As a small local business, the current mine provides us with numerous works through their subcontractors.

These works are very beneficial to our business as it allows us to keep ticking over and put that money earned back into the local economy via the purchasing of goods.

Every little bit of income within a small business counts. This is especially the case during periods of economic downturn where the larger companies you work with are predominantly the ones who are able to keep spending.

This project supports local business, employment and the prosperity of our region. It would be detrimental to the community near and far if the Dendrobium project did not get approval. Having lived in the region my entire life, I am very aware that we are proud of our region and the rich coal mining history that makes up our community. This project is essential to continue our way of life in the Illawarra, and this company supports many businesses and the community through local projects.

Mining makes a significant contribution to the local Illawarra area.
South32 directly employ 1,800 people and are the main supplier to the Port Kembla Steelworks.
Coal is the State’s largest single source of export revenue and the industry employs some 25,000 people across NSW.
The extension of the Dendrobium operation will provide the following;
• Supporting 500 full time operational jobs
• Create 200 additional jobs during construction
• A$2.8 billion net economic benefit to NSW
• A$1.1 billion net economic benefit to the Illawarra
• Generate A$714 million in rates, royalties and taxes

Australia's largest steel production facility, BlueScope's Port Kembla Steelworks, consumes over 3 million tonnes of coal per year throughout its steelmaking processes. Over 90% of their coal is sourced from local underground coal mines.
South32 is the primary supplier of steelmaking coal to BlueScope's Port Kembla Steelworks

The Dendrobium Mine site produce high-quality metallurgical coal, much of which goes on to the Illawarra steelworks, supporting local manufacturing and regional jobs. To remove Dendrobium mine will mean removing our steel industry from the Illawarra, which will in turn, deny the Illawarra of thousands of jobs and millions of dollars of locally spent projects for the community to benefit from. This project has my full support to give the Illawarra a competitive future.

The project should be approved based on:
1) Economic benefit to the region.
2) The coal is prodominately used for steelmaking in which there is no current economically viable alternatives.
3) Relatively low environmental impact.

This project will help to support the Illawarra economy. Domestic and international requirements for steel are not diminishing and mining metallurgical coal in Australia is a safer and more sustainable option than most other parts of the world.

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.

The Dendrobium Mine Extension Project proposes 30 years of longwall mining in the water catchment for Wollongong, Macarthur and Sydney. It will result in damage and loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs[i]. Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. The proposed mining is in the protected “Special Areas” of the water catchment upon which 5 million people rely for drinking water. We are in drought, paying for desalinated water and our dam levels are below 50% and yet the Dendrobium proposal has the highest water loss of any mine operating in the Greater Sydney Water Catchment area.
This project is not in the public interest; it is in the wrong place at the wrong time. It would be reckless and immoral for the Department of Planning to support this expansion.

The proposal will result in significant quantities of greenhouse gas emissions

The proposal is estimated to create up to 23.7 million tonnes of CO2e in the production stage and 237 million tonnes in the transport and consumption of the coal produced. This brings the total emissions to between 256 million and 260.7 million tonnes of CO2e for the life of the project[ii].

The current climate emergency means it is no longer morally acceptable for the NSW government to support projects that will severely negatively impact its capacity to meet greenhouse gas reduction targets. The Rocky Hill case supported climate responsibility in its judgement against the Rocky Hill mine, citing the mining SEPP Clause 14 (2): “... the consent authority must consider an assessment of the greenhouse gas emissions (including downstream emissions) of the development.”[iii]

To put the volume of emissions in context, the federal government estimates Australia’s greenhouse gas emissions for the year to December 2018 as 538.2 million tonnes[iv]. Thus approval of this mine would lock in emissions over the life of the project the equivalent of 48% of the 2018 annual emissions for all of Australia.

Annually it would add an average of 8.69 million tonnes per annum (260.7 million tonnes over 30 years) of CO2e to the atmosphere[v]. This is comparable to 1.6% of Australia’s current annual emissions.

South 32’s brinkmanship should not compromise public interest

South 32 has said that if this proposal is not approved, it will spell the end for the Port Kembla Steelworks and the Port Kembla Coal Terminal. This is misleading and unhelpful to understanding the public interest in relation to this coal mine.

There are still 11 years of mining at Dendrobium under current approvals (for area 3A and 3B) and South 32 operates other coal mines in the region. South 32 is only selling one third of Dendrobium’s coal to BHP for use in Port Kembla Steelworks. It is exporting the other two thirds.

Bluescope Steel’s Port Kembla steelworks declined to confirm that the steelworks would collapse if the proposed Dendrobium expansion does not go ahead[vi], so we have to question the truth and motivation for this brinkmanship.

30 year’s of mining is too long

South 32 is seeking approval for 30 years of mining at Dendrobium. This is far too long. Increasing population pressure on water resources and impacts of climate change mean that it would be reckless and irresponsible for the New South Wales Department of Planning to support a 30 year approval.

South 32 has not provided alternatives to this aggressive and destructive mining proposal

The proposal comprises an aggressive plan for twenty one 305 meter wide longwall panels over 30 years. It provides no alternatives to this destructive proposal, a proposal which poses unacceptable risks to the Greater Sydney Water Catchment Special Areas.

Offsets do not compensate for mining-induced destruction of catchment land and ecosystems

South 32‘s proposal to offset catchment land and ecological communities that have been irreparably damaged by mining is not in the public interest; truly like-for-like offsets are rare. Furthermore, there is no “equivalent” land that could compensate for damaged and compromised water catchment.

Mining induced subsidence will damage the watercourses and swamps that feed our drinking water reservoirs

South 32 predicts that it’s 305 meter wide long wall panels may result in subsidence of 2m to 2.45m[vii]. Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative[viii].

The mining and associated subsidence will also cause cracking of the land on the surface – including rivers, creeks, smaller watercourses and swamps that feed our drinking water reservoirs – and subsequent water loss to the catchment.

No level of damage is acceptable to the Special Areas. It would be immoral for the NSW Department of planning to support this level of destruction in Greater Sydney’s water catchment.

Billions of litres of water will be lost from Greater Sydney’s Water Catchment

The proposed mining is just 300m from Avon Reservoir and 630m from Cordeaux Reservoir[ix]. The mining will cause loss of water from water courses and swamps that feed the reservoirs.

Water loss from the catchment due to Dendrobium’s mining will increase over the coming years, with surface water loss expected to peak at 27.6 ML per day in the year 2035[x].

Consultants estimate that up to 9,500 Megalitres[xi] (ML – million litres) of surface and ground water will flow into the mines each year, which is the equivalent to the annual water usage of 123,940 residents of Greater Sydney[xii].


I ask that you reject this application from Illawarra Coal and commence a process to close the mine at Dendrobium permanently.

Thank you for considering this submission.

Regards
Stephen Spencer

[i] Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[ii] Environmental Assessment Part 2, Section 6, pp 150 – 151 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[iii] Gloucester Resources Limited v Minister for Planning [2019] NSWLEC 7, Item 491, accessed at:
https://www.caselaw.nsw.gov.au/decision/5c59012ce4b02a5a800be47f#_Toc431203
[iv] http://www.environment.gov.au/climate-change/climate-science-data/greenhouse-gas-measurement/publications/quarterly-update-australias-nggi-dec-2018
[v] Environmental Assessment Part 2, Section 6, pp 150 – 151, op cit
[vi] https://www.illawarramercury.com.au/story/6295531/bluescope-wont-say-dendrobium-closure-could-finish-steelworks/
[vii] Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[viii] Ibid
[ix] Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[x] Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[xi] ibid, p 111
[xii] Based on an average daily water usage for Sydney residents of 210 litres. Source:
https://theconversation.com/why-sydney-residents-use-30-more-water-per-day-than-melburnians-117656

SUBMISSION ON THE DENDROBIUM MINE EXTENSION SSD-8194

Illawarra Coal’s Proposed Mine Extension for Dendrobium:

We object to Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194. TEC was one of the first groups some years ago, to sound the alarm about the adverse water catchment impacts of longwall mining as cracks began appearing in streams and valley sides. Unfortunately our predictions have to come to fruition with clear evidence of loss of water flows and the failure of ‘monitoring’ (the key strategy) to improve outcomes.

The Dendrobium Mine Extension Project proposes 30 years of longwall mining in the water catchment for Wollongong, Macarthur and Sydney. It will result in damage and loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs .
Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment.

We understand the Dendrobium project has the highest water loss of any mine operating in the Greater Sydney Water Catchment area. In the era of drought and a growing population, Sydney and the Illawarra can ill afford to further damage their water catchments.

There are still 11 years of mining at Dendrobium under current approvals (for areas 3A and 3B) and South 32 operates other coal mines in the region. South 32 is selling only one third of Dendrobium’s coal to BHP for use in Port Kembla Steelworks. It is exporting the other two thirds. Bluescope Steel’s Port Kembla steelworks declined to confirm that the steelworks would collapse if the proposed Dendrobium expansion does not go ahead.

South 32‘s proposal to offset catchment land and ecological communities that have been irreparably damaged by mining is not a genuine measure to preserve the integrity of the catchment. While we have criticism of loose offset policies because they do not provide ‘like for like’ – the situation is even more pronounced as the lost water and wildlife habitat can’t be found elsewhere.

The 2016 Audit of the Sydney Drinking Water Catchment has numerous insights into damaged caused by aggressive longwall mining:

“The auditors found that there was reduced water availability across the Catchment in 2013-16 compared to the previous audit period and the overall total surface water extraction has increased since the previous audit periods”. (p13)
“The available data indicates that there has been a decline in the extent and condition of wetlands in some areas of the Catchment and efforts to rehabilitate wetlands that were impacted by longwall mining have been unsuccessful to date”. (p14)

The proposed mining is just 300m from Avon Reservoir and 630m from Cordeaux Reservoir . The mining will cause loss of water from water courses and swamps that feed the reservoirs. Water loss from the catchment due to Dendrobium’s mining will increase over the coming years, with surface water loss expected to peak at 27.6 ML per day in the year 2035 .

Consultants estimate that up to 9,500 Megalitres (ML – million litres) of surface and ground water will flow into the mines each year, which is the equivalent to the annual water usage of 123,940 residents of Greater Sydney .

This impact is unacceptable. We note that no alternative mine layout options have been presented. In our view this indicates a company with no regard for environmental impacts, hoping to push through a very damaging and long term mine layout. Such behaviour should not be rewarded with destruction of essential catchment values.

Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
https://www.illawarramercury.com.au/story/6295531/bluescope-wont-say-dendrobium-closure-could-finish-steelworks/
Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
ibid, p 111
Based on an average daily water usage for Sydney residents of 210 litres. Source:
https://theconversation.com/why-sydney-residents-use-30-more-water-per-day-than-melburnians-117656

I agree with the proposal.

Our View on the extending the life of mining operations at Dendrobium;
• Supporting 500 full time operational jobs
• Create 200 additional jobs during construction
• A$2.8 billion net economic benefit to NSW
• A$1.1 billion net economic benefit to the Illawarra
• Generate A$714 million in rates, royalties and taxes
• Continue the supply of high-quality metallurgical coal for steelmaking to our local and international customers.