I don't agree with the mining being so close to residents and in a
catchment. We have a beautiful area down here, let's not destroy it
for residents and tourists, now or future.

I support this Project with a revised bord and pillar mining method,
which will minimizes subsidence to very low levels the project will
also have minimal impacts to groundwater and the catchment area. The
continued operation of the Russell Vale Colliery will continue mine
employment with secure employment for the proposed workforce of 205
employees and will provides an additional 22 jobs during the
construction phase of the project and provide ongoing economic
contribution for the Illawarra and community.

I support extending the life of Russell Vale Colliery because it will
secure employment for the workforce

I am in favour of the proposal as I believe that mining is an important
industry for the Illawarra

As a resident and highschool student in the Wollongong area, I will be
directly impacted by any development under the water catchment. I am
writing this submission to object to the proposed mining under the
catchment, because water supplies are already being stressed by rising
temperatures and periods of drought - both being exasperated by
climate change.

There is no place for the opening of new mines in Australia if our
governments are going to take climate change seriously. A new coal
mine would only increase the amount of carbon emissions we are
emitting.

It is also clear that Wollongong Coal is a company which cannot be
trusted, with a very concerning history of terrible behaviour back in
India. Stories have been told of slag heaps being dumped illegally
near villages, and then children have been incinerated while
innocently playing near them. They have also gone out of their way to
attempt to assassinate people back in India who fought their pollution
of their villages. They propose this long wall coal mining not
considering the likelihood that cracking would develop in the dam.
They ask for us to trust them to look after our water, but how can we
when we know their history of dishonesty. They ask us to trust that
they'll do the right thing by the water catchment that supplies both
Sydney and the Illawarra. What will other countries think when they
hear Sydney has run out of its fresh water supply because it allowed
coal mining to occur underneath it?

This coal mine cannot go ahead. For my future and everyone else's
future, it cannot go ahead.

As a member of a local family business, I have had many years of contact
with the Russell Vale Colliery. As a provider of goods and services to
the Colliery, I have witnessed the importance of this business to the
Illawarra region, not only as an employer of locals, but also a
consumer who has provided a steady source of income to many local
businesses and their families.
A special mention should also be made of the hard working staff at
Russell Vale colliery who have endured hard times along with the good,
with a view to the longevity of this operation.
It would be a great shame to see another large employer and industry
force depart the region as a result of any short sighted refusal of
their expansion application.
The Illawarra region needs our primary industries to remain strong and
successful to ensure economic prosperity for our families continues
into the future.

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

The Russell Vale colliery operated beneath the Special Areas of
Greater Sydney Water catchment. The Greater Sydney and Illawarra
regions are currently in drought, with dam levels below 50% and
falling by the day. The effects of subsidence from underground mining
on groundwater are significant. This expansion proposal carries a
significant risk of pillar collapse in the old Bulli seam workings,
which can lead to 1-2 metres of subsidence - an enormous amount. This
project is a significant risk to the water catchment and is completely
inappropriate in a region so crucial to water security for the Greater
Sydney region.

Furthermore, this project carries significant detrimental health
impacts to the community, through both air pollution from coal dust,
water insecurity as detailed above, and contributon to climate change
from the 11 million tonnes of CO2-equivalent greenhouse gas emissions
that the coal from the Russell Vale coillery will produce in its
lifecycle. These health impacts will hit the most vulnerable in our
communities the hardest - children, pregnant women, the elderly, and
those with chronic health conditions. This is an unacceptable burden
to place on the communities of the Illawarra, for the private profit
of Wollongong Coal.

I call on the NSW State Government to reject this application from
Wollongong Coal, and to commence a process to close the Russell Vale
mine permanently.

Yours sincerely,

Dr Rada Germanos
B. Med Sci, MBBS

I support the Project as the revised bord and pillar mining method
minimises subsidence to very low levels with minimal impacts to
groundwater and the catchment area. The continued operation of the
Russell Vale Colliery will continue mine employment and provide
ongoing economic contribution for the Illawarra and community.

I support the Project as the Company has responded to the
environmental issues raised and has come up with a revised mining
method that will minimise subsidence and groundwater impacts to the
catchment.

I support the Project as Wollongong Coal has been innovative to
redesign the mining method to limit environmental issues on the water
catchment.

I support extending the life of mine for Russell Vale Colliery because
it will secure employment for the proposed workforce of 205 employees
and will provides an additional 22 jobs during the construction phase
of the project.
I support the Project as it will provide an estimated a net benefit to
NSW of $174.3 million and an estimated net benefit of up to $14.2
million to the local Illawarra region.

I support the Project as I consider this proposal as very important to
the Illawarra region for ongoing employment.

I support the Project as I feel that mining is an important industry
for the Illawarra region.

I support the Project as it is great for the community and jobs.

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.
I am a long-term resident of the Illawarra having lived at Coledale
for 18 years. In that time, I have seen an increase in the frequency
and severity of drought and bushfires. My home is below the Escarpment
and the sight of smoke from fires on lands above is now common. There
is no doubt that the drying effect on vegetation of water loss in the
catchment contributes to adds to both fire risk and erosion by both
wind and rain. As a member of the Illawarra community I am acutely
aware of the effects of noise, dust and traffic of a coal mine in the
middle of a suburban area.
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.
I 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. I have not made a
reportable political donation.
Yours sincerely,
Brian Mason
39 Buttenshaw Drive, Coledale, NSW, 2515

Destabilising overlying mines

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 contrary to public interest for the NSW government to
allow such risky mining in the water catchment for 5 million people of
Greater Sydney in a time of drought.(1)

The land around the proposed mining is unstable. The proposal states,
"It is noted that large areas of the surface within the UEP
Application Area are currently on the verge of moving as a result of
previous mining." [2] It is described as being in "limiting
equilibrium" - still moving, having not stabilised since WCL mined
longwalls 4, 5 and 6 several years ago. If the Special Areas of
Sydney's Water catchment are so special that ordinary people can't
even set foot on them without risking a $44,000 fine, they are special
enough that they should be protected from earth moving, destructive
mining.

Impact on ground and surface water

The project will further the loss of ground and surface water from
Cataract Reservoir and its catchment, adding 131 ML/year of ground
water and 10 ML/year of surface water to losses from previous mining
damage. This is estimated to bring the total ground and surface water
loss from the project to 298 ML/year. [3] This is the equivalent
annual water usage of 25,492 people. [4]

An additional 146 ML of "upgradient inflow" from surrounding mines -
the now "inactive" Cordeaux mine and Corrimal mine (not mined by
Wollongong Coal) - are draining water into WCL workings, bringing the
total to 444 ML/year.[5] This is the approximate water usage of 37,981
Greater Sydney residents.[6]

Following mining the void left will fill up with water. The water will
keep rising until it reaches the adit (mine portal) in the Illawarra
Escarpment in about 2057. The water will overflow through the adit and
the outflow will slowly increase, reaching 0.3ML (300,000 litres) per
day in 2179. WCL's modelling shows that the volume of water outflow at
the adit above Russell Vale will continue to flow, even beyond 2179.
[7] In other words, the project will result in escalating water
discharge from the adit for at least 160 years and probably longer.
The outflow will need to be managed and treated. Wollongong Coal is
proposing a commitment to manage and treat the water for 10 years.[8]

Greenhouse Gas Emissions

Although only a small project, the Expansion has a large carbon
footprint. WCL's consultants divide emissions into Scope 1, 2 and 3,
with 1 and 2 being the emissions produced in the mining and processing
of the coal and Scope 3 being emissions are "indirect emissions that
are a consequence of the activities of the reporting
entity but occur at sources owned or controlled by another reporting
entity"[9]. Scope 3 emissions are the largest volume of emissions, as
they involve use of the coal. The total CO2e emissions for the
project, from mining up to and including usage are approx. 11,147,000.
[10]

To put this in context, this is the equivalent to the annual emissions
of more than half a million Australians.
[11]

Economic case

The mine is currently in Care and Maintenance mode and only about 60
staff are employed. Therefore the impact on the employment outlook for
the Illawarra if this approval was not granted would be minimal.
Moreover, as neither of Wollongong Coal's mines are currently
operating the flow-on effects to the local economy if this proposal
was not approved would be negligible.

A coal processing plant on site at Russell Vale Colliery

Wollongong Coal plans to build a coal processing plant at the Russell
Vale Colliery and process coal on site.[12] 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.

Trucking

· The coal is trucked along Bellambi Lane, past people's homes onto
the Northern Distributor to Port Kembla Coal Terminal. WCL's new
expansion proposal means more coal trucks on the busy Memorial Drive.
There will be an average of 16 laden trucks per hour, Monday to
Saturday, travelling to the port.[13] In other words, counting the
return trip, there will be 32 truck movements per hour, or one truck
every 112 seconds. In addition to this there will be more coal trucks
transporting coal mining waste.[14]

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.

In fact right now, Wollongong Coal is operating under three major
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.

It is of real concern that the proponent is proposing to put in place
pit top infrastructure after they have started mining. History shows
that operators of this mine are unwilling or unable to meet the
conditions of mining approval and the Department of Planning is
unwilling or unable to enforce compliance. In every case the local
community suffers from the failure to implement required pit top
infrastructure.

The suitability of the proponent

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.

In India, corruption charges are being framed against Naveen Jindal,
Chairman of Jindal Steel and Power Ltd (JSPL). JSPL, via a holding
company, JSPL Mauritius, is majority shareholder in Wollongong Coal
Ltd. [14]

Moreover, here in Australia, 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. Operating a coal mine
in the water catchment of Australia's largest city is risky business.
The NSW Resources Regulator started investigating whether Wollongong
Coal was a "fit and proper" entity to hold a mining license in
2016...... and it's still investigating...... Isn't it about time the
Resources Regulator reached a conclusion? And shouldn't any
consideration of an expansion of operations be postponed until after a
conclusion has been reached.





REFERENCES

[1] Russell Vale Revised Underground Expansion Project 3687_R05 RtPAC
Second Review FINAL Revised Preferred Project Environmental
Assessment, p. 62
Accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[2] ibid, p 63
[3] Russell Vale Colliery Underground Expansion Project, Russell Vale
East first workings, Groundwater assessment, Geo terra, NRE16 - R1D,
11 July, 2019, p. 96 accessed at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[4] Based on water consumption of 306 litres per person per day, cited
in Sydney Water Conservation Report 2017/2018, accessed at
https://www.sydneywater.com.au/web/groups/publicwebcontent/documents/document/zgrf/mdq3/~edisp/dd_047419.pdf
[5] Geo terra 2019, op cit, p. 63
[6] Sydney Water Conservation Report 2017/2018, op cit 8[7] Geo terra,
2019, op cit, pp. 96-97
[7] Russell Vale Revised Underground Expansion Project, op cit, p. 172
[8] ibid, p. 158
[9] ibid, p. 133
[10] Greenhouse Gas and Energy Assessment 3687_R08_GHG Report_Final
Impact Assessment Results p. 7
accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[11] Australians annually are responsible for about 21.528 tonnes of
CO2 per person (based on 538.2 mt CO2 emissions year to Dec 18 as
cited at
http://www.environment.gov.au/climate-change/climate-science-data/greenhouse-gas-measurement/publications/quarterly-update-australias-nggi-dec-2018)
and population of 25 million)
[12] Russell Vale Revised Underground Expansion Project, op cit, p. 9
[13] TRAFFIC AND TRANSPORT IMPACT ASSESSMENT FOR RUSSELL VALE COLLIERY
REVISED UNDERGROUND EXPANSION PROJECT AT RUSSELL VALE RESPONSE TO PAC
SECOND REVIEW REPORT, p 5 accessed at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[14]
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