As shown by numerous research in Australia and overseas longwall mining is a threat to groundwater. Groundwater is a hugely valuable asset that is a foundation element in the ecological balance in our dry country. To risk underground aquifers through short term vision for one-off profits that are of negligible value long term is political stupidity. We strongly protest against any further mining rights being granted for Preliminary Works Project Mod 1 - Longwalls 4 and 5.

My organisation objects very strongly to any longwall project in drinking water catchments, and particularly under or near any streams first order and above and all upland swamps. This proposal will impact on upland swamps and streams in a Sydney Water Catchmnet Area. This assessment process should be guided by the precedents of the Planning Assessment Commission findings of the Bulli Seam Operation. Notably it found it is no longer acceptible to do anything more than negligible damage to pristine water supply systems, that precaution should be applied and the value of water on balance to society can outweigh the profits forgone, by leaving the coal resource in the ground. Since this PAC finding Upland Swamps on the Woronora Plateau have been declared an Endangered Ecological Community and longwall mining is recognised as a Key Threatening Processto them. We believe a clear position is emerging in the community, they are expressing a valuing of drinking water over coal exploitaion. It has been demonstrated many times in the Southern Coalfield, that longwall mining indisputably damages swamps and streams (Flat Dog Swamp, Waratah Rivulet, Cataract River and the Georges River). Planning decisions need to reflect community and political realities, on 1/12/11, the Premier of NSW made the statement on 2GB radio, that after a decade of drought, he had no intention of allowing mining or any other activity threaten water resources.

I write to object to the acceptance of this proposal as a modification to the Preliminary Works Project MP 10_0046. The extent and impacts of the proposed additions to the Preliminary Works Project, reflected in the increased coal volumes and the use of documentation from the (withdrawn) expansion project, make it clear that this proposal cannot sensibly be regarded as simply a modification to the Preliminary Works project. Gujarat NRE (GNRE) is attempting to incrementally establish their expansion project.
Given its errors and omissions, the Environmental Assessment Report (EA) for the current proposal is unacceptably misleading and confusing. That it has been released to the public reflects poorly on the Department of Planning and Infrastructure (DoPI). Furthermore, the DoPI failed to identify and act upon a number of non-compliance matters and it was left to community members to point out the failures in a series of complaints. While the DoPI clearly goes out of its way to accommodate the interests of the proponent, it seems it acts on the concerns of the public with great reluctance. The EA and its associated documentation contain a large amount of material for which the general public were given only three weeks to respond. Requests for an extension to the public comment period were refused
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I also strongly object to the proposal for the additional reasons given below.
Longwall mining under the Sydney Water Catchment Area poses unacceptable risks to our water supply
The extraction of coal from Longwalls 4 and 5 will cause subsidence within an area that includes Cataract Creek and several upland swamps. Cataract Creek has been recognised by the Planning Assessment Commission (PAC) as having "highly significant values" making it "worthy of protection" (Bulli Seam Operations report, 2010). Subsidence impacts on swamps, surface waters and groundwater has been described in detail in the Southern Coalfield Inquiry report and the PAC reports for the Metropolitan Coal and Bulli Seam Operations (BSO) projects. These reports recognise the importance of swamps both as water stores and filters, and as biodiversity pools of very high conservation value. I note with alarm that the May 2012 end of panel report for Longwall 7 in Dendrobium Area 3A reports serious impacts on swamps 12, 15b and 16. The evidence that swamps cannot be safely undermined is overwhelming. Remediation of swamps is not possible and there are no examples of `self-healing'.
Swamps CRHS1, CCHS3 and CCHS4 have special significance status under DECCW (now OEH) 2011 draft guidelines, and CCHS3 and CCHS4 include rare Tea-Tree communities. Recommendation 18 of the Metropolitan Coal PAC report includes the following; "swamps of special significance will be protected from negative environmental consequences". Aboriginal site 52-3-0322 is located on the edge of CRHS1 and Aboriginal site 52-3-0320 is on the edge of CCHS3. CCHS3 and CCHS4 overly Longwall 5 and CRHS1 is within the subsidence zone of Longwall 5. Approving Longwalls 4 and 5 would approve the loss of these swamps.

Two first order streams join together directly over Longwall 5 to form a second order tributary to Cataract Creek; these streams will be severely impacted by the subsidence over Longwall 5. There is also a first order stream that appears to commence over or at the edge of Longwall 5. Low order streams play a vital role in connecting upland swamps to higher order streams.

Subsidence, increased strata permeability and strata depressurisation risks redirection and loss of surface and ground water from the Cataract catchment, as the Sydney Catchment Authority believes has occurred as a result of damage to the Waratah Rivulet. Recent work by Professor Philip Pells (Thirlemere Lakes report and addenda, and research accepted for publication in Australian Geomechanics) shows that the Bald Hill claystone layer cannot be counted on to protect surface and near surface waters from depressurisation and water loss.
In Appendix E Pells cites examples highlighting the uncertain nature of subsidence prediction. The severe damage to two kilometres of the Waratah Rivulet provides another example of modelling and prediction failure. The widths of the longwalls that caused the catastrophic damage to the Waratah Rivulet were much the same as the width of Longwalls 4 and 5. Compounding this uncertainty, there appears to be little precedent for multi-seam mining, for which additional subsidence factors of up to 80% have been suggested. Such risks and uncertainties are unacceptable in relation to our water supplies and the need for biodiversity conservation.

The Gujarat EA is misleading in several respects, for instance is suggests that a report by Geoterra (Appendix I) indicates little or no impact to swamps over Longwalls 4 and 5. This report refers specifically to CRHS1, which is not located above the longwalls, and makes no mention of the swamps that are directly over the longwalls. The EA provides no subsidence information, predicted or observed, for Longwall 4. Longwall 5 would reactivate and compound the subsidence of Longwall 4. There appear to be no predictions for valley closure or upsidence, other than a mention of upsidence in CRHS1. Appendix J does not seem to contain monitoring and management plans referred to in the EA. The EA provides essentially no mitigation information. The Metropolitan Special Area is a Schedule 1 area for which SCA consent is required, it is not a Schedule 2 area as the EA suggests. The EA makes no reference to the Sydney Drinking Water SEPP or its embodied Neutral or Beneficial Effect (NorBE) on water test.

The water catchment area is not ours to risk. We have a responsibility to preserve the catchment special area and its underlying land and aquifers undamaged, so that future generations of this area can have the access to drinking water that we have taken for granted in our lifetime.
The location of the Gujarat NRE No. 1 Colliery in a residential area is unacceptable

Residents in the vicinity are exposed to airborne particulates from the colliery's operations. These operations include; a coal stockpile located just 200m from people's homes; a resizing (crushing) facility; an enormous ventilation fan that blasts air from the underground mine directly at homes in West Corrimal; and, trucking of coal past people's homes to Port Kembla Coal Terminal.
Airborne particulates from coal mines are increasingly associated with serious respiratory and other health complaints. In particular, particulates smaller than 2.5 micrometres are known to damage health (NSW Environmental compliance and performance report: Management of dust from coal mine, Dept of Environment, Climate change and water NSW in collaboration with NSW Dept of Planning and Industry and Investment NSW, 2010, p3). This Modification proposal does not even measure or model small particulates. The only air quality monitoring data is from an air quality monitor located in Wollongong 6 kms away. The exposure to particulates of 2.5 microns and less may extend for kilometres and could reasonably be expected to impact on at least 1000 to 2000 homes in the area. It is unacceptable for DoPI and the Government of NSW allow this kind of exposure.

Residents are also exposed to noise pollution from colliery operations and trucking. Countless complaints about noise remain unresolved.

Greenhouse Gas Emissions
The coal seams of the Illawarra are known to be gassy and typically release 10 or more cubic metres of gas for each tonne of extracted coal. The composition of the gas varies from being primarily methane to primarily carbon dioxide. Assuming all of the fugitive gas is carbon dioxide, a considerably weaker greenhouse gas than methane, the coal to be extracted under the current proposal would add 32,000 tonnes of carbon dioxide to the 44,000 tonnes of fugitive carbon dioxide released by the Preliminary Works project. Combustion of the extracted goal would further add 4.8 million tonnes of carbon dioxide emissions to the 6.6 million tonnes of carbon dioxide emitted from combustion of the coal from the Preliminary Works project
GNRE has demonstrated that it does not have the capacity and resources to operate this colliery

Since the Preliminary Works approval GNRE have proved that they are not capable of self-regulation. They have failed to even comply with basic conditions imposed on them by DoPI and the PAC, including: implementing management plans for noise, air quality, greenhouse gas emissions, traffic, biodiversity, water, heritage, and many more areas by the due date of 13 April, 2012 (still outstanding at the end of August 2012). Their implementation of a Community Consultation Committee or approved alternative was months overdue. The EAs account of the so called consultation process is highly misleading.

It appears that extraction of longwall 4 (a component of this Modification application and an activity that is already virtually completed as a result of another very controversial approval process) has been problematic, due to longwall misalignment and that this error has resulted in the contamination of all the extracted coal. Not only is the subsidence much greater than predicted, the extracted coal has little value.

GNRE does not appear to have the resources, or the will to bring the antiquated infrastructure at No. 1 Colliery up to modern standards. Irrespective of the drawbacks or merits of this proposal, GNRE is not an appropriate corporation to extract this coal or operate this colliery.

I recognise that jobs and royalty revenues may be lost with the rejection of this entirely unacceptable proposal. (Although, I note that this modification cuts jobs from the Preliminary works commitment by about 100 jobs or a third of the No.1 Colliery workforce.) However, the broader community interest and inter-generational considerations are of greater significance. The number of jobs at stake is small relative to the regional work force and likewise the royalty revenues are very small relative to annual State and Federal incomes. The value of the natural assets that would be put in harm's way by this proposal cannot be sensibly quantified; they are priceless.

Attention: Director, Mining and Industry Projects
Major Projects Assessment
Department of Planning
GPO Box 39

To whom it may concern,
Objections to Proposal MP 10_0046 - MOD 1


I object to the proposal for the following reasons:

1. Gujarat NRE is attempting to incrementally establish their expansion project for this mine.

- The expansion project proposal was submitted to DoP and then withdrawn.


2. Longwall mining under the Sydney Catchment Area poses unacceptable risks to our water supply

- The Sydney Water Catchment Area is a pristine vital resource is not ours to destroy, it belongs to future generations.
- The extraction of coal from Longwalls 4 and 5 will cause subsidence within an area that includes Cataract Creek and several upland swamps, thereby increasing risk of loss of surface and ground water from the Cataract catchment.
- Cataract Creek has been recognised as having "highly significant value" and being "worthy of protection" (Planning Assessment Commission, Bulli Seam Operations report 2010). Yet one first order stream that starts over or at the edge of Longwall 5, as well as two other primary streams that join together directly over Longwall 5 to form a tributory to Cataract Creek will be severely impacted by the subsidence over Longwall 5.
- Furthermore, recent work by Professor Philip Pells (Thirlmere Lakes report and research accepted for publication in Australian Geomechanics) shows that the Bald Hill claystone layer cannot be relied upon to protect surface and near surface waters from depressurisation and water loss.

3. Mining under swamps and streams poses dangerous risks

- The importance of swamps as water stores and filters, and as biodiversity pools of very high conservation value have been recognised in the Southern Coalfield Inquiry report and the Planning Assessment Commission's report on the Metropolitan Coal and Bulli Seam Operations project. These same reports also describe the negative impact of subsidence on swamps, surface waters and groundwater. Therefore it is alarming that the May2012 end of panel report for Longwall 7 in Dendrobium Area 3A records serious impacts on swamps 12, 15b and 16.
- The Gujarat EA is misleading in several respects, for instance it suggests that a report by Geoterra (Appendix 1) indicates little or no impact to swamps over Longwalls 4 and 5. It also provides no subsidence information and makes no mention of the swamps that would be directly affected.


4. Multi-seam mining has never before been carried out in the fragile Special Areas.

- This expansion adds a third coal seam to be mined and our understanding is that there are no examples of triple seam mining in Australia.

- Gujarat are proposing an experiment of unknown subsidence outcomes - compounded and unpredictable subsidence is likely.


5. The mine entrance is in a residential area and poses serious health and safety risks to residents.

- Gujarat point out the residential area was built around the mine but when Gujarat bought the mine in 2004 the residential area was already established.
- Particulate dust matter is a major concern. There are 80,000 ton stockpiles 200m from residences. 2.5micron dust and smaller is seen as the `new asbestos', linked to respiratory and other illness, and yet the mine will only be monitoring down to 10microns.
- Noise is another major concern. The only exhaust fan from the current seam is 450m from residence. Gujarat's fan at their Wongawilli mine was heard 4kms away.
- The only method for coal transport from site is by truck. Gujarat have operated for eight years and still create noise, dust, speed and vibration problems in the area. Diesel fumes from these trucks are a known carcinogenic.


6. This mine is non-compliant with its DA conditions.

- Department of Planning still haven't approved one of Gujarat`s Management Plans (required to be in place 4mths ago) and yet Gujarat is multi-seam longwalling under the Metropolitan Special Area.


7. Gujarat (and Department Resources and Energy) are having the validity of the Longwall 4 approval challenged in the Land and Environment Court.

8. No proper community consultation has taken place regarding Gujarat's proposed mining expansion and its effects on local residents.

- There has been an extremely limited opportunity for residents to express opinions, including opposition to a proposal from Gujarat to continue an existing longwall (Longwall 4) and develop a new longwall (Longwall 5) in the Metropolitan Special Area just behind Russell Vale.
- The Department of Planning (DoP) has refused to grant an extension of time.

In view of all the above concerns and facts, I repeat my opposition to this proposal.

Yours sincerely,

Diana Covell
Illawarra resident for over 30 years.
30 August 2012

Why does the obvious didsaster have to be fought to be avoided!

How can Government even consider the longwall 4 & 5 proposal at Gujarat???

Look at the long term consequences. Please do not allow to proceed. Money will be spent and wasted but the costs to the environment, and possibly direct negative implications to people will never be recouped.

as attached

there is no clear indication of the development proposal.I could not locate drawings whcih show the extent of the works being proposed.How do you identify what the extent of the existing work is and what is being proposed.A simple plan would provide the most clearest picture.One that does not require extensive details but will communicate the idea quickly.One that will also identify its location and what is surrounding the proposal.Otherwise who would no what was going on?This would also identify if there are additional facilities which would be required due to the works.Given that there may be more employees would certainly impact on the car parking,amenities and traffic issues.Would hours of operation be changed?Most importantly what is the lifespan of he works and what are the rectification procedures once the work has been completed.ie are we looking at work for the next 2,5,20years.Once the work has been completed does the applicant just abandon the work and walk away.Will this result in future environmental issues,site contamination,subsistence,gas buildup etc...Is there a possible future reuse of the facilities.
How does the information supplied on donations impact on this development.(besides being a mandatory requirement)How does it impact on the approval of this development.?Are the council or person approving(assessing) the project providing statements also.ie what religious backround,citizenship etc..The fact that they have been disclosed shows that they are generous people....I imagine.
The environmental statement needs further clarification and elaboration.Have they complied with the current epa requirements?Mining is considered to be part of the australian asset.As such how do we locally benefit ,both long term and short term.Understandably the locals are being employed but is it adding back into the community.Do the resorces stay in australia?etc.Are they employing any apprentices?What does the government provide if any in assistance?......Your written reply to these issues would be welcomed .Your earnest comments and not legal ,planning or political rhetoric would provide some hounest and sincerity in your reply.

I object to the increase in extraction as the impact on the surrounding environment and community will be disastrous in terms of stock piling and transport , major accidents with coal trucks are already a regular occurence on memorial drive , also as any longwall mining under our water catchment area is a distaster waiting to happen . I would rather see our water reserves protected not lost through the greedy actions of foreign mining companies

See attached