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State Significant Infrastructure

Withdrawn

Dendrobium Mine Extension Project

Wollongong City

Current Status: Withdrawn

Proposed extension of mining within Area 5 and extension of the life of Dendrobium Mine until 2041.

Attachments & Resources

Notice of Exhibition (2)

Application (1)

SEARs (5)

EIS (46)

Response to Submissions (1)

Agency Advice (23)

Additional Information (2)

Submissions

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Showing 81 - 100 of 514 submissions
Andrew Nicholson
Object
BULLI , New South Wales
Message
Mining for coal under our water catchment in an era of climate change is complete madness.

The rationale for State Significant Infrastructure Status is flawed :
"According to the NSW Government, the rationale for declaring the expansion of Dendrobium Mine in Sydney and Wollongong’s water catchment as State Significant Infrastructure is that the expansion of Dendrobium Mine is essential for the operation of the Port Kembla steelworks. However, Bluescope Steel had already made provision for purchasing and transporting coal from other mines , and has also secured considerable Federal and NSW Government funds to investigate transition to low- or zero-carbon steel production."

Damage to Sydney and Wollongong’s drinking water catchment:

"Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. The proposed mining is in the protected Special Areas of the water catchment upon which 5 million people rely for drinking water. There should be no mining in the Special Areas of Greater Sydney Water Catchment; this is the stated position of WaterNSW and the legislated purpose of Special Area protection.
'
Mining induced subsidence will damage the watercourses and swamps that feed our drinking water reservoirs. Despite the reduction in the overall size of the project, longwalls themselves proposed for Area 5 are still 305m wide.

South 32 predicts that 305 metre wide longwall panels may result in subsidence of 2m to 2.45m . Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative ."
Phil Diamond
Object
MOUNT KEMBLA , New South Wales
Message
Please find my Submission to the proposed extension of Dendrobium Mine. cheers Phil Diamond
Attachments
Name Withheld
Object
COALCLIFF , New South Wales
Message
I object to the Dendrobium Mine Extension Project.

The Dendrobium Extension Project would result in ~88 million tonnes CO2-e of GHGs. This is equivalent to the emissions of ~280,000 average Australian households over 18 years. The Extension would add between 12.2 – 15.5 million tonnes of CO2-e of direct Scope 1 and 2 GHGs to the NSW GHG inventory over the life of the Project.

Based on the average Scope 1 emissions (assuming flaring) of 789,551 tonnes CO2-e per annum, the Dendrobium Extension could become the 4th highest emitting coal mine in NSW.

These emissions will primarily be fugitive methane emissions, which must be urgently reduced. The International Energy Agency – in their Net Zero by 2050 report – has called for the “elimination of all technically avoidable methane emissions by 2030”.

I find it abhorrent that the NSW Department of Planning has recently been found to "coach" South32 in it's application to the IPC - when in 2019 speakers to the United Nations warned nations have 11 years to prevent Irreversible Damage from Climate Change.

If the IPC throws its lot in with South32, and with the State Government, and approves this expansion, it will be facilitating further climate disasters; flooding, bushfires, mass starvation, along with national and global instability.

Sources:
https://www.un.org/press/en/2019/ga12131.doc.htm
https://www.abc.net.au/news/2022-06-10/dendrobium-foi-reveals-coaching-environmentalists-say-/101135878
Name Withheld
Object
AUSTINMER , New South Wales
Message
I object to the proposed extension of the Dendrobium mine. My objection is based upon 3 main concerns.
Firstly is the use of long wall mining so close to the water supply. The risk posed by this type of mining to the integrity and safety of the drinking water for Wollongong and Sydney is real. When there is contamination or loss of volume of drinking water supply in the future it will not be labelled as an accident. It will be seen as an incredible lack of foresight and terrible decision making.
Secondly I object based upon the risk to the amazing ecology of the upland swamps. I love this area dearly and am amazed each time I walk in these environments- the plant diversity is incredible and realising that the koala population is able to hang on in this area despite the encroachment of urbanisation is great news but fractures and subsidence due to long wall mining will likely change the habitat and therefore pose further risk to endagered species.
Thirdly I wish to express my despair that First Nations heritage in this area is being undervalued and actually deliberately putting this heritage at risk is really demoralising. Reconciliation doesn't occur when voices of Aboriginal australians are dismissed. The cultural significance of this landscape as a whole is being denied by this proposal.
I object to the extension of the Dendrobium mine and in particular the use of long wall mining methods.
Name Withheld
Support
STANWELL PARK , New South Wales
Message
The revised mine plan for this project adequately addresses the concerns raised when the project was initially rejected. We need to now strike a balance between environmental impacts and the economic considerations for State NWS, the local communities and our medium/small local businesses. South 32 is prepared to invest a substantial amount of capital into this project and the benefits to local small and medium businesses and the local economy is not to be underestimated. If this project does not get approved, it will have a devastating impact on the livelihood of local people and businesses, downstream and upstream, which will place further economic strain on taxpayers and local councils. This will further result in increase unemployment and crime. I trust that common sense will prevail in this transition period until alternatives to coking coal is established, which as we all know, is still a fair way off. Do not destroy our businesses! Consideration MUST be given to South 32's emission targets and whether approving this project will jeopardize those targets. Groundwater loss and other environmental impacts are grossly overstated in comparison to economic impacts, playing into the hands of lobby groups. They have no interest, or care about a balanced approached in this application between social, economic impacts and environmental impacts. This revised Mine plan now strikes that balance, so to reject the Project again for similar reasons, simply will not suffice.
Name Withheld
Object
NORTH WOLLONGONG , New South Wales
Message
I strongly object to the proposed extension to the Dendrobium Mine for a number of reasons. Firstly, the mine provides an unconscionable risk to Wollongong's drinking water, as the potential subsidence from the mine may impact the water catchment area. The mine poses a risk not just to the quantity of water in the catchment, but also its quality, with the risk of metals leaching into the water. Secondly, the mine will likely impact aquatic ecosystems, upland swamps, and the habitat of koalas. We should not accept this risk to these delicate ecosystems. Lastly, this mine will delay the transition to low or zero carbon steel. In summary, I strongly believe that this extension should not be approved.
Name Withheld
Object
THIRROUL , New South Wales
Message
I am writing this submission to object to the Dendrobium Mine Extension Project.

I am concerned about the damage to Sydney and Wollongong’s drinking water catchment that will result from longwall mining. I understand that the mine extension is in the protected Special Areas of the water catchment upon which 5 million people rely for drinking water. I believe there should be no mining in the Special Areas of Greater Sydney Water Catchment. I am also concerned about mining induced subsidence which will damage the watercourses and swamps that feed our drinking water reservoirs. I believe that our drinking water catchment is essential infrastructure and should be prioritised over a privately-owned coal mine.

I am very concerned about the climate impacts of the project, which will more than triple current direct (Scope 1) greenhouse gas (GHG) emissions and add between 12.2 – 15.5 million tonnes of CO2-e of direct Scope 1 and 2 GHGs to the NSW GHG inventory over the life of the Project. I understand that based on the emissions per annum, that the Dendrobium Extension could become the 4th highest emitting coal mine in NSW.

These emissions will primarily be fugitive methane emissions, which must be urgently reduced. The International Energy Agency – in their Net Zero by 2050 report – has called for the “elimination of all technically avoidable methane emissions by 2030”.

We are already experiencing the devastating impacts of global warming, as evidenced by recent bushfires and floods – it is imperative that we take action now to reduce our reliance on fossil fuels. Extending the life of the project by 20 years is clearly not consistent with this imperative.

I am also concerned about the damage to Aboriginal cultural heritage. I understand that there are 31 Aboriginal Heritage sites in and close to Area 5, with 6 of these sites directly over longwalls. Sites named in the Environmental Impact Statement include: 13 axe grinding grooves, 8 shelters with art, 2 shelters with deposits, 1 shelter with art and deposits, 6 shelters with art and potential archaeological deposits and 1 isolated find.

I object to the profits of a private company being prioritised over the cultural heritage of Aboriginal people. While monitoring of Indigenous cultural sites is required there is no requirement to preserve or avoid these sites, and no penalties to South32 when it destroys them. It is reprehensible for mining interests to desecrate Aboriginal Cultural heritage.

I am concerned about the impact on koalas and their habitat. Koalas have recently been declared Endangered in NSW. The Environmental Impact Statement notes that there are koalas living in the area that will be undermined, but includes no current survey of koala numbers or locations. There is no management plan for koalas who may be living in the ecosystems that would be cleared for infrastructure, other than offsetting that includes a bio-banking scheme that has not yet been negotiated, and payment to a government trust. It is hard to see how these future arrangements will prevent a devastating impact on actual, living koalas who may be present in land to be cleared for infrastructure.

Water loss and impact on swamps and waterways means that the ecosystems of the catchment are ‘dewatered’. This is a real and devastating threat to plants and wildlife in the catchment, including a koala population that remains inadequately documented and studied.

I believe that the claim that the project will protect jobs in mining and at Bluescope steelworks is overstated. In view of the demise of the fossil fuel industry world wide, the opportunities for jobs in sustainable industries such as renewable hydrogen production, renewable energy, recycling of rare earths from e-waste, conventional recycling, and low or zero carbon steel production need to be prioritised as they will actually deliver more jobs directly and indirectly, when compared to the fossil fuel industry.
Adele Stewart
Object
WOONONA , New South Wales
Message
Dear Minister Roberts

I am writing to voice my concern over the possible approval of the Dendrobium Mine expansion and to ask you to please honour the original decision made by the State Government’s Independent Planning Commission which was to reject the proposal due to the high risk to our drinking water.
I understand that some changes have been made and the expansion is now smaller however the risk to our drinking water is still far too great.
The fact that this expansion has now been declared State Significant Infrastructure so requiring a new decision is unsound and worrisome.
The expansion of the Dendrobium mine is unsound and not essential infrastructure as claimed because:
Bluescope Steel had already made alternate arrangements to source their coal so the Dendrobuim expansion is redundant for the supply of coal to Bluescope
Bluescope Steel secured significant funding from both federal and state governments to fast track their transition to low or zero carbon steel
Our drinking water catchment itself is essential infrastructure! Just because it doesn’t have buildings or make money does not make it non-essential infrastructure. It’s a natural infrastructure which is no less important than built infrastructure. The Water Catchment Infrastructure itself is more essential than the Dendrobium mine expansion infrastructure.
The decision to have this declared as State Essential Infrastructure is worrisome because:
It has been revealed under FOI that the department for which you are now responsible, the NSW Department of Planning has been Coaching South 32 in how to have the original decision overturned
This demonstrates lack of integrity from your department and is a transgression bordering on manipulation
It will be extremely unjust and obviously biased if you allow any new documentation from South 32 including the points coached by your department, to be included in your decision making

Please apply the precautionary principle and recognize that water will be a much-needed resource far beyond the 20 year life span of the Dendrobium expansion and that you will be putting the health of our Illawarra Community at risk if you approve this expansion. Would your Lane Cove Community want their drinking water to be put at risk?
Australia is the only country that allows mining under drinking water catchments. Please do not allow this stupidity to continue and please understand that as a government it is your duty to look to the future and create new economic opportunities.
Please reject this proposal.

Yours faithfully

Dr Adele Stewart
Name Withheld
Object
HELENSBURGH , New South Wales
Message
Submission opposing SSI-33143123 Dendrobium Mine Area 5 Expansion
MM: I wish to acknowledge the people of the Dharawal Nation.
This is my unique submission, views presented here are my own. I am an active member of two Illawarra community groups opposing the Dendrobium expansion: Protect Our Water Alliance (POWA); and Protect Our Water Catchment Incorporated (POWC). POWC are currently represented by the Environmental Defenders Office (EDO) as seconders in the NSW Land and Environment Court case of South32 challenging the NSW IPC decision to reject its earlier SSD-8194 area 5&6 expansion.
Regarding Dendrobium: the NSW IPC presented a stated set of reasons when it rejected SSD-8194 and South32 are well within their rights to challenge the NSW IPC decision in L&E courts. The questions I raise here are informed by my deep involvement in the Dendrobium planning process as a whole; and, for obvious reasons, I will not be commenting on court proceedings.

I am a member of the community who, like many, has engaged extensively in this planning process in good faith. As a result of my recent experiences, I find myself questioning the procedural ethics of the ways the NSW Government and the Department of Planning has conducted the planning process for Dendrobium.
My understanding is that the NSW IPC was set up in response to several years of well documented corruption by NSW government ministers’ involvements in major planning projects; such as mines. The intention, at the time, was to make the major project deliberations transparent, accountable, open to community stake-holder input and expert advisors from all relevant fields. This became an election issue and the NSW liberal government was returned to power with a promise to the people of NSW that the bad-old-days of corruption in planning were over.

QUESTION 1: I am however, struggling to understand how the NSW government has been able to amend legislation in the parliament to grant the Dendrobium expansion State Significant Infrastructure Status prior to the conclusion of South32 SSD-8142 vs NSW government planning and NSWIPC L&E court challenge?

QUESTION 2: How could South32 Dendrobium mine SSI status have been given by government ministers while the SSD-8194 is still effectively unresolved and therefore “live” in the planning system?

QUESTION 3: The above means that, South32 are running two planning process pathways in parallel. As we know this is the first mine to be given SSI status. The government has said publicly that Dendrobium will be the only mine to be given SSI status. How will the government ensure that their actions will not set a precedence for future mining companies to apply pressure both politically and in the courts for SSI?

QUESTION 4: I find myself wondering if there has been any previous situation in NSW where the simultaneous, and parallel, pursuit of two large State Significant development applications SSD and SSI, by the same developer, has effectively been facilitated by a government amendment?

QUESTION 5: What will happen if South32 win the SSD-8194 court challenge? How will the NSW government manage a situation where South32 are able to proceed with SSD-8194 which is a larger development than the SSI-33143123?

IN CONCLUSION
QUESTION 6: Would it not make sense that the SDD application is allowed to be resolved before the SSI application proceeds any further?

MM June 14th, 2022.
Name Withheld
Object
KEIRAVILLE , New South Wales
Message
As a resident of the Wollongong Local Government area, an elector on the NSW Electoral Roll and af customer of Sydney Water i object to the extension of the Dendrobium mine project.

This major project has previously been assessed and reported on in February 2021 by the NSW Independent Planning Commission and found the "proposed mine design risks long term and irreversible damage to Greater Sydney and the Illawarra's drinking water catchment". Although South32 has submitted a smaller, revised plan this proposal still would result in detrimental losses to the drinking water catchment, a tripling of direct green house gas emissions and a potentially "irreversible" damage to 16 endangered swamps.

The Dendrobium project, according to the NSW Deputy Premier, is worthy of being considered as State Significant Infrastructure, citing the Dendrobium mine's importance to Port Kembla steelworks. On the other hand South32 has admitted "BlueScope may be able to source alternative supplies of metallurgical coal locally". This option would avoid further damage to the drinking water catchment. In any case Dendrobium mine, under current approvals still has eleven years of mining. 30 years of mining is too long.

If the mining extension to the Dendrobium mine is considered an entity of State Significant Infrastructure then all the more is the Sydney Water catchment areas to be considered at the highest order and most State Significant Infrastructure which is directly above the proposed Dendrobium mine extension.

I call on the NSW Minister for Planning, Mr Anthony Roberts to implement in his power, under S. 2.9 (1) (c) of the EP&A Act, to task the NSW IPC with reviewing independent reports being commissioned by NSW DPE (including security of coal supply for BlueScope. This section of the Act allows the IPC to advise the Minister or the Planning Secretary on any matter on which the Minister or the Planning Secretary requests from the Commission".
The safe drinking water of the Greater Sydney region including Blue Mountains and Wollongong areas is under threat by the proposed Dendrobium mine extension. Over 5 million people rely on Sydney Water for safe and reliable drinking water. Sydney is the international gateway for overseas visitors. If international attention was focused on the method of mining, subsidence and the detrimental effect of inappropriate mining in a designated drinking water catchment area what would the international reaction be? Not as a First World Country or a State.

As an elector on the NSW State Electoral Roll, I like many others - in excess of 5 million voters - will be voting in the upcoming NSW State elections in March 2023. This year the NSW Department of Planning, Industry and Environment announced the intention to double the number of koalas in NSW by 2050, including actions that will provide more habitat for the koala.

Electors have long memories and next year the electors will remember that on 13th January 2022 the koala was unfortunately listed as Endangered Species. If the goal of doubling the koala population by 2050 is to be achieved, then as part of that process, the Dendrobium mine extension should be denied and the water catchment area be returned to doing its job and be that of a natural filter for drinking water suppy to millions of people who have no other source. BlueScope has alternative local supplies of suitable metallurgical coal for the steelmaking process.

The elected representatives of NSW State Parliament are answerable to the electorate of NSW. The NSW electorate will hold the relevant Minister accountable for the actions in protecting and preserving the drinking water of the nation's largest city and international gateway to the nation.

I call on the Minister to reject the proposal to extend the Dendrobium mine.
Clayton Hairs
Object
BERRIMA , New South Wales
Message
I am writing to express my objection to the extension to the Dendrobium long wall mine in its revised form.

I live in an area which may well be affected by the mine extension in the Southern Highlands.

I object to the potential damage with the extension would do to 16 endangered swamps, potentially irreversibly, should this submission be given permission to proceed.

It is well known that long wall mining is far more damaging to drinking water (this mine extension directly affecting Sydney and Illawarra water catchment) and to endangered swamps. South 32, the owner of the mine have illustrated that there would be more jobs in bord and pillar mining than in long wall and hence argument on the basis of significant job creation are questionable.

South 32 have also conceded that Blue Scope Steel are under no obligation to buy their product and Bluescope could just as well source their coal from elsewhere making arguments in respect of the necessity of the mine questionable, particularly in light of the fact that Bluescope are currently investigating the use of sustainable sourced biochar and coke oven gas (which contains 60% hydrogen) as replacements for coking coal. Alongside this BlueScope have signed a memorandum of understanding with Rio Tinto to explore using renewable hydrogen as a replacement for coking coal.

The dependance of the Port Kembla steelworks on future coal supply from a new long wall project remains unclear. As such, I would request NSW planning minister Anthony Roberts to exercise his power under S 2.9 (1)(c) to task the NSW Independent Planning Commission with reviewing independant reports being commissioned by NSW DPE (including security of coal supply for Bluescope). This section of the Act allows the IPC “to advise the Minister or the Planning Secretary on any matter on which the Minister or the Planning Secretary requests advice from the Commission”.

While it might be too late for the IPC to determine the project, they are permitted, as illustrated above, to review key documents which might allay a modicum of community concern to the integrity of the assessment of this application for mine extension.

Sincerely
Clayton Hairs
Berrima NSW
Jo Bradley
Object
Sutherland , New South Wales
Message
Dear Minister Roberts,
I object to the greater Sydney drinking water catchment being undermined and damaged. Water is our most valuable resource and preserving the pristine environment in these special, protected areas should be our utmost priority.
We know that long wall mining causes permanent damage to kilometres of streams, waterways and swamps, that it dries out the landscape and changes it forever.
We know that despite a 'commercial in confidence' integrated system between BlueScope and South32, that BlueScope could use coal from somewhere else that is less vital for our long term survival.
We believe the price of steel and the just in time supply of coal is not as important as preserving our drinking water source.
I hope there is a time soon when our Government will stop Inviting rich companies to extract sovereigN resources for the benefits of very few and At the cost of Many for many generations.
The intergeneration cost of drying out vast areas of habitat to so many Endangered Animals (especially koalas) and plants cannot be Truly compensated for. I do not agree with Paying fees for the destructIon of the habitat of Endangered animals. These fees can not possibly compensate the people of the future however they will still suffer the loss of what we take away now.
Preserving indigenous artifacts should be considered within the whole context of the landscape, as these sites can not be disconnected from each other or isolated from their surrounding environment.
Please consider the reasons for the decision to create Dharawal National Park, and let these same reasons (along with the many experts objecting to this new development proposal) influence your decision regarding this development.
Sincerely,
Joanna Bradley

PS and the planned permanent water losses - today 14/6/22 I read such sad news about people and animals in India and Chile in sheer desperation for fresh water due to the impacts of climate change on rainfall. We are not immune, and the unknowns are too many.
Illawarra Local Aboriginal Land Council
Object
Wollongong , New South Wales
Message
The Illawarra Local Aboriginal Land Council (ILALC) would like to state our continued opposition to the proposed extension to the Dendrobium Mine within the Illawarra Escarpment and water catchment areas. ILALC put in a submission opposing the originally Dendrobium mine extension Project (SSD-8194). ILALC’s 2022 and 2019 submission is attached to this submission.

The Dendrobium Mine Expansion will impact Aboriginal Cultural Heritage. The mine expansion will, directly and indirectly, impact culturally significant tangible Aboriginal sites, including rock shelters with art and deposit, axe-grinding groves and stone artefacts. The mine expansion will also dewater important upland swamps and resource locations, alter and reduce cultural values associated with cultural complexes and landscapes, and disarticulate Aboriginal places and objects from their cultural context.
Aboriginal objects, places, landscapes, connection to Country, the interconnectedness of sites, waterways, swamps, intangible heritage and ecosystems are all of great significance and importance to Aboriginal people. South 32 provide no evidence or explanation as to why the profits of a private company should be prioritised over the cultural heritage of Aboriginal people. Monitoring of Indigenous cultural sites is required, but there is no requirement to preserve or avoid these sites and no penalties to South 32 when it destroys them. It is reprehensible for mining interests to desecrate Aboriginal Cultural Heritage whilst the area remains out of bounds for the Aboriginal community.

It is ILALC’s view that the Aboriginal Cultural Heritage Assessment Report (ACHAR) commissioned by South 32 does not meet the Secretary’s Environmental Assessment Requirements (SEARs). ILALC believes that the ACHAR does not provide critical information to allow the Minister to make an
informed decision about the project in relation to Aboriginal heritage. Fundamentally, as explained below, the report fails to identify the Aboriginal cultural values, objects, and sites present within the area or the potential harm the proposed development poses to these. All of these are fundamental in ensuring an open, honest, and accurate assessment of harm to Aboriginal Cultural Heritage.

ILALC consider that the ACHAR does not comply with the requirements of the ‘Code of Practice for Archaeological Investigation of Aboriginal Objects in New South Wales (DECCW 2010)’ (The Code) and therefore fails to meet the requirements of the National Parks and Wildlife regulation 2019. ILALC suggest that the ACHAR has:
 o Not complied with Requirement 5a and 5c of the Code. Specifically, the ACHAR:
o Does not adequately identify or record all (or even a representative sample of all) the material traces and evidence of Aboriginal Land use.
o Does not employ an adequate sampling strategy when undertaking the surveys:
 o Surveys did not adequately sample all landforms;
 o Surveys did not provide adequate survey coverage (including a lack of surveys of ancillary and surface infrastructure) to identify or characterise
Aboriginal cultural heritage within the Subject Area.
o The ACHAR does not present adequate descriptions or images of the Aboriginal cultural heritage sites. This means the site, its context, its significance, or potential
harm cannot be understood by the Minister making the decision or the Aboriginal community whose heritage it is.

o The scientific value and significance assessment section of the ACHAR does not adequately identify or assess the cultural values of the Subject Area. It preferences
Western Science over Aboriginal Knowledge in assigning value, sidelining Aboriginal people’s voice from determining the cultural significance of their heritage and
in the Development Assessment process as a whole. It is only after understanding which places are culturally significant and why, that any decision can be made
about managing them.

 o The ACHAR recommends to undertake further investigations of Aboriginal cultural heritage (at the surface and ancillary infrastructure sites) and Aboriginal cultural
values after granting approval for the project. This does not allow for the true extent of harm to be taken into consideration when making the determination.

o The ACHAR recommends that a Trigger Action Response Plan be created and implemented subsequent to approval. However, beyond monitoring and recording of
harm resulting to tangible heritage from subsidence, there are no actions proposed to stop works or apply penalties to South 32 when it impacts or destroys them.

o The ACHAR does not identify harm to all Aboriginal cultural heritage. It does not identify harm to intangible cultural heritage, resource gathering locations (swamps),
waterways, the interconnection between sites and places, cultural complexes or landscapes or harm to tangible sites outside of the Subject Area. Without considering
all of this, the full extent of harm to Aboriginal cultural heritage cannot be determined.

ILALC believes that a decision relevant to Aboriginal Cultural Heritage cannot be made before the above and below issues are addressed. It is ILALC’s view that based on the limited information provided in the ACHAR and Archaeological Report (AR), it is not possible to make a decision about whether harm to Aboriginal sites (identified and not identified in the ACHAR) should be permitted.

All Aboriginal cultural heritage, including Aboriginal objects, places, resource gathering locations, intangible cultural heritage, waterways, swamps and the cultural landscape, is of high cultural importance and significance to Aboriginal people. Until Aboriginal community views are identified, respected and meaningfully addressed by South 32, there can be no ethical, moral or procedural justification for approving the Dendrobium Area 5 Extension on Aboriginal heritage grounds.

The attached document provides details to support ILALC's position.
Attachments
Name Withheld
Support
SCHOFIELDS , New South Wales
Message
I am supporting this project as its boosting our economy with a minimum environmental impact.
Name Withheld
Object
WEDDERBURN , New South Wales
Message
See Attachments
Attachments
Oatley Flora and Fauna Conservation Society Inc.
Object
OATLEY , New South Wales
Message
Oatley Flora and Fauna Conservation Society (OFF) submission
Dendrobium Mine Extension Project (SSI 33143123)
Oatley Flora and Fauna Conservation Society (OFF) was established in 1955, is based in the Lower Georges River area and has over 300 members. OFF’s Mission Statement is ‘Working to protect, conserve and enhance the natural environment locally and globally’. OFF has a keen long-term interest in the precious environment of Sydney and the Illawarra’s water catchment areas.

OFF objects to the Dendrobium Mine Extension Project (SSI 33143123) for the following reasons:

Damage to Sydney and Wollongong’s drinking water catchment
Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. The proposed mining is in the protected Special Areas of the water catchment upon which 5 million people rely for drinking water. As stated by WaterNSW there should be no mining in the Special Areas of Greater Sydney Water Catchment. OFF is of the view that all of Sydney’s drinking water catchments and the associated supply infrastructure is of State Significance and ensuring the sustainability of Sydney’s water supply should be prioritised over access to coal.
Water quantity losses
Mining induced subsidence will damage the watercourses and swamps that feed our drinking water reservoirs. Despite the reduction in the overall size of the project, longwalls themselves proposed for Area 5 are still 305m wide. As revealed by WaterNSW the resultant cracking and dewatering of watercourses, swamps and aquifers will add significantly to the losses to water yield already occurring.
Water quality impacts
According to DPIE’s report on South 32’s previous unsuccessful application to expand Dendrobium Mine, as water courses fracture due to mining induced subsidence, metals will be dissolved and leach into the water. This will lead to an increase in metals in the water courses and reservoirs.
Impact on Aboriginal Cultural Heritage
There are 31 Aboriginal Heritage sites in and close to Area 5, with 6 of these sites directly over longwalls. Monitoring of Indigenous cultural sites is required but there is no requirement to preserve or avoid these sites, and no penalties to South32 when it destroys them. It seems most likely that the end result will be damaged Aboriginal Heritage items.
Extent of impact on koalas
Koalas have recently been declared Endangered in NSW. The Environmental Impact Statement notes that there are koalas living in the area that will be undermined, but includes no current survey of koala numbers or locations. There is no management plan for koalas who may be living in the ecosystems that would be cleared for infrastructure, other than offsetting, which OFF considers to be an inadequate management strategy. Water loss impact on swamps and waterways means that the ecosystems of the catchment are ‘dewatered’. This is a real and devastating threat to plants and wildlife in the catchment, including a koala population that remains inadequately documented and studied.
Impact on Aquatic ecosystems
The mine expansion will impact on aquatic habitat and lifeforms, due to both water loss and contamination of water from mine outflows, and leaching of minerals into waterways.
Impact on Upland Swamps
The upland swamps of the Woronora Plateau play an important role in the water catchment by capturing and holding water, filtering it and in times of drought releasing it slowly into the creeks and rivers that feed into the reservoirs. These swamps are classified as Endangered Ecological Communities (EEC) and are significant in terms of their biodiversity. Each swamp contains rare plants and animals. The specialised flora and fauna of the EEC also carry individual protection at species level. Dewatering the swamps will likely result in local extinctions.
Significant Climate impacts
As the Project is proposing to extract from Area 5 which has “a higher gas concentration”, the Extension project would more than triple current direct (Scope 1) greenhouse gas (GHG) emissions.
In total, the Dendrobium Extension Project would result in ~88 million tonnes CO2-e of GHGs. This is equivalent to the emissions of ~280,000 average Australian households over 18 years. The Extension would add between 12.2 – 15.5 million tonnes of CO2-e of direct Scope 1 and 2 GHGs to the NSW GHG inventory over the life of the Project.
Based on the average Scope 1 emissions (assuming flaring) of 789,551 tonnes CO2-e per annum, the Dendrobium Extension could become the 4th highest emitting coal mine in NSW.
These emissions will primarily be fugitive methane emissions, which must be urgently reduced. The International Energy Agency – in their Net Zero by 2050 report – has called for the “elimination of all technically avoidable methane emissions by 2030”.
It is unacceptable for the project to cause this high level of emissions when NSW should be doing all that can be done to reduce and eliminate emissions for the benefit of current and future generations.
Nicholas Southall
Object
FAIRY MEADOW , New South Wales
Message
Hello, I’m Dr Nick Southall. I live in Wollongong, I work at the University of Wollongong, I’m a lecturer in International Development Studies, and I’m making this submission to oppose the expansion of mining at Denbrobium.

South32 admit this proposal will result in a range of irreversible impacts to the water catchment Special Areas, undermining of streams and swamps, massive loss of drinking water, dangerous effects on water quality, and damage to at least six Aboriginal cultural heritage sites. It also threatens ongoing impacts to the climate, the environment, eco-systems and people, including increased likelihood of bush fires on the Illawarra Escarpment.

Large numbers of Australian water experts and the NSW Local Government Association are opposed to mining in the water catchment. Wollongong City Council’s response to the expansion warns of the cumulative loss of water from the extension of this and other coal mines and that those losses will be far greater than predicted. This proposal would significantly reduce local water quality and supplies at the same time as demand increases. WaterNSW have said this expansion must not go ahead.
The proposed damage of this expansion cannot be accurately calculated and may involve the loss of water forever. The damage cannot be repaired and South32’s offer of compensation for the loss of water cannot address the value of a priceless resource. Water is essential for sustainable development, critical for healthy ecosystems, and healthy communities. Here I want to draw attention to the importance of upland swamps. In the Scoping Report South32 are claiming to “protect significant stream features”. Yet, the proposed mining will undermine around ‘feeder swamps’ & ‘smaller streams’ that are connected to them. This is a deliberate misunderstanding of how the ‘significant stream features’ function and how subsidence & cracking around them impacts water storage and flow.

Water is the primary medium through which we feel the effects of climate change. A recent Bureau of Meteorology report explains how the dehydration of the escarpment will create conditions for a major inferno which could devastate local bush, eco-systems, wildlife, and risk human life. The burning of fossil fuels and the undermining of our water catchment is turning our region into a tinderbox. This expansion would help to guarantee that in the years ahead the Illawarra burns.

Many of the suggested financial and employment impacts claimed by the company, and those doing economic modelling for them, are based on assumptions that do not hold-up to scrutiny. Only fifty additional on-going jobs are expected from the proposal. Yet, the destruction, damage and dangers detailed above is unlikely to provide even medium-term job creation or financial benefits to our community. Coalmining is a dying industry increasingly reliant on labour hire and casual workforces. It is delusional to suggest that there’s a stable future in coal jobs and incomes. Our region’s future prosperity lies elsewhere.

Regarding Bluescope’s reliance on South32, I urge the Minister to carefully check the accuracy of company claims about the use of Dendrobium coal and alternative supplies. The Government has designated the mine State Significant Infrastructure due to its alleged role in providing coal for the Port Kembla steelworks. During the IPC hearings, South32 said they needed to mine Area 6 claiming the local steel industry was threatened without it – that Bluescope relied on the blended mix of Bulli & Wongawilli seams Dendrobium extension would provide. But now the company says they don’t need it. So, they lied to the IPC in their application in relation to this central issue.

Meanwhile, the IPC found that most of Bluescope’s coal came from other mines, the majority of Dendrobium coal over the next 20 years would be exported or transported elsewhere, and Bluescope's preferred coal would not be mined by the expansion until almost 20 years into the project. Recently, BlueScope's general manager of manufacturing David Bell told a ‘virtual town hall’ that work on the Port Kembla wharves would allow the steelmaker to bring in coal from elsewhere if need be. There’s also plenty of Bulli Seam coal available from South32’s Appin mine, an area where there is no mining in the water catchment.

In conclusion, South32’s proposal is a two-fold attack on our water supplies – undermining them from below and evaporating them from above. No money can compensate for something that is priceless and for destruction which will be perpetual. You cannot offset eco-system and species loss. Coal mining in the water catchment does not offer a guarantee of secure jobs, decent wages, or economic growth. It will cause irreparable long-term damage to our future prospects. Our region must transition to a more sustainable future. This future needs your support, and that support must include protecting the water that nourishes our community, the economy, and our environment. I strongly urge you to refuse this expansion.

Yours sincerely,
Dr. Nick Southall
Lee McKerracher
Object
RABY , New South Wales
Message
As a local resident I have a number of concerns about this extension project being given the approval to proceed. Coal mining is an industry that contributes to climate change and our focus needs to be on investing in renewables and not in expanding coal mining. Additionally, it should be noted that this project was rejected in February 2021 by the Independent Planning Commission NSW finding its "environmental impacts would be long term, irreversible and not in the public interest" ( refer: ABC Illawarra, 8 December 2021 https://www.abc.net.au/news/2021-12-08/new-dendrobium-mine-plan-south32/100684180 ) but we are again faced with a 'revised' proposal to continue something already rejected as not in the public interest.

More specifically, there are a number of issues of this mine expansion that raise concerns and have led me to oppose this project. They are:

1. Risks to the water catchment: Sydney is an outlier in global terms as it is the only city in the world that allows longwall mining in a publicly owned water catchment. The proposed mining is in the area of the water catchment that approximately 5 million people rely on for drinking water. There should be no mining in the Special Areas of Greater Sydney Water Catchment; this is the stated position of WaterNSW and the legislated purpose of Special Area protection. Why? Because it threatens the water quality through the cracking and dewatering of watercourses, swamps and aquifers. This is expected to add the loss of many more millions of litres of water each day to the 10 million litres daily water loss from Dendrobium’s current and past mining. WaterNSW has been clear that mining in the Special Areas causes loss of yield to the reservoirs and the swamps and water courses that charge them (refer to: https://www.waternsw.com.au/water-quality/catchment/mining ).

This mine expansion also impacts on the ability of the water catchment to collect, clean, and store water and negatively impacts on the sustainability and resilience of the supply of drinking water for Sydney and Wollongong, in terms of both water quality and quantity. Water that enters and then flows out of mines picks up contaminants along the way. Current measures for managing this problem have been shown to be insufficient to prevent impacts on waterways (refer: EPA fines Dendrobium Coal $15K for alleged water pollution https://www.epa.nsw.gov.au/news/media-releases/2021/epamedia210401-epa-fines-dendrobium-coal-$15k-for-alleged-water-pollution ).

2. Koala impact: local koala populations have been under threat for many years and the impact of the 2019 bushfires has meant that this species is threatened and needs protection. The mine expansion will directly impact the koala populations in that area. The Environmental Impact Statement notes the existence of this koala population however there are a number of omissions in the Statement. There has been no survey conducted to map out the current koala populations and where they are located within the catchment area; there is also no management plan noted on how these populations will be protected and managed across the whole project from commencement through until 2041. These are critical omissions considering how endangered our koala populations are (refer: https://www.abc.net.au/news/2022-06-02/dendrobium-mine-impact-koala-population-nsw/101119502 and https://www.australiangeographic.com.au/news/2022/05/nsw-government-lists-koala-as-endangered/ )

3. Impact on First Nations Peoples Cultural Sites: There are 31 First Nations Peoples cultural sites within and nearby the proposed expansion site - some of these sites are located directly above the proposed longwalls. Lessons should have been learned from the destruction of cultural sites that occurred in Western Australia in 2020 when Rio Tinto actually blew up ancient sites that had been established for over 40,000 years - these sites can never be replaced and undertakings were made that this never happen again through the Juukan Gorge recommendations. Notice should be taken of the concerns outlined by the Illawarra Aboriginal Land Council referring to mining operations in the Illawarra region (refer: https://www.abc.net.au/news/2021-10-19/nsw-government-urged-to-adopt-juukan-gorge-findings/100550518 ) The cultural sites which include artworks and archeological deposits in this area need to be protected for future generations. I am not convinced that any mining company will do this, especially as the industry track record shows a disregard for these sites.

Thus for the above reasons I am very much opposed to this project proceeding. There is too much at risk, firstly to the water catchment and water quality for over 5 million people; to the continuation of the local koala population and finally (but no less importantly) to the preservation of First Nations Peoples cultural sites.
Keith Horton
Object
MOUNT PLEASANT , New South Wales
Message
Early last year, the NSW Independent Planning Commission stopped coal mine expansion plans at Dendrobium, 'finding the proposed mine design risks long-term and irreversible damage to Greater Sydney and the Illawarra’s drinking water catchment.' Now South32 has submitted a revised plan. There are many independent reasons that together constitute a decisive case for stopping this plan too. I briefly itemise them below.
1/ The Project would certainly result in losses to Sydney and the Illawarra’s drinking water catchment, possibly severe and irreversible ones. The last time South32 proposed longwall mining in the same area the NSW IPC found that there was a risk of 'potentially irreversible impact upon the quantity and quality of surface water in perpetuity.'
2/ The Project would result in a tripling of direct (Scope 1) Greenhouse gas emissions. At a time when the window of oppurtunity for action that would give us at least some realistic possibility of preventing the worst effects of climate change, the Project is therefore unacceptable.
3/ 16 swamps listed as ‘threatened’ will be undermined by longwall mining. When the NSW IPC refused consent for the previous longwall proposal, they concluded that there was 'no documented, reliable and practical rehabilitation technique for returning the pre-mining water balance to the impacted swamps'.
4/ The Project would negatively impact the local koala population. No proper scientific examination of that population has been conducted, so we simply don't know how many koalas live in the area impacted by the Project. Given that koalas are now listed as endangered, the Project should certainly not go ahead prior to such an examination.
Catherine Dyson
Object
CRONULLA , New South Wales
Message
Water is the foundation of life.
In a world of uncertain future, politically and climate , how can we knowingly put at risk the water supply for Australia’s major city . Very short sighted. The long term consequences will last must longer than when new steel making techniques are in use.
The NSW government has a program to save koalas and yet this project has no proper assessment on effect on koala numbers and habitat.
We visit museums around the world to revere evidence of past cultures and yet we knowingly pay no heed to The Original Australian concerns about destruction of cultural heritage if the mine extension proceeds .
Evidence of a colonial past of disregard to Aboriginal cultural heritage continue.
The NSW government can use this as an example of not repeating the sins of the past .
Minister Roberts I implore that you be the new shining beacon to show that Liberal governments have climate action as a priority and NSW can lead the way in good planning for the future of NSW residents.

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Project Details

Application Number
SSI-33143123
Assessment Type
State Significant Infrastructure
Development Type
Coal Mining
Local Government Areas
Wollongong City

Contact Planner

Name
Gabrielle Allan