My family originates in South Wales in the UK, and has a longstanding and proud coal mining tradition. I have seen the impacts of transitioning away from coal mining in that context. Therefore, I fully support statewide, and national, unfettered efforts to ensure a just and fair transition for our coal workers and associated industries to move towards the future. This is a major challenge and one that we all have to face. At best, extending mines will delay that inevitable challenge. At worst, that delay will mean that we miss out on opportunities for those that transition earlier rather than later. Let us make that transition to do our fair share of protecting our global environment, and in particular without causing further damage to our most precious local environments by further coal mining in our drinking water catchments.
Coal is still required for coming decades, and longer if emissions can be reasonably offset. But its sourcing should be from areas that have the minimal ecological and water quality value. That rules out the drinking water catchments of Sydney and the Illawarra. These Special Areas are among the most valuable ecosystems globally - both in terms of their environmental value, and their water quality and quantity benefits. Protecting these water sources 'to the maximum degree practicable' (as advocated in the Australian Drinking Water Guidelines) helps reduce water treatment costs, improve water yields, improve water quality and safety, and delay and reduce the need for costly upgraded water supply and treatment infrastructure. This benefits all those in the Sydney and Illawarra regions and reduces all of our water supply costs. Furthermore, the ecosystem values (such as carbon sequestration, threatened species protection, and ecosystem services) are invaluable and everlasting. These so-called 'Special Areas' really are very special, and represent one of the few areas of minimally impacted native temperate Eucalypt forest in Australia, and given our unique ecosystem, globally.
Contrasting the above points - short term very localised gains from coal mining within the water catchments that contribute to global negative environmental impacts, compared to the benefits that will last in perpetuity from protecting those same catchments, it seems very hard to see that any more mining or other development in the water catchment Special Areas can be logically and fairly permitted.
I have a particularly detailed knowledge of the Special Areas and of the benefits that they provide. I am a Water, Sanitation and Hygiene (WASH) consultant based in Sydney with 25 years of professional experience in the sector. Previously I was the Water Quality Manager for South East Water in Melbourne, where most of our water was sourced from the protected water catchments of the Upper Yarra and Thomson catchments. The benefits of such well-protected catchments were myriad - both in terms of tangible benefits, and public perception and trust. More recently I was the Principal Scientist and Manager Science and Research for Sydney Catchment Authority. For eight years I was the Program Group Leader for the Catchments, Source Waters and Monitoring Research Program, and was the Program Leader of the Catchments Research Program, for the Cooperative Research Centre for Water Quality and Treatment. Since that time, as an independent consultant, I specialise in assessing risks in water sources, with a view to understanding how to mitigate risks to public health (e.g. through water treatment and/or enhanced source protection). I work in this area across Australia as well as into New Zealand, much of the Western Pacific and South Asia. Invariably, full drinking water catchment protection is highly valued where it is in place. Note that this includes the catchments of much of Sydney, Melbourne, Perth, Darwin and many regional areas, such as parts of north Queensland.
As a private citizen I consider that we need to draw a line and prevent further degradation of what little is left of our best-protected natural environments. Given the massive tangible value of a protected drinking water catchment, what better places to fully protect than just such areas? If we only protect one category of natural systems, our drinking water catchments would seem to be the most important, since we can derive massive societal benefit from that protection.
As a professional in the water and environment sector, I am aware of the practical challenges of mitigating risk in practice, no matter how well designed and well-intentioned the risk management plan may be. More importantly, even if through innocent mistake, once damage is done, it often cannot be reversed. I am also aware of how planning reviews see development applications. Saying 'yes' to one development makes it much harder to say 'no' to others. The precedent set by permitting the mine extension into the Special Areas will be quite understandably cited by parties seeking all manner of other developments and activities that threaten the Sydney and Illawarra's water catchments. I have been involved in a professional capacity in multiple planning tribunals and these precedents are used by developers to promote intensification of development, or removal of existing protections. Clearly something as self-evidently environmentally significant as a large coal mine, in an environment so sensitive as the Special Areas, sets a strong precedent. Other developments will be tending to argue that their impacts are lesser and/or environments less important. Therefore, I consider the line needs to be drawn on further development in these Special Areas.
I accept that there may need to be justifiable compensatory and alternative opportunities provided for the communities, investors and businesses, to offset opportunity costs of this application being rejected. That cost can be borne by the Sydney and Illawarra community at large since we all benefit from protecting these areas. I cannot speak on their behalf but personally I consider that a cost I'm happy to contribute my fair share to and I suspect most Sydney and Illawarra residents feel the same.
Finally, I thank you for providing the opportunity to share my perspectives and for considering my feedback. I realise that these decisions are very challenging, nuanced and complex, and I wish you all the best in making a final determination.
Dr Daniel Alun Deere
14 June 2022