To the Planning and Assessment team,

I have a strong objection to this assessment. This expansion will lead
to cumulative impacts that have a huge impact on the local community's
water and air quality.

This proposal to expand coal is out of time, it is time to keep the
coal in the ground in order not to overreach our required action to
prevent the worst of climate change.

I'm worried about pollution in the local river system. The pits now
come close to the edge of the Namoi's alluvial aquifer, the productive
groundwater that underlies the river, and feeds it. The pits will
induce leakage from the alluvial aquifer and the Namoi River itself.

People in the small community of Boggabri believe the community cannot
handle a fifth mine in close proximity to the town. They're concerned
that the scale is too large for the town to cope with.

The mine will be located close to the historically significant
property and homestead "Kurumbede" which was the inspiration for
several Dorothea Mackellar poems including the famous "My Country."
One outbuilding at Kurumbede will be destroyed by mining and the
homestead could suffer from the vibration of blasting and the loss of
scenic value.

The area adjacent to the proposed mine is strategic agricultural land
and the impacts of dust and noise will make this land unliveable and
likely impact the quality of crops grown there.

Please do not proceed with this project through Koala habitat.

No more mines!!

no more fossil fuel expansion

I object to this proposal on a number of grounds. As a mother of two
young Children I have concerns regarding the risk of contamination of
the Namoi River. I do not believe adequate modelling has been done to
mitigate this risk. I have concerns about the koala habitat that is
being put
in jeopardy. Too many of our precious and unique flora and fauna have
been destroyed due to the short sighted actions of corporations. ,
which then demands public money to rectify ie. Animal conservation,
great barrier reef restoration. And lastly, I object to further
investment in coal. Despite knowing full well that globally that coal
is no longer considered best practice and that it is a significant
contributor to global warming, Australia sees the need to continue to
invest in this toxic method. Clean and renewable energy is the only
option if Australia is to preserve its place as one of the most
liveable and well regarded countries on earth. The only reason that
the government choose to continue to deny global warming is greed and
money and that is not a justifiable excuse that I feel comfortable
giving my children as they grow up and I am left explaining the local
and global damage to the environment and to communities that we had
the opportunity to prevent but didn't. Shame on you.

I am Johannes Brits and I have been a resident in Australia for almost
22 years. I love the fauna and flora of this magnificent country and
see it as my duty as a lover of nature to do my upmost to protect it.

I would like to start in objecting to the short timeframe given to
prepare a submission. 42 is not enough time to prepare a proper
response.

The following points have been brought to my attention and need to be
addressed:

COAL RAILWAY AND RAIL LOOP: No modelling has been provided as to the
movement of surface water once the railway is constructed, and there
are 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.

"The final vertical alignment of the rail and the sizing of the
openings (bridges and culverts) will be determined during the detailed
design stage."- Appendix C Flood Assessment, page 38.

This has very serious ramifications for flood risks and makes it
impossible for anyone to make an informed submission.

Further, according 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 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.

Biodiversity - koalas: 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.

Please leave a legacy that you can be proud. This country has an awful
extinction record and damage that has already been done in the pursuit
of fossil fuels are heinous.

Yours sincerely

Johannes Brits

No new coal in NSW please!

I am objecting the proposed new Whitehaven coal-mine on numerous grounds,
both social and environmental. My primary concerns being;
* The horribly damaging impacts of our emissions on the environment -
which have been shown repeatedly to be leading to catastrophic global
climate change. Although I do not live in the region, this is a State
Significant Development, and I am concerned and the loss of
agricultural land
and its implications for food security.

* The disregard for the local community's concerns - not extending the
public exhibition period to 90 days.
Having recently travelled in the region, attended the Boggabri
planning meeting, and spoken at length with locals, I'm unable to see
how this project is in the best interests of the community, or more
broadly the country, given the urgency with which we need to move
towards renewable energy sources. Being relatively young and observing
the unfailingly myopic outlook of our government and mining companies
seriously frightens me. The wellbeing of people and the environment
should be the primary concern when evaluating proposals such as this,
not the speed with which it can be pushed through regardless of
consequences.

The Vickery mine extension Environmental Impact Assessment should be
rejected.

The Vickery mine poses the risk of irreversible or catastrophic harm
to the Namoi River, and its surrounding surface water and groundwater
systems, and the health and well-being of human populations in the
Boggabri region as well as the habitat of the endangered koala and the
Commonwealth-listed Murray Cod.


1. Cumulative impacts have not been considered

The Gunnedah Basin in the vicinity of Boggabri is also the location
for 22 Million Tonnes per Annum of Approved coal mining. The 10 MTPA
proposed Vickery mine is surrounded by other Exploration Licences
which will, in the course of time, be sought to be developed,
including a licence which covers the Vickery State Forest itself.

Vickery Coal Mine Extension is another megamine the scale of Maules
Creek, and in close distance from the Leard Forest Coal Mining
precinct. Yet the EIA does not make any attempt to apply the
Precautionary Principle to its assessment of the cumulative impacts.
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.

2. This is not my full submission

I wish it to be known that my Submission is not complete, due to the
onerously short Public Exhibition period. This means I have not been
able to provide as full as Submission as is called for given the size,
complexity and lack of public awareness of the Vickery Coal mine
extension project. 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.

3. Threats to the town of Boggabri

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.


4. Social impacts of Vickery must be assessed with existing local
mining operations in mind

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.

Health

The Social Impact Assessment does not refer to the growing evidence
about rising bronchial ill-health in Boggabri and Narrabri towns,
reported anecdotally by GPs, and is consistent with health problems in
the Upper Hunter Valley. The reported increase in bronchial
medications has occurred since the time of the Maules Creek mine, and
Boggabri extension. Furthermore 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.

Mental health

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.

Loss of farming families from the region

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.


5. Noise

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. This is well-known to
occur, and is well-documented that CHPPs produce highly disturbing
noise in the 16-25Hertz range. Whitehaven's Maules Creek coal mine has
intractible noise problems at the 50 Hz frequency.

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.

I do not find it credible that the 10 MTPA mine will be quieter than
the 4.5MTPA version that was previously approved in 2015.


6. Coal railway and rail loop

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.

"The final vertical alignment of the rail and the sizing of the
openings (bridges and culverts) will be determined during the detailed
design stage."- Appendix C Flood Assessment, page 38.

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.


7. Biodiversity - koalas

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.


8. Road Transport

The Road Transport Assessment uses survey data collected in 2012 which
is outdated. It predates the establishment of the Maules Creek coal
mine, the extension of the Boggabri and Tarrawonga mines.

There has not been a thorough assessment of road usage or an
up-to-date road traffic audit identifying cumulative impacts.

Road transport since 2012 has grown dramatically, including mine
workers, transportation of heavy plant and equipment, and increased
road haulage of coal from Tarrawonga mine which gained approval
subsequent to 2012. These are not accounted for in the Vickery Road
Transport Assessment.

Since 2010, the Dept of Planning has continued to approve increases in
truck movements on the Highway from 2MTPA to 3MTPA to 4MTPA, rather
than building the Kamillaroi Highway overpass as promised.

I believe there should be no new coal on the Kamillaroi Highway.


9. Not a "fit and proper person"

The Chief Executive officer of Whitehaven Coal, Mr Paul Flynn, does
not have the "character, honesty and integrity" to satisfy s 83(g)
"fit and proper person" test of the Protection of the Environment
Operations Act. Here is the relevant legislation:

45 Matters to be taken into consideration in licensing functions
In exercising its functions under this Chapter, the appropriate
regulatory authority is required to take into consideration such of
the following matters as are of relevance:
...
(f) whether the person concerned is a fit and proper person,
Note.
See section 83 for provisions relating to the determination of whether
a person is a fit and proper person for the purposes of this section.

83 Fit and proper persons
...
(g) if the person is a body corporate, whether, in the opinion of the
appropriate regulatory authority, a director or other person concerned
in the management of the body corporate is of good repute, having
regard to character, honesty and integrity,

At the company's 2017 Annual General meeting the CEO responded to
questions about the Maules Creek high-risk rating, telling
shareholders that the Level 3 risk rating was the result of complaints
from just one nearby landowner who wanted more for his land, which was
an untruth. The Level 3 risk rating was due to a history of noise
exceedances and pollution problems. The CEO's statement was false, and
has been denied by the NSW EPA. I believe that this makes the CEO not
a "fit and proper person" within the definition of the Protection of
the Environment Operations Act 1997 to hold an Environmental
Protection Licence as a Director of Whitehaven Coal, of which Maules
Creek Coal Pty Ltd is a subsidiary. As a result, Whitehaven Coal
should not be granted approval for the Vickery Coal Mine Extension.

In addition, the history of non-compliance of the Maules Creek coal
mine, the fact that Whitehaven has had a Mandatory Noise Audit at
Maules Creek Coal mine, and a Pollution Reduction Program at the
Gunnedah Coal Handling and Processing Plant, I believe that NSW cannot
afford to take the risk.

10. Water trigger

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.


11. Indigenous culture

From the experience of 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.

No new coal!!

Another coal mine? Are we completely losing our minds?
I object to this proposal for a number of reasons:
1. The environmental impact of the mining process itself and the
further detrimental impact when the extracted coal is used. We must,
as a community refuse to continue to expand the sources of pollution
which contribute to global warming.
2. The impact this project will have on the near neighbours.
3. The availability of renewable sources of energy which don't have
all the adverse impacts associated with fossil fuels and their
extraction.
4. The significant degradation of the visual amenity of the region.