Ashton Coal Project (MOD 11) - RUM Integration

I support this proposed modification as an alternate to the South-East Open Cut for the Ashton Coal Complex. By accessing adjacent (already approved) resources as an alternate to the development of an other open-cut pit in the Hunter Valley, the proposal provides an option with less environmental impacts (such as cumulative dust) than the the SEOC option. The proposal also continues to support jobs in the region by continuing the mine life and with it employment.

Submission re Ashton Coal Project (MOD11) - RUM Integration 3/12/2021

I respectfully submit that this project should not proceed.
I shall begin with some general considerations re climate change:
1. This is effectively a new coal mining project, and over its life will create 2.6 Mt CO2e Scope 1 and 2 emissions, according to the proponents.
2. During the recent COP26 meeting in Glasgow, the UN, the IPCC and the IEA have all stated that if we are to have any chance at all of confining global warming to 1.5 degrees, there must be no new coal mines and phasing out of existing mines as rapidly as possible.
3. Coal mines in NSW already have massive GHG emissions. My research of CER and company website data has shown that NSW mines have released on average 15.1 Mt CO2e Scope 1&2 emissions per year for the past 4 years, increasing each year. This does not include emissions from the 14 mines which do not provide adequate or even any emissions data. NSW Government figures obtained from Questions on Notice (Legislative Council Q&A #491, 5/5 2021) included these “missing” mines, and totalled an average of 18.3 Mt per year over the 5 years 2015-19. There appears to be a rush to open new or extended coal mines in NSW and Qld, as if COP26 and its calls from leaders of world agencies never happened. Commentators have described this behaviour by coal corporations as unbridled greed – in the face of an existential threat to humanity and the biosphere, accelerating coal production before coal becomes a stranded asset. Governments must limit not facilitate such behaviour.
4. The Ember consultancy website recently published figures in an essay explaining why the world must act on coal mine methane (1): The short-term impact of world coal mine methane leaks is greater than the EU’s entire CO2 emissions, and the IEA showed that coal mine methane has a bigger impact on climate change than shipping and aviation combined. This calculation includes only operational mines, not old leaking or in-construction ones, and experts have suggested that emissions could be double IEA’s estimates. And we now know that coal mine methane detected by satellites far outstrips figures reported by mining operations. The IPCC’s AR6 calls for immediate deep cuts in ‘climate forcers’ like methane for a chance to keep to 1.5 degrees warming; it says that methane reductions are our quickest, best chance to achieve this and lists Australia as the world’s seventh largest emitter of coal mine methane.
5. At a State Government level, Minister Stokes (17/4/21 speech to the Committee for Sydney) “asked the DPIE to also investigate options for reducing Scope 1&2 emissions…..We knowthis is the greatest contributor of GHG’s and we have the power to limit them through more rigorous assessment of project applications and imposition of conditions on development assent.” So the company should tell DPIE where they think reductions are possible; ? diesel or fugitive emissions, or ? Scope 2. Russell Vale are planning on halving their Scope2’s; Ravensworth should aim for 100% reduction.
6. The history of this project gives further cause for concern. Glencore placed Ravensworth Underground in ‘care & maintenance’ in 2014, and ceased flaring at some point after halting coal extraction. Since then it has leaked more than 1Mt CO2e of methane without penalty or restriction (ACF in the SMH 12/8/21). The company needs to explain whether it has a plan to manage GHG’s when the mine closes (or goes into care and maintenance), and whether the mine could be flooded. The Ember essay tells us that “mine flooding is the most effective way to reduce methane emissions from abandoned coal sites. If not technically feasible, mines can be sealed. ”
7. I have examined coal mine methane mitigation measures that NSW coal corporations consider reasonable and feasible; and once again the results are not encouraging. Like the concept of Net Zero, they look very much like window dressing to allow ‘business as usual’. Scope 1 emissions may be offset by tree planting but this is of course an unacceptably slow response to an urgent problem. Underground coal mines can flare pre-drainage and goaf gas. Flaring unfortunately produces CO2, the main GHG, (1 tonne of methane burns to 2.7 tonnes of CO2) and other pollutants harmful to human health. In NSW it is ‘uncommon’ to flare at ventilated air concentrations of methane <30%. Gas enrichment technology is under consideration – a new technology for the Australian coal industry. Ventilation Air Methane (VAM) technology also seeks to deal with the 50-85% methane vented to the atmosphere. Currently there are no active VAM applications in Australian underground coal mines. As there are significant initial capital and operating costs and large land requirements, the industry is looking to the state government for funding, and I question whether government should be throwing even more resources at a sunset industry. Partial conversion to electric vehicles will reduce diesel emissions – one might say that every little bit counts. Scope 2 emissions may be reduced by agreements to purchase solar farm electricity. Tahmoor Coal’s purchase from Molong Solar farm would reduce total Scope 1 &2 emissions by an underwhelming 1.46%.

8. In conclusion, this project should not proceed. Most governments around the world have now taken the view that the risks of further coal mining, particularly new mines, are unacceptably high; that coal mine methane is one of the most potent causes of our existential crisis.
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(1)Why the world must act on coal mine methane, Anatoli Smirnov, 2 November, 2021
https://ember-climate.org/commentary/2021/11/02/coal-mine-methane/

Please see attached submission.