in the Shenua area, until it is too late. History shows that when Koala's become stressed in their habitat they become susceptible to diseases and they die out. Is this to be the end story for any creature that gets in the road of a coal mine?

2. Water - there is a risk of contaminated water being released from the sediment dam during rainfall events where it exceeds the capacity. With the unpredictable rainfall events this situation is considered most probable and the releasing of contaminated water across the black soil plains and into our ground water systems is unacceptable.
It is stated in the proposal that:
- there is a potential for the reduction of catchment flows to surrounding waterways including the Mooki River, Watermark Gully, Native Dog Gully and Lake Goran with 25% loss at Watermark
- groundwater levels are predicted to largely recover rapidly
- a reduced rate of upward flow from the Permian to the alluvium is predicted
These predictions and forecasts by the Proponent are of great concern to our community.

3. Ecology - A total of 4,084 ha of vegetation will be removed progressively over the life of the project. This is a very large loss of vegetation and most certainly not allowed for any farmer to clear under any circumstances. The mine Proponent will no doubt shape the mountains of spoil and plant grasses and maybe some trees to make the vista more acceptable to a casual glance. But once the statutory period for maintenance of the area expires , the grass thins out and the trees wither. The evidence of this is before everyones eyes to see if you travel around the Hunter Valley coal mining areas. Ask yourself, how many sheep and cattle do you see grazing these "restored " mines. The answer is none! The soil is unfertile , the grass is too low in energy to sustain grazing animals.




4. Future Expansion - It is stated in the EIS that a final void will remain in the Western Mining Area and will cover an area of approx. 100 hectares. It will have a maximum depth of 80 metres below the natural ground surface. This is the outcome that is recommended by the mining company as it is the most cost effective method plus it allows opportunity for access to coal resources. This raises concerns for our community as we are not talking about a one off mine but an opportunity for future expansion with further risk to water resources, agricultural land and people's health.

5. Noise - the proposed mine is located near the village of Breeza in Northern NSW which is a quiet rural area. Infrasound/low frequency noise (ILFN) produced by machinery is known to be a problem in these types of areas due to the lack of background noise. ILFN is known to cause cardiovascular disorders, psychological problems and stress. It is of great concern to the community that Shenhua is not completing any assessment on low frequency noise as stated in the EIS "Acoustics Impact Assessment 4.6 Low Frequency Noise - no separate assessment of low frequency noise levels is required".

6. Heritage - Both aboriginal and European. The project will destroy significant Aboriginal heritage sites. The relocation of any significant object from its natural environment is not recommended due to the potential damage that can occur. Since white settlement the Liverpool Plains have changed remarkably little . The change in agriculture from grazing to cultivation which mainly occurred post World War 2 has today left New South Wales with world class cropping land that can be managed to produce food for future generations for as long as humans remain on the planet. It seems to me to be insanity to risk long term food production for the short term cash grab from mining.

7. Increased Train Movement - All towns and properties along the rail line will be impacted by additional noise and dust from increased coal train movements.

If the Government approves this project, they are knowingly approving the detrimental impacts of this mine at the cost of the landholders and the community. The Government will be shown to have a clear double standard . One set of rules for ordinary citizens with tough environmental rules and fines and gaol time for offenders , and one set of rules for large mining operations where you get what you want , priority over everyone else's interests. Once the mine starts, you cannot stop or mitigate the impacts to the water resources the surrounding land and ecosystem. The system enters a new state and is changed forever.
Be it known that I fully support the Caroona Coal Action Group's submission to review the Shenua EIS.

I have uploaded a submission in PDF format