As a community member in a neighbouring community whose livelihood
depends on clean water and arable agricultural land I wholeheartedly
believe the Vickery mine extension Environmental Impact Assessment
should be rejected.
The mine poses the risk of irreversible damage to the Namoi River, the
surrounding surface water and groundwater, and the health and
well-being of human and animal populations across the region.

* This is not my full submission - our Region is in the midst of a
catastrophic drought - as a farmer I am busy from sun up to sun down
and believe that due to the short public exhibition period I am
severely limited in how much time and effort I can spend on my
response to this huge and complex document. I believe that the
relatively short Public Exhibition period has compromised the right of
the public to comment on this important State Significant Development
and is an incorrect decision by the Minister for Planning who refused
to extend the Public Exhibition to 90 days to allow more expert
consideration and community comment. It is extremely inconsiderate
given the Regions current state of drought and the pressures families
are under on a daily basis, without having to digest and respond to
documents such as these in such a short amount of time.

* The EIA does not make any attempt to apply the Precautionary
Principle to its assessment of the cumulative impacts of this mine.
There are many examples where the EIA has ignored or misstated the
cumulative impacts. Eg locals are already badly affected by blasting
vibrations and dust from Whitehaven's Rocglen and Tarrawonga mines.
This is not alluded to in the EIA. The EIA also is misleading about
the distance between Vickery and Tarrawonga, stating they are 11km
apart when in fact there is just 4km distance between Tarrawonga and
the proposed Vickery borefield.
In view of pre-existing concerns about dust from the Leard Forest coal
mines, I am of the view that cumulative impacts of dust pollution and
the risk to the health of communities in the Gunnedah Basin are not
adequately assessed.


* Social impacts of the mine includes health and well-being, including
physical and mental health. According to the Social Impact Assessment,
existing local mining operations form part of the basis of assessment.
Many impacts are not quantified, such as for example the effect of
mine noise on sleep disturbance and quality of life is completely
ignored in the Social Impact Assessment, yet widely known since a very
large number of Boggabri and Maules Creek residents lodged moving
objections to the Maules Creek noise modification last year.
The Social Impact Assessment does not refer to the growing evidence
about rising bronchial ill-health in Boggabri and Narrabri towns, and
is consistent with health problems in the Upper Hunter Valley. I am
exceptionally disappointed that the recently established Namoi Air
Quality Monitoring System does not incorporate dust monitoring in or
near the town of Boggabri. WHY??
The SIA makes much of the fact that "anxiety" is a national problem.
However, I believe that anxiety in coal-affected communities is based
on real triggers that emanate directly from the coal mining industry.
Examples include:
* The threat of loss of livelihood and property rights
* Dividing neighbor against neighbour is a common tactic of Project
Delivery personnel to break down a bloc of landowners who deny access
to their land
* Night-time noise and sleep disturbance is bound to result in some
anxiety
Therefore, to blame the anxiety in coal-afflicted communities on a
general national mental health problem fails to properly assess mental
health impacts of the Vickery coal mine itself on the local community.
This MUST be addressed immediately.

* Over 70 farms have been sold to coal mines in the area around the
Boggabri and Maules Creek region. This has caused leakage of long-term
resident population and replaced them with tenants in the most part,
many of whom do not bring their families with them. Many more tenants
are employees of the mines, and do not farm. Farming land is either
grazed by arrangement with other parties, or left unfarmed, often
because the property has been deemed a biodiversity offset.
Community groups such as the NSW Rural Fire Service, the Country
Women's Association, Meals on Wheels, etc suffer due to the decline in
permanent residents.
This has led to a downward economic spiral in Boggabri.
Employment forecasts unreliable due to the prevalence of drive-in,
drive-out workers.
It is a well-observed fact that even mine staff who have an address in
Boggabri are Drive-in, Drive-out workers. They tend to leave their
families in places such as the Hunter Valley towns, and commute weekly
to their work. This has not been addressed in the SIA. Boggabri has
not received an influx of population, and Whitehaven are understood to
encourage workers to live in Gunnedah instead, adding to road traffic.
Small communities simply cannot afford to lose families to FIFO or
DIDO workers - it does not sustain local business nor improve living
standards for locals.

* Boggabri is a town in slow decline, despite the assurances that were
made by the coal industry when the Maules Creek mine was being
proposed that prosperity would come.
Despite strong support in the community for a dust monitor in the town
of Boggabri, which is supported by Boggabri Coal (Idemitsu Resources),
Whitehaven has opposed this plan. Although a Dept of Planning
representative recently blamed this on the NSW EPA, there is written
evidence that Whitehaven refused to support the Boggabri dust monitor
unless it were paid for by the NSW Government.
Loss of population has an impact on housing occupation levels.
The CIVEO worker camp benefits to Boggabri are overstated - CIVEO
never patronized the Boggabri butcher, for example, and bought their
meat from elsewhere.
Businesses in Boggabri have not seen the benefit from decade of coal
mines, if anything the reverse has happened. Only one pub out of three
remains in operation.
There is no child care centre and furthermore Whitehaven Coal
approached Narrabri Council and advised them not to invest in child
care in Boggabri, which is a disincentive to young families who may
wish to relocate there. Community bitterness surrounding the child
care centre has caused extreme distress to the Boggabri Business and
Community Progress Association, which strives to secure the survival
of the town.


* The Noise Impact Assessment has extremely significant ramifications
for the surrounding community, with impacts that will extend to the
town of Boggabri, based on my knowledge of other coal-affected towns
such as Wollar and Bulga, which are being gradually depopulated due to
mine encroachment and noise issues.
The construction of a coal handling and processing plant at the
Vickery coal mine is an additional threat, as it will produce
unacceptable levels of low-frequency noise.
In addition, the Noise Impact Assessment is lacking an All Years Worst
Case Scenario, and fails to include key noise producing infrastructure
in its modelling.

* No modelling has been provided as to the movement of surface water
once the railway were to be constructed, and inadequate details of the
construction of the 14 km rail spur. There are inadequate indications
of what sections will be elevated, and which will be embankments.
This has very serious ramifications for flood risks and makes it
impossible for anyone to make an informed submission.
Further, acccording to the Dept of Planning, "this is a flood
modelling much different than other developments .. without explicitly
stating where each structure is.... It's certainly a key issue."
[Source: Stephen O'Donoghue, Team Leader, Resources Assessments, Golf
Club meeting 26th Sept 2018]
I do not have confidence in modelling which is based on such vague
assumptions, with no details about where each structure is.
The rail loop itself is particularly too close to the Namoi River and
the riparian vegetation and koala habitat will be lost.
The community has been living under the assumption that there would be
no Namoi River crossing associated with this project, since Whitehaven
Coal was advised the Commonwealth of the Environment that a river
crossing would not be acceptable under the Environmental Protection
and Biodiversity Conservation Act.
The coal railway is one of the most serious concerns about this
Vickery project.

* The entire locality where the Vickery mine is intended to be built
is prime koala habitat, including the area where the rail loop is to
be built.
Koalas are listed as an endangered species under NSW and Commonwealth
legislation. I do not believe that any mitigation measures, such as
relocation of the local koala population can be viable because
alternative habitat is being destroyed throughout NSW and in any case
relocating koalas is known to have a high failure rate.
Impacts on the Koala have also been understated because of
insufficient consideration of impacts upon the full extent of suitable
habitat within the Approved Mine area. Like other cumulative impacts,
the effects on koala habitat have been dealt with poorly in the EIS.
There does not seem to be any limit of the extent of impact being
considered and matters in relation to landscape impacts have not been
considered adequately.
Right now, some of the most important and large nearby koala habitat,
being Vickery State Forest and Leard State Forest are either being
actively destroyed by coal mining, or else they are slated for
destruction in the medium-term.

* This Project is a controlled action under the Environmental
Protection and Biodiversity Conservation Act, and is a "large coal
mine" under the terms of the EPBC Act.
This EIA does not provide an adequate amount of detail to enable
decision-makers at the State or Commonwealth level to properly assess
the likely impacts of the mine, and the railway, on the Namoi River,
and the surrounding surface-water and groundwater.
Elsewhere, the EIA provides factually inaccurate or incomplete
information which may a tendency to be misleading.
I do not have confidence that the Namoi River is safe from severe
damage if this mine proceeds, and fear that water quality and
downstream flows will be damaged to the detriment of downstream users.

* From the experience of issues over the Maules Creek mine, Whitehaven
continually ignore their responsibilities in relation to cultural
heritage as it is set out in the Burra Charter and the Policies
relating to Aboriginal Cultural Heritage Valuations set out by the
Office of Environment and Heritage. There has been a lack of any
consultation with the First Nation's People's Knowledge Holders,
within the Red Chief Local Aboriginal Land Council boundaries.
Consulting with Registered Aboriginal Parties is not enough.

With little time to respond I would again like to reiterate that I
WHOLEHEARTEDLY object to the approval of this EIA and urge the
Department to allow the community, region and wider community a chance
to respond in a proper manner. Elections are won and lost on the way
in which Governments listen to their constituents - this issue may
very well be another nail in the coffin of a government refusing to
embrace climate change and listen to the people living in these
communities. As a Coonamble local I know only too well how devastating
the threat of mining on our communities can be - our water is too
precious to risk FOR ANY REASON. Prime Agricultural land also needs to
be protected - we cannot afford to continue losing Prime Ag land -
there will be a food crisis as well as a water crisis - HOW DO WE LIVE
WITHOUT FOOD AND WATER?
I

As per attachment, please find ASG Equipment's submission in support of
the Vickery Extension Project.

As per attachment, please find Absolute Services Group's submission in
support of the Vickery Extension Project.

this mine extension will impact heavily on both us and our neighbours

See attached submission.