Airly Coal Mine Expansion

Re: Airly Mine Extension Project, Application No SSD 5581

To whom it may concern,
I am writing to express my objections to the proposal for an Airly Mine Extension.
We are concerned stake holders as our land and business interests lie on the northern limit of the mine lease, below Genowlan Point. We are a family owned business that currently runs cattle, which rely on native pasture as well as 30 acres of forage crop and water from the Genowlan creek. This undertaking represents significant financial investment.
Our main concerns regarding the extension to the mine lease relate to:
1. Surface Water. Any activities that impact to reduce the availability and quality of water from the Genowlan Creek seriously affects the viability of our business and is unacceptable.
2. Ground water. Of significant concern is the potential impact to our water security resulting from "predicted" impacts to ground water supply and quality. Currently we rely on a bore adjacent to Genowlan Creek to provide water for our cattle.

The Capertee Valley has a long tradition of farming. Whilst this already puts pressure on the available resources, it is unacceptable to think that this proud history and great future should be placed at risk from further and uncertain pressure.

I know you will take our objections into consideration.

Regards, Anthony Fiore

Having reviewed the Airly Extension Project's EIS, I cannot see a valid reason as to why this project should be rejected. There appear to be no associated issues with this project that can't be adequately mitigated.
The Airly Extension Project is critical in supporting the local communities of Capertee, Kandos and Rylstone. I fully support this project.

Due to the recent downsizing of Angus Place Colliery to care and maintenance, in conjunction with previous numerous job losses in the mining industry, and rejection by the State Government of other mining ventures in the region, I felt compelled to forward a submission supporting the Airly Mine Extension Project.

It is of my personal opinion that continuous job losses in the mining industry in our region will have a devastating long-term flow-on effect to the local economy and to the already struggling small businesses and broader communities, (mining and non-mining related) that rely on revenue that is generated from employment in the mining industry. Therefore, employment preservation for the future sustainability and growth of our region is therefore paramount.

For the above reasons, I fully support this project going ahead.

The Airly Project Extension will be fundamental in supporting jobs and families within the broader community.

I support the Airly Project Extension as a large percentage of the Rylstone and Kandos community is dependent on employment there. Without the Airly mine the broader community will suffer.

I reside in the Capertee valley for that portion of my life that is spent in Australia. So I am only able to keep up with the issues while I am at home, which is about half my life.

As I understand it, the mine was given initial EIS permission to open on the basis that it would not include a coal washery. Subsequently it did open and closed again on the basis that the coal was not of sufficient quality to be profitable without a washery.

Part of the reason, I believe, for the current application is to request permission to open a washery. I am firmly opposed to that - they opened on a promise not to do something that I considered very harmful for the valley environment and I do not believe they should be rewarded for their bad commercial decision.

Otherwise, I am very nervous about any activities whatsoever that put at risk the already very delicate water environment of our valley. I have no commercial interest, but I have been involved for some years in activity to regrow habitat for various endangered bird species, particularly the critically threatened regent honeyeater. Changes in the water regimen would have obvious consequences for such activity that would very probably be harmful.

I have other issues, but, having been informed of the enquiry at the last moment, I have had no time to research them or to properly think them through.

Yours faithfully,
Kenneth W Ozanne BA, MSc

I object to this Extension project because it is undermining the area of Airly Genowlan which should be declared World Heritage
due to its unique biodiversity and pagoda landscapes.
Also the original mine proposal was never to go under Mount Genowlan. Centennial has hardly begun to mine under Airly Mtn and now they are greedily trying to get approval for this massive extension.
Damage to this unique landscape is not worth the short term gain to an overseas Company who has shown recently that it is not a good corporate citizen.

Being a former employee I know they are a great company that support the community.
I have family that work for Airly mine and without the mine they would have to relocate, making life harder.
The community values Airly mine and it's low impact mining.

I am a rate payer in the Mid-Western local government area and have a family that supports schools and sporting groups in the area. I would like to make a submission in support of the Airly Mine Extension Project. The Airly Mine Extension Project has been planned and designed in accordance with the objectives of Ecological Sustainable Development (ESD) which are to use, conserve and enhance natural resources. This has been demonstrated in the environmental assessment of the Airly Mine Extension Project by Centennial Coal remaining committed to the principles of ESD and understanding that social, economic and environmental objectives are dependent on each other.

I support the Airly Mine Extension Project as it will help to secure local jobs. I don't work directly in the mining industry but my brother does and my parents own a business in the township of Rylstone where many of the Airly Mine workforce reside. This mine indirectly supports many of the small surrounding towns. Without this extension hundreds of jobs will be at risk including those who work in small businesses in the surrounding towns.

I fully support the Airly Mine Extension Project based upon the following:
As the Manager of Airly Coal Mine I recognise and appreciate the unique opportunity provided by the Airly Project to demonstrate to all stakeholders that an optimal balance between resource recovery and responsible environmental management can be achieved.
Core values shared by employees at Airly include safe, efficient mining practices, ensuring minimal environmental impact, co existing with neighbours and partnering with the community whilst maximising economic opportunity.
The range of extensive technical studies and generated reports covering recognised potential social and environmental impacts include surface subsidence, terrestial ecology, surface and groundwater, heritage, air quality, visual amenity, noise, traffic , bushfire and landuse clearly define the sensitivity of the Airly and Genowlan Mountain complex.
Armed with this knowledge Centennial Coal and in particular Airly employees are committed to operating in accordance with a geotechnically engineered mine design specifying an appropriate pillar system factor of safety calculation for both minimal subsidence impact and long term stability.
Airly has gained significant benefit from employing from our Charbon Mine, experienced and skilled employees familiar with this mining system and processes and who posses an awareness of the importance of maintaining high standards of operational compliance and thereby meeting the expectations of the local community in terms of environmental performance.

To whom it may concern,


RE: Submission on behalf of BirdLife Southern NSW Conservation Subcommittee


BirdLife Australia is Australia's peak bird conservation organisation. We represent over 65,000 supporters across the country. We are dedicated to providing a voice for Australia's birds.

The BirdLife Southern NSW Branch conservation subcommittee thank you for the opportunity to comment on the Planning Assessment Commission (PAC) review of the proposal to extend the operations of the Centennial Coal Airly Mine. Our comments follow below:



1. The Capertee Valley has been designated by BirdLife International as an Important Bird Area (IBA no. 24546). This designation was granted based on the extraordinary diversity of bird species found in the valley; there are at least 216 species present within the IBA. The Project Application Area falls within the Capertee Valley IBA and has potential to impact upon this area.


2. The Capertee Valley is the world's most important breeding area for the Regent Honeyeater which is listed as endangered under the EPBC Act and critically endangered under the TSC Act and internationally under IUCN. A minimum of 55.28 ha of the Project Application Area is considered critical habitat for the species, but the actual area of impact upon Regent Honeyeater habitat is likely to exceed this.


3. The Project Application Area also supports 16 other bird species that are listed as vulnerable on either the TSC Act or EPBC Act.


4. The Project Application Area encompasses a total area of 3,982 ha. While most of this is underground disturbance, surface facilities will permanently remove 39.09 ha of vegetation. This area will not be restored for at least 20 years. This represents a substantial, long-term loss of primary habitat for many endangered bird species.


5. BirdLife commends the decision to avoid removal of mature Box-Gum woodland from proposed Reject Emplacement Area 1 (REA1) by proposing Reject Emplacement Area 2 (REA2). However impacts to threatened bird habitat will not be entirely avoided by doing this. Section 7.1.1 states "The scattered trees are not considered to comprise woodland as their distance and lack of contiguous understorey does not provide sufficient habitat to be considered anything more than dispersed paddock trees." This statement is negligent. It is a known fact that isolated paddock trees contribute some of the most important remaining foraging habitat for the Regent Honeyeater and the TSC Act and EPBC Act listed Endangered Swift Parrot (Lathamus discolor) as well as the Vulnerable honeyeaters, Painted Honeyeater (Grantiella picta) and Black-chinned Honeyeater (Melithreptus gularis gularis). This is because of the abundance of mistletoe (Amyema spp.) and high nectar flows from flowers in these large trees. Paddock trees also tend to occur in lower elevation areas soil nutrients are higher leading to enhanced nectar supply. The loss of any large native paddock trees will have impact to local populations of these threatened species by further depleting scarce food supplies


6. BirdLife is not entirely convinced that the mapping of the vegetation in REA2 is correct. The field inspection by Roget Lembit on the 18th June 2014 is inadequate as it occurred during winter when native grasses have died off and seed-head is mostly undetectable (making grass species diversity and accurate species identification questionable). During the winter months, native herbage has usually dried-out or grazed by herbivores at this time and annual exotics come to dominate. During this period, it is impossible to get an accurate representation of the native grass and herb assemblages in order to determine whether the grassland community qualifies as the Endangered Ecological Community (EEC) "Box-Gum woodland derived native grassland (DNG)". Early spring is the recognised time to undertake surveys of grassland assemblages to determine presence of Box-gum woodland DNG. Failing this, surveys may be conducted in autumn but only after sufficient rains. All other times are inadequate for making decisions on the presence of the DNG form of this EEC.


7. The loss of tree hollows is a listed `Key Threatening Process `under the TSC Act and likely to impact on a larger number of threatened birds including the Vulnerable Brown Treecreeper (Climacteris picumnus victoriae). BirdLife maintain that the direct removal of any tree hollows should be avoided, and if unavoidable should be offset irrespective of whether such hollows occur in historically cleared, or woodland environments. The proposal will result in the direct loss of at least seven small (2 - 10 cm) hollows, one medium (11 - 20 cm) hollow and two large (>20 cm) and many additional hollow-bearing trees from within the surface disturbance areas.


8. The habitat contained within the Project Application Area currently provides connectivity between the Capertee National Park to the north and the Gardens of Stone National Park to the south. The fragmentation or loss of any of this habitat through building of roads, access tracks and other surface facilities will affect habitat and the movement of avifauna species across the landscape.


9. The Project Application Area contains four major creek systems; Airly-Coco Creek, Emu Swamp Creek, Gap-Genowlan Creek and Torbane-Oaky Creek. Genowlan Creek is the most important single location for breeding by the Regent Honeyeater in Australia. Regent Honeyeaters in the Capertee Valley primarily nest in Needle-leaf Mistletoe (Amyema cambagei) growing in River Oak (Casuarina cunninghamii), this habitat is dominant along the lowland areas of Genowland Creek and is also present along Coco and Airly Creeks.


10. Centennial Coal and RPS have provided no proof or scientific backing to show that that subsidence-related effects (a section of Genowlan Creek is predicted to have a groundwater drawdown of up to 1.1m) on natural drainage will not permanently affect vital Regent Honeyeater streamside breeding habitat which could potentially contribute to the Regent Honeyeater's extinction.


11. All of the listed creeks provide important water sources and habitat for the threatened woodland bird species discussed. All of these creeks are threatened with accidental mine water discharge. The number of cases of environmental spills from inadequate waste water management and poor storm water holding capacity is alarming and enough to suggest that a spill will one day occur as a result of the proposed expansion of Airly Mine.



12. The lack of mention of Needle-leaf Mistletoe (Amyema cambagei) in the total flora species list for the entire Project Application Area, or mention of `Needle-leaf Mistletoe in River Oak Forest' as important habitat for the Regent Honeyeater is cause for concern as this is the most crucial habitat for Regent Honeyeater in the Capertee Valley. The omission of this brings BirdLife to question the rigour and validity of background research undertaken for the entire Flora and Fauna Appendix Report (Appendix H).


13. There is no suitable explanation as to how RPS and Centennial Coal determined that MU 20 (Capertee Rough-barked Apple - Redgum - Yellow Box Grassy Woodlands) is the only `Critical Habitat' for the Regent Honeyeater in the Project Application Area.


14. The term `Critical Habitat' is officially only given to habitat which has been declared under the OEH `Critical Habitat Register'. Only four species have been allocated `Critical Habitat' under this process to date, the Regent Honeyeater is not one of them. However, this must not detract from the reality that much habitat within the Project Application Area is considered extremely important and critical to the survival of the Critically Endangered Regent Honeyeater.



15. Any vegetation community which contains the important feed trees, White Box (Eucalyptus albens), Yellow Box (E.melliodora), Blakely's Red Gum (E.blakelyi) and the breeding/feeding resource Needle-leaf Mistletoe (Amyema cambagei) and its host River Oak (Casuarina cunnignhamii) that occurs in the vicnity of the Capertee Valley is crucial to the survival of the Regent Honeyeater. This means that all tracts of MU 54 (Capertee - Wilgan Riparian Rough-barked Apple - River Oak Riparian Forest), MU 42 (Capertee White Box - Tumbledown Red Gum - Ironbark - Callitris Shrubby Woodland), MU 38 (Capertee Grey Gum - Narrow-leaved Stringybark - Scribbly Gum - Callitris -Ironbark Shrubby Open Forest )and MU 21 (21 Capertee - Wolgan Slopes Red Box -Grey Gum - Stringybark Grassy Open Forest) should be included in the RPS `Critical Habitat' map for the Regent Honeyeater across the Project Application Area (see Page lxiv in Appendix H). This means the area of `Critical Habitat' for Regent Honeyeater in the Project Application Area will greatly exceed the initial (unrealistic) calculation of 55.28 ha.

16. Further targeted survey of Regent Honeyeater during the breeding season and non-breeding (foraging) seasons should be carried-out across the Project Application Areas, ideally using both observational survey methods and passive acoustic devices (e..g. SongMeters). This will assist in establishing where birds are present and possibly breeding across the Project Application Area.



17. Impacts of subsidence on vegetation and bird habitat (e.g. through dieback caused by the shearing of tree roots, or alteration of tree root access to ground water) is overlooked in this report and not addressed adequately enough to provide any satisfaction that impacts will not be significant.


18. Subsidence will cause the collapse of pagoda formations, cliff lines, overhangs and other outcropping sandstone formations. This may cause direct impact to roosting Sooty Owl (Tyto tenebricosa) listed as Vulnerable under the TSC Act, and breeding habitat of the rare Rockwarbler (Origma solitara) which is the only species of bird that is endemic to NSW.

19. BirdLife recommends that subsidence risk be audited by environmental agencies that are impartial (e.g. not employed by Centennial Coal). Any potential impacts upon native vegetation should be adequately documented, released to the public and addressed by Centennial Coal.


20. BirdLife maintains that offsets are rarely an appropriate response to proposed biodiversity or native vegetation loss
http://www.birdlife.org.au/documents/POL-Offsets-Policy.pdf

Any consideration of offsets should address all surface area disturbance vegetation losses (including derived native grasslands) and any subsidence or other mine-related vegetation dieback at like for like ratios or more. Offsets must comply with both Commonwealth (EPBC Act) and State (Biobanking or an adequate Conservation Agreement).


We appreciate this chance to comment on issues that we are most passionate about and we look forward to being informed of the final decisions of the PAC process.


Yours sincerely,

Birdlife Southern New South Wales
Conservation Subcommittee

I am in favour of the Airly Coal Mine extension. I have been involved in coal mining in this district for the last 28 years. I began at Charbon Colliery in 1986, I went to Ulan Coal in 1996 for7 years, then returned to Charbon in 2003 and remained there until its closure in 2014, I commenced at Airly in March 2014. I know firsthand how hard the management and workforce work to protect the environment and to have as small an impact as possible. The mining methods at Airly are strictly adhered to and strata management is always maintained. As a local resident, and currently Pastoring a church in Kandos I know how important the employment Airly mine provides to the district. In recent years the Kandos/Rylstone district has been adversely affected by the closure of major industries like the Cement Works and Charbon Colliery and the reopening of Airly Mine has given the district fresh hope. Many families and businesses, directly and indirectly rely on the success of Airly Mine.

I have been part of the Kandos/Rylstone community for about 30 years, the district has a lot of natural beauty but is desperate for industries which provide substantial employment such as Airly Mine. I was very pleased to read in the submission that the mine has improved its mining practices to help protect the environment. I know that coal is being targeted by political activitist, but I agree with Tony Abbot that coal is good for Australia, at this time. As renewable technologies become more reliable and cost effective then it makes sense to lessen our carbon footrpint. At this present time coal is still the cheapest, most efficient form of energy. I fully support the operations of Airly Mine.

Read my submission.

COMMENTS ON ENVIRONMENTAL IMPACT STATEMENT OF AIRLY MINE EXTENSION PROJECT, APPLICATION NO. SSD 12_5581, SEPT. 2014.


INTRODUCTION:
I have been visiting Mt. Airly and Mt. Genowlan since 1970. I have family connections to people who lived at Mt. Airly in the early 1900s, and I have researched some of the history of the area. Since the 1970s I have also undertaken a number of wildlife research projects in the area, such as bird atlas surveys, birdsong recording and analysis, flora and fauna surveys, and more recently I have been photographing unusual dragonflies in the spring-fed dams at Airly Gap and Airly Village areas. Airly Village has always been an ideal place to bring elderly or disabled people for a bush picnic as it is easily accessed. The area is also a wonderful wildlife haven and scenic asset that should be conserved for future generations.

I own a property in Capertee Valley with 1 km frontage to Coco Creek, and have lived here since 1996. Eighty-five acres of my 100 acre property is conserved as nature habitat by Nature Conservation Trust. It is dry woodland and Coco Creek provides the only water source for my land, the wildlife depends on it. I do not want to see Coco Creek, nor any other waterway in Capertee Valley, compromised by a coal mine that may pollute or limit flows in any way.

COMMENTS RELATING TO AIRLY VILLAGE AREA:
[EIS statements are taken from EIS Volume 1, Executive Summary, Table `Summary of Environmental Impacts'].

EIS:
An additional 500 mm subsidence may occur, on top of the predicted 150 mm, for area known as New Hartley Shale Mine [bright yellow // hatched area on attached pdf map], with potential for surface fracturing.
COMMENT: Unacceptable. This area adjoins the historic Airly Village complex. Some of the cliffs above the village are very high. Any rockfalls would endanger both the village and people walking on the Tramway Track.

EIS: There could be 5% cliff failure with isolated individual rockfalls.
COMMENT: This is unacceptable, compromising the surface environment and the safety of walkers.

EIS: Flows from the Village Spring are likely to cease.
COMMENT: Unacceptable. I assume this means all the springs in the Airly Village area but the actual locality is not specified in the EIS summary. The Airly Village springs supply fresh clean water to campers and walkers, and are an essential part of the wildlife habitat at Mt. Airly. The springs have historically been accessed at various points along the Tramway Track, and this delightful area along the Tramway Track at Mt. Airly is easily accessed by walkers and family groups and currently receives the majority of human visitors that come to Muggi Murrum-ban State Conservation Area. This area also has a good population of Superb Lyrebirds, and I have often noted the (ground dwelling) lyrebirds bathing and drinking at spring water seepages. These springs form an integral part of the habitat of individual lyrebird territories.

EIS: There will be no impact on the recreational use of Mugii Murum-ban State Conservation Area.
COMMENT: I doubt this. With the danger of rockfalls, and springs near the camping area completely drained, plus plans to regularly undertake exploration borehole drilling, the impact on visitors to Airly Village and Muggi Murum-ban State Conservation Area will be considerable.

EIS: There will be increased discharges into waterways in prolonged wet weather. There will be a 5% reduction in stream flow for Gap Creek and Genowlan Creeks. COMMENT: Unacceptable. Do not poison or modify our waterways, this precious water flows into the drought-prone Capertee Valley from higher areas such as Mt. Airly and Mt. Genowlan that receive more regular rainfall. These waterways in the valley are well used by several thousand local residents for domestic, farming, agricultural and recreational purposes as well as creating important habitats for wildlife. Where water is concerned, the wider environment of Capertee Valley must be considered, not just the area of the mine.

Thank you for the opportunity to comment on the Airly Mine Extension Project.

Vicki Powys

Please accept our PDF submission
Neil Gorrell
Watervale
Genowlan Road
GLEN ALICE NSW 2849

As attached, please note I have had to send this from a neighbours computer, because I didn't have internet access. on the 29/10/2014 at 12.30pm
Sue Harvey

I support the project for the Airly Mine Extension Project to continue underground coal mining in their current mining lease ML 1331 and carry out future mining in their current exploration area A232.

The Mugii Murum-ban State Conservation Area is ecologically and visually a spectacular region. The mining method developed is a superb example of how underground coal mining and environmental protection can co-exist and that mining can be carried out with the end purpose of protecting significant surface features. The mining method has been developed with both avoidance and minimisation of environmental impacts in mind.

The partial extraction mining method has been tried and tested for numerous years at Centennial Coal's Clarence Colliery, with negligible impacts occurring to the surface features of the Wollangambe wilderness' cliff lines, pagoda formations and groundwater and surface water systems.

The identification of potential environmental impacts and the environmental assessment developed has been both proficient and thorough and the partial extraction mine design has been expertly developed to allow coal extraction whilst still minimising these potential impacts.

With further mine closures in the western coal fields due to the down turn in coal and electricity markets and the rejection of project applications based on impacts to the community and environment, the Airly Mine Extension Project, if approved, will be a astonishing example that underground coal mining can not only be productive and safe but at the same time avoid and minimise impacts to the environment and the community.

The approval of this project will be a win-win all round with Centennial Coal's partial extraction methods that have a proven history in previously mined areas in the western coal fields.

I am in full support of all facets of the Airly Coal Mine Project and hope after careful consideration of the project that continued mining at Airly Mine is approved.

I support the project for the Airly Mine Extension Project to continue underground coal mining in their current mining lease ML 1331 and carry out future mining in their current exploration area A232.

The Mugii Murum-ban State Conservation Area is ecologically and visually a spectacular region. The mining method developed is a superb example of how underground coal mining and environmental protection can co-exist and that mining can be carried out with the end purpose of protecting significant surface features. The mining method has been developed with both avoidance and minimisation of environmental impacts in mind.

The partial extraction mining method has been tried and tested for numerous years at Centennial Coal's Clarence Colliery, with negligible impacts occurring to the surface features of the Wollangambe wilderness' cliff lines, pagoda formations and groundwater and surface water systems.

The identification of potential environmental impacts and the environmental assessment developed has been both proficient and thorough and the partial extraction mine design has been expertly developed to allow coal extraction whilst still minimising these potential impacts.

With further mine closures in the western coal fields due to the down turn in coal and electricity markets and the rejection of project applications based on impacts to the community and environment, the Airly Mine Extension Project, if approved, will be a astonishing example that underground coal mining can not only be productive and safe but at the same time avoid and minimise impacts to the environment and the community.

The approval of this project will be a win-win all round with Centennial Coal's partial extraction methods that have a proven history in previously mined areas in the western coal fields.

I am in full support of all facets of the Airly Coal Mine Project and hope after careful consideration of the project that continued mining at Airly Mine is approved.