To the Honourable Minister for Planning, Mr Brad Hazzard, MP,

I attended the recent meeting with the Breeza community at Breeza Community Hall on Friday May 3rd, and it was apparent that many community members feel some of the information provided in the EIS, and the accompanying graphics are a falsification of the nature of the Breeza community, a community based around agricultural production. Many community members felt the employment data presented in the EIS, was exaggerated and community members are proud of their current employment including with Carroll Cotton Gin, driving trucks which transport cotton from farm to gins and as farm-workers.

The recent Cotton Australia report into cotton production and its inability
to co-exist in any way with open- cut coal mining was timely and relevant to this project. Laser-levelled and capitally-improved land, for irrigated cotton production cannot live comfortably alongside a project comprised of three open- cut coal mines, and the clearing of 4000 ha of vegetation and subsequent subsidence that occurs, the types of subsidence that occurs, have been well articulated elsewhere.

It is clearly in complete contradiction to sustainable, economic agriculture.

I wish to conclude my submission here.

Angela Martin
Sent from my iPhone

To the Honourable Minister for Planning, Mr Brad Hazzard, MP,

In a broad, global context we are still fighting for some balance in the `land-grabbing' phenomenon that is beginning to take place closer to home. Transnational acquisitions of land have been happening for a long period of time, however with Shenhua's acquisition of agricultural land at Watermark it has brought home the danger in allowing any land to be purchasable at a price. I recently attended one of Shenhua's community consultations regarding their EIS, and it was very good to hear from local farmers who adjoin the land that is currently being leased-back from Shenhua, of their experience of how it has affected their communities operation, right down to the absence of a local fire truck to fight fires, a couple of farmers noted that the land does not appear to be being managed well for noxious weeds and pests, and I have taken these points on board as I prepare a submission in conjunction with some of the information received from Caroona Coal Action Groups consultant, Earth Systems.

I think neighbours of Shenhua's in the Watermark, Breeza area are experiencing a heightened sense of isolation, since there are less land-holders to constitute a community. I hope you've had time to pen a short submission to the Minister for Planning, into the EIS on the Breeza Open-cut project. Recently at the ADC Futures Summit in Melbourne, the head of Shenhua Watermark spoke about Chinese investment in Australia and noted that the regulatory environment was getting more difficult, he used the term "It's been shifting beneath our feet".

The fact that the Land and Environment Court recently adjudicated in favour of the community of Bulga-Milbrodale, in the case of the Coal and Allied Warkworth mine (a subsidiary of Rio Tinto) versus the Bulga-Milbrodale Progress Association, is a good sign that the tide is turning, and that the planning process is failing in NSW to account properly for displacement of community and enterprise, and also failing to deliver predictable outcomes. This was the criticism that was levelled at the NSW Government and Minister for Planning Brad Hazzard recently by the CEO of Coal and Allied in Australia.

The fact that companies like AGL in Broke or Santos in Marys Mount or Shenhua in Breeza are at their current stages of the planning process, is a good sign that things have not been `working' in planning and environmental legislation, and government generally for a number of years. Companies will not be able to dodge a due planning process forever, one which takes into account that a degree of economic cohesion only occurs in an industry when you have a critical number of enterprises operating side-by-side. It is this way in agriculture.

Senator Fiona Nash recently sent through a paper published on the `land-grabbing' phenomenon, to the NSW Farmers Economics committee, it highlights that acquisitions by transnationals, be they state-owned or otherwise, could be classified as violating human rights when they reduce the availability of irrigation water or other water in surrounding or downstream farmlands, with the potential of causing water stress, social unrest or poorer water quality. It is still not quantified how much water a foreign government or company actually takes out of the system when they purchase land for development or mining. You would be aware that the Ord-Irrigation Project is proceeding with the Chinese investment of $400 million. We are constantly being told that Chinese investment is warranted in a country that is starving for capital, however because water-resources are finite too, we don't want to end up in a situation like Indonesia, where the volume of total `green water' - that water associated with rain-fed agriculture, and the land associated with it has been surrendered for mining or overseas agricultural investment, placing your own countries production in jeopardy. I'll table the paper authored by Maria Rulli and Antonio Saviori et.al. It was an Italian and US collaboration.

I don't believe there is anyway of ameliorating the damage to surrounding agriculture, water resources, or social cohesion by a project of this scale.

The Environmental Impact Assessment is flawed from the outset, as it seeks to address the total output of greenhouse gas emissions of a project of this scope and size, any person on the street in Gunnedah will tell you that as a country we are desiring to move away from carving up the surface of the earth in our quest to extract fossil fuels. The EIS is a mis-representation of the total impact on global greenhouse gas emissions, and the consequential impact on climate change.

I strongly object to the Environmental Impact Study prepared by Hansen Bailey, for the Shenhua Watermark project, the Australian Koala Foundation have stated ad-finitum that they are opposed to the translocation of koala populations by projects of this nature and the resulting coal dust has a pronounced impact on the health of any remaining koalas, as well as human health, and the offsets that are suggested in the report are not of an equal ecological value as the vegetation that is removed in the process of finalizing the mine-plan.

I endorse the entirety of the contents contained within the NSW Farmers Assocation submission, that was submitted by Danica Leys, on behalf of the policy-team at NSW Farmers. I believe the remarks that the outcomes of the Namoi Water Study are not in-line with Hansen Bailey's own `independent' water management plan are spot-on. The Namoi Water study was undertaken to attempt to model what the likely cumulative impacts of a number of proposed coal-mining and coal seam gas projects would be in their entirety. I think most educated people believe that the impacts upon the floodplain, the Mooki River and the surrounding aquifers, despite what Hansen Bailey suggest, are pronounced and not able to be remedied using technology of any kind. The fact that the disturbance boundary and the mines are separated from the Gunnedah Formation by a small buffer zone, does not mean that there will be no impacts on the shallow aquifers and the Gunnedah Formation. It is highly likely and probable that aquifer recharge and run-off, that is surface water flows, will be impeded significantly by the development.

The Department of the Environment, Sustainability and Communities, the portfolio held by Federal Minister, the Hon Tony Burke, MP, publishes the State of the Environment Report annually, in-line with what would be anticipated under the Environment Protection and Biodiversity Conservation Act (1979), recent reports have studied in-depth carbon in soils, categorizing the different types of carbon in soils, that is carbon that is freely available for plant growth, carbon that is locked into soil particles, long-term carbon, and, it is obvious from this kind of reporting that soils of alluvial floodplains, with high carbon contents should not be used as areas of open-cut coal mining.

I was very happy to see the aboriginal representatives that were in attendance at the meeting in the Breeza Community Hall on Friday May 3rd, 2013. Those aboriginal persons present mentioned that it was impossible to retrieve and re-locate the grinding grooves, present in areas of theWatermark project. In other areas of New South Wales grinding grooves and other aboriginal relics, that are of irreplaceable value have been moved and damaged in the process. It is a damning endichtment on previous governments, both State and Federal that companies have been able to damage and destroy some places of significance and some irreplaceable relics in the process of minerals extraction.



I believe the Breeza community and the wider Gunnedah community have spoken quite categorically in their opposition to this project comprised of three separate open-cut mines producing coal at a rate of 10 million tonnes per annum, Run-of-mine Coal for 30 years. No amount of royalties or taxes will account for the damage to the current community, lifestyle, and amenity benefits of the Breeza community. A community founded on the agricultural industries including cotton production, beef cattle and dryland broadacre cropping.



I wish to conclude my submission here.



Angela Martin

I support the submission of Earth Systems on behalf of the Caroona Coal Action Group (CCAG), of which I am a I am a member, regarding the proposed Shenhua Watermark Coal Mine at Breeza NSW. I have reviewed the Earth Systems submission, and am most concerned about the number of discrepancies, unresolved issues and potential for environmental and social harm as a result of the mine indicated in Shenhua's EIS.

I live on a farm outside a coal exploration or mining licence area, and have been a resident of the Liverpool Plains for 20 years. I have a well developed understanding of the issues raised in both the EIS and Earth Systems submission, having been professionally involved in primary industry and natural resource management all of my working life. This understanding is supported by a strong technical background. My academic qualifications include a Bachelor of Rural Science (Hons), Post Graduate Diploma in Agricultural Economics, Post Graduate Certificate in Sustainable Agriculture and Master of Business Administration (MBA). I am currently enrolled in a PhD.

I was a member of the Namoi Catchment Water Study Stakeholder Advisory Committee, and Shenhua's Community Reference Groups.

At the first meeting of Shenhua's Community Reference Groups, the consultant charged with developing their EIS introduced himself by stating the number of staff-years his company held in gaining EIS approvals. I inferred from this statement that the consultant was more interested in gaining development approval for his client than preparing an independent statement of potential environmental impacts. This concerned me greatly.

In relation to Shenhua's proposed development, issues which particularly concern me include the following, noting that this list is not exhaustive

- disturbance of white box woodland community and other species listed as endangered or threatened under the EPBC Act. I do not believe in this instance that offsets are appropriate.

- the potential aquifer drawdown.
- impacts on the Mooki floodplain which is in close proximity to the proposed mine site.
- impacts on a valued koala population, and the belief that "re-location" (if this is indeed possible) of such a species is morally and ethically acceptable.
- potential contamination of surface and ground water by salt, chemicals and soil sediments
- the likely extensive erosion
- subsidence

In addition to the issues raised by Earth Systems and others, I raise the issue of climate change. I believe it would be irresponsible of the NSW Government to approve this mine, given the resultant carbon emissions. The support of fossil fuels is contributing to irreversible changes to our global environment, and this will have catastrophic consequenses for our social and economic systems in the future, let alone species which cannot defend themselves. This is in conflict with the principles of Ecological Sustainable Development, and the concept of Triple Bottom Line decision making, in which environmental and social costs are truly accounted for.

Disclose reportable donations: I have made no reportable political donations.

Privacy Statement: I have read the Department's Privacy Statement and agree to the Department using my submission in the ways it describes. I understand this includes full publication on the Department's website of my submission, any attachments, and any of my personal information in those documents, and possible supply to third parties such as state agencies, local government and the proponent.



Yours sincerely,
Katrina McDonald

To the Honourable Brad Hazzard, Minister for Planning, NSW,
As a proud member of the Caroona Coal Action Group, I would like to begin by endorsing the findings of Earth Systems, in their assessment of the Environmental Impact Study prepared by Hansen Bailey for Shenhua Group, on the open-cut coal mine project proposed by the proponent in the Watermark area near Breeza.

As a farmer I must contend I find the
entire proposal quite abhorrent, I believe the planning process is skewed towards developments of State Significance, and is failing to properly measure and test cumulative impacts on surrounding agricultural lands, and water quality and quantity issues. I recently read a collaborative research project, written by a couple of Italian and US academics on the concept of transnational acquisitions
Sent from my iPhone

I am a member of Caroona Coal Action Group
I object to the proposed Shenhua Watermark Coal Mine at Breeza NSW. I have reviewed the submission prepared by Earth Systems for the CCAG and am writing in support of the CCAG submission.

I note that not surprisingly the Shenhua EIS has cherrypicked figures and statistics to suit their
Submission some of which have been mentioned in the Earth Systems report . I hope that it is realised many of them elsewhere are somewhat suspect in reality.
If this is an example of the whole EIS then how credible is the Statement?
I am particularly worried about the lack of realism given to the water , from the mine and run off;
And how Shenhua expects to confine it and deal with it especially with the quantities involved and the salt content and what effect this will have on the river Mouki into which any overspill will no doubt go. What will be the effect not only on the aquatic life but the general environs and then down stream to the Namoi and the Darling system.
How can Shenhua guarantee not to interfere with the excellent aquifers ? We fear they will do irrepairable damage to them and subsequently have a direct effect on the farming and other industries and employment beyond. Will they accept their responsibilities and the principle that the perpetrator pays ?. How do you begin to quantify this sort of damage.?
What assurances will be given to restricting mining to the application only ? How often are there subsequent applications extending and abusing the initial permit to the absolute cost to the locals.
Definitions should be agreed before proceeding any further referring to flood plains and deep or shallow aquifers and other very relevant and extremely pertinent fundamentals. If subsequently the mine is sold on with the permit/licence what assurances at law have the public got to confining the mine to the permissions originally granted only ?
This mine is expected to have a 30 year life span (?) WHERE AS ......
Farming should last for ___thousands__ of years always improving production and quality of crops.
This is an almost unique area to Australia. Very good soils, very good climate with adequate reliable rainfall and with very good water for irrigation easily available. Where else can these be found ?
Please don't' destroy such a rare asset in Australia for " a few shekels of coal "
There are plenty of less fertile and less important agricultural areas in the NW of NSW. In years to come will this decision be remembered as Hazzards Folly? Or should that be Harcher's .( Do we want another Mac's Mine Muck up ??)
Please stand up and do what is right for the long term future .

Dear Sir,

Please treat this email as summarising my strong objection to this development after having read the 38 pages of the Earth Systems Report (ESR).

I am a member of the Caroona Coal Action Group. My family company, Winterthur Pty Ltd, owns a property, Bonny Rigg, adjacent to the Warrah Ridge Road at Quirindi.

The ESR discloses so many discrepancies and omissions from the EIS that my overall impression is that Shenhua has treated the preparation of the EIS as an encumbrance (a waste of time) indicating that the company expects that approval for its development is already a foregone conclusion. The chief executive of the company has complained, publicly, of the extensive and detailed Australian environmental considerations (no doubt thinking of his home country of China) which further supports my view.

I draw your attention to the following sections of the ESR which underline that, in the interests of protecting the environment, the whole proposal should be rejected:

3.2. Discrepancy of 2000 ha in the description of the development is quite extraordinary.

3.5. Many gaps in the assessment of the key issues.

3.8. A number of plans relating to the development not provided.

2.2. Drawdown of groundwater to 3.5 additional metres – substantially in excess of previous information provided.

4.4.3. Problems in dealing with, from an environmental point of view, the quantity and quality of site discharge water.

4.4.4. Salinity impacts on the ground and surface waters is most significant.

5.4.7 Management measures. Insufficient information provided.

5.4.8 Insufficient and inconclusive information provided in respect of the justification for the long term impact on agricultural resources and soils.

6.4.1 and 6.4.2. Support documentation not provided for impact assessments.

7.4.3 Assessment to meet requirements of biodiversity offsets not addressed.

8.4.1 Mine closure and remediation – a number of risks that will be faced at that time not addressed.

10.3.1 Aboriginal Archaeology – results of survey unclear.

11.3.1 Waste. The impact of waste generated from the site is not fully addressed.

11.3.2 A number of hazards associated with the proposed use of the site have not been identified or addressed.



Yours sincerely,



E Craig Miller.

Telephone (02) 9498 2969

Attention Director Mining and Industry Projects NSW Government Planning &infrastructure GPO Box 39 Sydney NSW 2001

I wish to make a submission in response to the application by Shenhua Watermark Coal Ltd to apply for a Licence to mine the EL 7223 in the valley known as the Breeza plains on the ridges known as Watermark located southeast of Gunnedah and north west of Quirindi N.S.W. 2343 .Project No.SSD -4975 .My name is Patricia Duddy my husband is Clive Duddy, I reside on the property known as Rossmar Park ,Rossmar Park Road, Caroona 2343 . This property is located to the south of the EL and significant parts of its productive lands will be heavily impacted by the plans laid down in the Hansen and Bailey application to the Government for a mining Licence.Our family conducts a highly productive farming and grazing enterprise,we grow cotton wheat sorghum barley oats beef and produce thoroughbred horses These enterprises have been conducted by this family since the early 1930's and my family settled in the Quipolly district,at the headwaters of the Mooki River in the 1860 ,so any observations of the possible impact of this Developement on this area and it's surrounds does not come from any casual observations .We are also members of the Caroona Coal Action group ,at it's earliest inception have overviewed the Independant review of the environmental Impact Statement for the Watermark Coal Project as presented by Earth Systems , am also a member of the Community Consultative committee for Watermark and am regularly invited to attend presentations on behalf of BHP Billition at their community consultations .our understanding of the coal project has been exposed to the anticipated plans by the Shenhua staff since the very early days and unfortunately our original disquiet has not be placated. Now though with the advent of the water study ,a jointly funded Commonwealth Industry project ,the cumulative impacts of the proposed projects in the Namoi Catchment Area have not only been identified but also regarded as being permanently detrimental. We have significant underground and surface waters Namely the Mooki River Gooran Lake Native Dog Creek Watermark Gully Yarraman Overflow ,all of which provide significant overland flows which contribute to the extraordinary productivity of our alluvial black soils .the location of a significant opencut mine which is mooted to be active for at least thirty years,providing 10Mtpa ROM for thirty years progressive rehabilitation of ALL DISTURBED AREAS closure of feeder agricultural roads for mine access rail loading and other facilities close proximity to the village of Breeza surrounded by some of the most highly productive and fertile lands certainly creates a Developement with all the warning flashing lights .How can this Developement comply with all the relevant environmental laws and policies when they themselves cannot clearly state what they will do to satisfy water quality management .This surface water that we regard so highly and they call dirty water if contaminated and I say if when we know it is when , is one of the arteries of the renewable character of our valley,to have it impacted, contaminated, reduced, is of such significance to the productivity and equity of the land and landowners,quite apart from those who reside in the towns and villages. The watermark project comments on adverse impacts on quality of surface runoff, from disturbed areas,adverse impacts on downstream water quality, loss of catchment areas interference to flood flow ,need for extra water to meet with requirements of mining ,capturing of runoff to on site storage all these requirements in an already stretched water environment. The areas of high impact zone 3 , 7 , 8 in the immediate vicinity and with at least 35 bores predicted to experience groundwater reduction within 10 Klm of the project and four adjacent to the southwest at least one metre to two metre ,the areas impacted just get more and more and with an anticipated void in the final stage will it just act like a big bath plug and keep on drawing water from the rest of the valley water? Water is our life blood it comes in big hits, it comes in abnormal events it comes in such quantities it makes light of high wall of exposed scree ,buffer zones and 150 meters of black soil protection .A 65.7 t p.a of salt introduced into our environment is an interesting side effect,a new industry perhaps.There appeared little understanding of the peculiar weather events that allow us to grow two crops a year and also include sorghum as well as wheat into our farming activities because we are subjected to both the influence of the southern rains in the winter and thenorthern monsoons in summer,these events while providing dexterity in production also come with enormous overland flows which would stress the containment dams considerably it is interesting to see where a levee is proposed to prevent flooding of the mine ,reduce the storage of the Mooki River floodplainby 235 ml
> And by reason of the location of the overburden in the disturbance boundary immediately impact on the NEVER TO BE ENTERED flood plain. Whatever you look at in the E.I.S there is no guarantee that either the water, be it ground or alluvial, be available in either the quantity or quality of its present form, not be impacted,damaged reduced or interfered with ,the conduits in which it travels naturally will be reduced, realigned and in some cases become inaccessable as they become absorbed by the mine surely in this day and age an antiquated method of energy extraction totally unrenewable situated in an enviable agricultural zone, should not be given the green light . To take the overview, air to be damaged. Acoustics impacted. Blasting unequivicable damage, visual try flying over it in another ten years,Ecological creatures probably never even named because of it unique and ancient character,Koala Plan ship them out, National Environmental significance ,an ancient unique ridge rising out of a floodplain providing shelter, climate, alternate agricultural pursuits by reason of its geography and terrain ,Aboriginal ArchaeologyValuesheritage and impacts ,significant finds ancient beyond belief, to be REMOVED and RELOCATED.Historic Heritage Impact. At least 45 families already paid out and relocated,an endangered species to be declared farming and grazing families so much for inter generational equity.Groundwater impacts ,considerable and irreversible enough to change the agricultural activities of the immediate surrounds, soils and land, soils certainly never to be the same again ,rehabilitated, unlikely ,a small tree does not house a rare bat, a sulfur crested cockatoo population ,etc, it takes eons of time to build the environment back again ,over sixty five species of birds on this ridge alone,what is on the watermark ? Agricultural Impact, try the busy road syndrome, 600 extra workforce on the naive roads we call highways,large numbers on shift work in large pop up villages on the outskirts of our settled populations.We are a settled people undertaking settled activities in an agricultural environment of enormous productivity ,we have good soils, quality water beautiful landscape,rare and endangered species,both flora and faunaWe as the Liverpool Plains have an iconic presence which with the advent of an open cut mine of the proportion envisaged in the watermark application will be changed and damaged in perpetuity.The Minister who made this decision is now in disgrace, do not let the ongoing saga of the two mines and their exploration Licences and promises of further bounty to the State if they move to the granting of a mining Licence be a further reprehensible step in this ongoing sorry tale of the watermark,the Mooki and the Liverpool Plains

Patricia Duddy Rossmar Park,
Rossmar Park Road Caroona 2343 N.S.W. 9 th May.2013 ..

I am a member of the Caroona Coal Action Group. I object to the proposed Shenhua Watermark Coal Mine at Breeza NSW. I have reviewed the submission prepared by Earth Systems for the Caroona Coal Action Group (CCAG) and I am writing in support of the CCAG submission.

I am a member of the Caroona Coal Action Group. I object to the proposed Shenhua Watermark Coal Mine at Breeza NSW. I have reviewed the submission prepared by Earth Systems for the Caroona Coal Action Group (CCAG) and I am writing in support of the CCAG submission.