SUBMISSION OPPOSING GRL'S ROCKY HILL COAL MINE PROPOSAL

INTRODUCTION

I am writing to strongly oppose the proposed GRL Rocky Hill Coal mine in Gloucester Shire.

Before deciding to live in Gloucester Shire, I visited on several occasions, stayed in B&B accommodation, the Country Club Motel or I camped. I listed other places along the coast but decided on Gloucester due to its friendly atmosphere, its great beauty of a mix of agricultural pursuits and its natural environment. It was a peaceful change and a way of life that the Hunter and places closer to large centres could not offer.

I chose to farm in Gloucester because of its unspoiled beauty and country charm and the great promise of being able to get away from it all. This is the place I `retired' to. This is where I now spend nearly all my discretionary income and where I contribute to the community. I take great pride in my farm and try to bring about a practical balance with the environment has included fencing off a rainforest for permanent protection.

My family and guests love coming to Gloucester for the same reasons that I chose to live here.


THE GLOUCESTER SHIRE MAJOR DEVELOPMENT PROJECT (GSMD)

There already exists a major significant self-sustaining project known as the Gloucester Shire. By its diversity, it has attracted or produced a population 5,000 people living in more than 2,000 dwellings and has generated all the essential businesses to support and grow a vibrant self-sustaining Gloucester township and Shire.

The cornerstone of the Gloucester Shire Major Development project (GSMD) has been organic growth. That growth is based on exploiting, valuing and nurturing the environment. A model of success, today businesses are attracted to the Shire for its beauty and healthy lifestyle.

Community concern regarding GRL's activities is entirely justified - GRL continues to be an untrustworthy secretive adversary that intends to mine coal in the Gloucester Valley despite clear and continued community and council opposition. The nature of opposition is not about `not in my backyard'. The community is generally aware of the immense damage to be inflicted, and the potential for GRL to permanently disfigure the GSMD - its economy, environment, roads and traffic, health and community amenity.

GRL's `spin' continues to pussy-foot around its true intent. GRL is not an organisation intent on helping GSMD - despite its delusional goal. Indeed, in an earlier life many of the same managers and backers were promising to `help' Margaret River.

By any economic comparison of the two projects, GRL's Rocky Hill Coal Mine proposal is insignificant. But it carries enormous adverse and permanent impacts for the GSMD because of its:
contaminating production,
processes that ensure permanent soil, water, and aquifer damage,
constant need to expand and damage more land until its has taken all,
secretive deceptive ways,
continued contamination of all that the GSMD project, its people, and businesses rely on,
potential to create economic and employment shockwaves with its responses to the coal price,
lack of long term loyalty to the community, and
eventual exit which should be expected to be unplanned and under-resourced - particularly as exit is likely to coincide with poor profitability.

In essence, two 'significant' projects are in conflict. GRL seeks to intrude.

GSMD is major, pre-exists, and has a vibrant healthy future upon which the people of Gloucester - its stakeholders - rely.

GRL's Rocky Hill is insignificant. Demonstrably, it brings no economic benefit to the Shire or the State. But the nature of its business makes it extremely significant to this Shire - because its intent and processes are precisely opposite the GSMD's.

These undermine GSMD's cornerstone principles and for this reason the proposed small Rocky Hill and its various cancerous forms have the potential to cripple the major project. Already this has started. Already there are negative business and employment impacts. Already productive agricultural land and investment lies idle. Already homes on the Forbesdale estate are unsalable. These impacts for the GSMD will deepen.

The choice for government is simple. Choose for protecting Gloucester and its community and reject an inefficient, damaging and misrepresented project.


MY OBJECTIONS
Gloucester will be forever changed for the worse if this mine is approved. It will be a mining town with damaged landscape, poor air quality and lost rural character. It will lose its friendliness as drive-in-drive-out workers become the norm. They are only interested in Gloucester as a mining centre - and a place to damage for their pay. I know that most are not proud of what they do. But they do it.
The Shire character will change because of mining. But is will also change and lose important diverse businesses and people whose businesses and interests will have been undermined by unsustainable coal mining and its many impacts on peaceful self-sustaining activity. So Gloucester is set to gain features that detract and lose features that are beneficial. It may take 20 years but it will happen if GRL is allowed this foothold.

This whole application should never have happened. A caring government has more than enough reasons to refuse this application - and any other anywhere in closely settled Gloucester Shire.
The EIS is biased for a GRL outcome - it cannot satisfy the Planning Department's needs.
The EIS should be either refused outright (preferred) or rejected to include the full scale and impacts of mining associated with stage2.
The mine clearly is intended to grow to stage 2 - which will make the mine bigger, closer to residents, last longer and probably become full 24 hour operations - but GRL has restricted itself to only presenting impacts of stage 1. We must see the real definition of `Rocky Hill' project. Not just the unviable-foot-in-the-door stage1.
Current and past MDs have all indicated they will mine closer to Gloucester if viable.
GRL has two adjoining exploration areas that will be mined if this application is successful.
Rocky Hill will reduce the quality of life of most people in the community.
Up to 500,000 litres of diesel will be burnt in this enclosed Gloucester Valley to dig up coal that NSW does not need - for a few greedy men.
Coal dust and diesel emissions are proven carcinogens for which there is now no safe minimum level. GRL will introduce these major quantities.
It borders on insanity for GRL to seriously suggest in any forum that an overburden dump in plain eyesight to all visitors is a `visibility barrier'.
Climate change is real. GRL states that it will consume massive fossil fuels at the current `stage 1' unviable production rate.
GRL will also release more methane for which there is no capturing solution. In a press statement for the failed Vasse Coal project in the Margaret River the same people now promoting or backing Rocky Hill acknowledged that these fields are methane rich.
Coal mining permanently damages the soils and aquifers important to fellow farmers near the mine area.
GRL have no viable way of `rehabilitating' the mining lands. The `void' cannot be filled with rubble and then miraculously become aquifers.
30% of run of mine coal is waste that will be returned to the pit or dumped with the overburden. This coal, its dusts and toxins, become part of the new geology for leaching and ultimately will enter the water system
The people who live close to the mine, and the residents of Gloucester, are permanently exposed to all of the adverse impacts of coal as part of their daily lives.
GRL cannot give any assurance regarding train loading times - which may well be in the middle of the night. GRL makes no suggestion of a curfew.
GRL's employment numbers are inflated. Yancoal has been unable to achieve GRL's claim. In their recently published career choices, no Gloucester school leaver chose coal mining or support.
GRL is clearly wrong to state that its employees will spend the greatest part of their income in Gloucester. According to the ABS most disposable income is committed to non local services and government payments.
GRL have not costed the current or prospective losses in existing businesses.
Unoccupied properties on Gloucester's residential estates near the mine area are specifically excluded from GRL's impacts. The unoccupied properties are rendered unsalable. The potential new residents and their continuous contribution to the economy through building and furnishing businesses and their daily living expenditure are not taken into account - as a loss to the community.
Lifestyle retirements are net importers of income and prosperity that have not been acknowledged in GRL's EIS.
House values for nearby residents have already dropped - making it impossible for them to leave to the same level of accommodation and amenity. Some of them with mortgages, fixed income and no government representation, are trapped.
Gloucester has a bright future without the `help' of GRL. That bright future will be damaged by GRL and potentially it will suffer very long term impairment as businesses that leave are unlikely to return to a Gloucester whose `brand' has changed.
I know of one company employing a significant number of staff that is already considering whether it should stay.
GRL will create more visibility barriers along the Bucketts Way if they are not stopped now.
How do GRL and AGL settle their differences - should GRL blast within 1km of AGL's wells? Do they decide what's best - or does government have a role to play?
GRL has falsely claimed that its mine will rescue Gloucester from declining population and declining employment when these factors are clearly not tends or problematic.
There is no provision for GRL to stop water consumption in drought.
When the coal price drops GRL's employment figures become unemployment figures.
GRL's ex Director and Geologist Dr Vic Tadros may have had conflicted interests as he was Minerals and Energy's Acting Principal Geologist and studied this basin with Julie Maloney before, or when, taking up his role with GRL.
The Planning Department overlooked background checks on Tadros' Managing Director Brian Wingett.
How is that GRL has successfully renewed its exploration licences again - enabling exploration for a period of 9 years - against the Gloucester community's interests (and certainly not fulfilling the state's desire for early production)?
What happens when GRL fails due to coal price and cannot fully rehabilitate? (Coal price may easily fall over the next 20 years due to renewables take-up, new technology and Mongolia's coal fields due for production by 2015.)
There are no specific safeguards are in place to insulate Gloucester from the effects of a quite predictable coal downturn.
There is no provision to re-establish the Gloucester Brand. What funds are set aside for this? What financial provision is GRL expected to make for this?
There is no specifically identified provision for health impacts from the permanent exposure of a community for 20 years. This should be clearly identified now - given the latest medical research that coal mining and its diesel consumption produce carcinogens that have safe minimum level. (This issue may well arise to parallel the Wittenoom asbestos problem. Medical advice was to control the dust. It was throughout the town when actions slowly gathered pace and finally due to poor financial performance and health issue it closed. The town closed later due to the dust.) The evidence is already available to decision makers.
GRL has chosen to seek approval to mine in a closely-settled-area (CSA) and beside a peaceful tourist township and floodplain. This was a high risk strategy well known to its executives and backers. Its backers and executives were personally involved in the failed Margaret River Vasse Coal project. That project which was further from town, underground, and had a smaller footprint, was rejected outright.
GRL separated stage 2 from the project, demonstrating their knowledge that they are doing wrong to this community.
A very few men stand to profit while inflicting the heavy and enduring costs of an open-cut coal mine on Gloucester Shire's residents. These men have no loyalty to Gloucester - nor any interest in the long term outcomes they precipitate.
Deception is a key feature of GRL's strategy. That deception is essential to its success for one reason: GRL has chosen to build a mine in a Closely Settled Area, on floodplain, beside Gloucester. These are just some of the dimensions of their deception:
secret land deals under a variety names with `non-disclosure' clauses
choosing Rocky Hill as the name for a floodplain mine;
dividing its mining operation into stage one and stage two to defer dealing with the true scale of impacts until a foothold has been achieved;
using `averaging' and inapt data to avoid identifying the real impacts;
denial of its desires to mine all economic coal in all its exploration leases;
asserting there will be no void in the rehabilitated site despite the evidence;
omitting a key issue from the Executive Brief - the strength of long term community and Shire Council opposition - despite Key Insights report of greater than 80% opposition and just 10% `supportive';
not reporting the net economic benefit/cost despite this being a DG requirement;
introducing into the EIS the potential for tacit approval to expand (ie the EIS contains: provision for stage 2 but no detail; provision for 24 hour operations but no detail; provision for 21 years duration but limiting its scope to 14 years);
using language that suggests that GRL's prime interest is in helping the community (despite community opposition). The same names Polwarth, Ross, Ross Family Trust, AMCI were involved in the unsuccessful Vasse Coal proposal to open Margaret River to underground coal mining. (Vasse Coal used the same goal there - to help the community - despite community opposition.)
surprising nonsense - public statements to the effect that without GRL Gloucester population leakage would be problematic. Two other reports in the past decade indicate sustained growth without GRL.
public statements that simply refuse to deal with community concerns and push a very thin line of argument which is plainly wrong: there will be no net benefit to the community; there will be enduring job losses.
The EIS is unprofessional and misleading - a document of advocacy rather than objective assessment.
A disingenuous argument pervades the EIS. The defined mine cannot sustain itself.
It is clear from all GRL's actions and its EIS that its application has been tailored to understate and omit costs/impacts and risks, and massively overstate so called benefits:
Despite the Director-General's requirement to show the net economic benefits, GRL fails to note any downside.
Regardless of what size makes the mine viable, the lie is that the project will not deliver net benefit to the state economy, local economy or local employment. For every increase in scale, every expansion, every additional train or truck or hours of operation in a closely settled area - and floodplains - and enclosed valley - carries impacts beyond the scope of GRL's open-cut coal mining economics. GRIP's quite forensic study of the EIS proves that. GRIP has presented all their evidence and calculations - with industry advice/information.
There is no Australian need for GRL's coal. No net benefit will accrue to the State. The proposal is opposed by more than 80% of the Gloucester community. There is no Gloucester Shire need for GRL's highly destructive coal mining in this closely-settled area: not economic; not employment; not new business. By any measure, it is against the `greater good'.
The EIS is at best a sham. At worst it is a fraudulent attempt to do the unconscionable.


ICAC, PROBITY AND NEED TO STOP GRL
ICAC recently uncovered systemic issues in government process and probity. Gloucester did not figure in that inquiry. But the main figure, Minister MacDonald, directly presided over the delivery of Gloucester to GRL. He did so without explanation - and it is entirely possible that he did so to fit with or cover his `small mining company' decisions elsewhere.

Disgraced Minister MacDonald, senior officials, and a government bereft of dignity and principle gave GRL its foothold. A seriously compromised system approved and then defended GRL, dismissed community representations, and renewed exploration licences that principle and sanity would have denied.

At a different time with an honourable government, exploration within or near closely settled areas would not have been entertained - regardless of the existence or otherwise of `ring-fencing'.
GRL has no self-regulating conscience. Successive MD statements make it clear that GRL will not stop of its own accord. It will not stop because the people of Gloucester don't want it and it will not stop because of its adverse impacts. It does not recognise health impacts. It will not pay for the roads which are already badly damaged and below heavy vehicle design standards. Only government can stop GRL. It should be stopped while Gloucester is still Gloucester.

GRL will not create jobs. It has already eliminated employment for those people it has displaced on the farms it coercively bought. Instead it will create an alternative place to work for people who are already employed. Because it will offer more money, it will draw people from valued community service businesses. The much vaunted `additional employees' argument used to try to win support in the community will come at the expense of Gloucester services and businesses. Coastal populations will also supply workers which GRL will describe as `locals' as does Yancoal.

At this point, Government under its duty of care, can seek full disclosure of GRL's expansion aspirations and define distinct constraints that protect Gloucester Valley's feel, amenity, scenic qualities and community health.

Of course GRL should not be allowed to mine here. But if approval were given, it should be for GRL's current design as it stands - with no prospect of future expansions or modifications and revocation of its other ELs which in turn must be zoned clearly to exclude mining.


RECOMMENDATIONS
Demand GRL disclose its full development scale or aspirations - and apply full life-cycle cost benefit analysis.
Require that analysis to include provision for contamination, rehabilitation failure, dust pollution, risks from enduring water catchment pollution flumes, heavy metals and BTEX releases, voids filled with salts and contaminated washery sludge, government's social/industry adjustment costs for Gloucester post Rocky Hill, enduring health budget impact, and health, social and qualitative impacts.
`Ring fence' Gloucester community, including established estates, from GRL or any other damaging development.
Declare the Bucketts Way and the scenic and heritage values of Gloucester protected from GRL and all future damaging development.
Protect the health amenity and peace of Gloucester Shire communities from GRL and all future damaging developments.
Introduce mandatory biennial performance improvement targets for all consent conditions.
Examine the full circumstances under which GRL's initial exploration applications and their renewals were approved.
Cancel all three of GRL's Exploration licences.
Refuse unconditionally GRL's application.

Dear Sir/ Madam,
I am writing a submission against the open cut coal mine proposed immediately adjacent to my local town of Gloucester. It is known as Rocky Hill, though I am unsure why as it will more likely be a rocky hole, right on the town's doorstep. The health implications alone should prevent this mine going ahead and I would urge the minister to prevent it doing so. Surely clean air and water is an inalienable right and the government should prepare for legal action if it allows this mine to proceed. I am vehemently against such an outcome.
Yours Sincerely,
Cameron Laurie

See attached PDF

I support this mine as it will open more job in the community and help the town. It will be a good opportunity that will open the community up.