Dendrobium Mine Extension Project

I strongly object to the Dendrobium Mine Extension Project, for several reasons.
This expansion will cause the loss of 8 billion litres of water each year from the Greater Sydney Water Catchment (groundwater and surface water losses), including losses direct from Avon and Cordeaux Reservoirs. This is the same volume of water as the average consumption of 110,000 people. Water security is only going to become more important in a changing climate, and it is absurd that ongoing mining in the water catchment Special Areas is allowed to continue.
Secondly, the impacts of this project on Aboriginal Cultural Hertiage and the cultural integrity of the region are inexcusable. We know that Traditional Owners object to the knowing destruction of their sites, and we need to take cultural heritage protection seriously.
Thirdly, this is the first mine in NSW to be granted SSI status. It has become clear that DPIE gave South32 advice regarding how it could get this proposal approved. This SSI resembles state capture by the mining industry, and is fundamentally anti-democratic. The community deserves real accountability and transperancy in this process, and a right of appeal. I, and others, are asking for the involvement of the Independant Planning Commission in this process.

I believe this project will hinder the country's ability to meet our commitment to reaching net zero carbon emmissions. The project is intended to last over another 20 years. This project does not reflect what the general population want. The recent federal election outcome reflects that the public wants serious climate action. We would be expecting to be stopping mining coal a lot sooner than this.
Further, apart from the additional CO2 that would be unleashed, i have serious doubts the mine can work successfully without damaging the environment - especially our water supply and habitat.
Could we please be working on more environmentally responsible ways to get our energy!

I write to strongly object to this mine extension. I cannot support this project due to the extreme risk to the Wollongong and Sydney water catchment, and to the environment.

Water is fundamental to life. It would be a failing today, and to generations to come, if this project were to be approved.

Please do not approve this project.

This project is critical to the Illawarra region. Having spoken to lots of people who've lived here for decades, I understand that the mines in question support a host of local businesses and associated ecosystems. It is critical that we as the community be mature when it comes to such decisions and not take a biased or lopsided view of the situation. Having reviewed the submission documents itself, i seems that the recommendations of the planning commission have been taken very seriously and decent thought given to minimizing any impacts to the environment and heritage sites. This demonstrates responsibility and integrity at the part of South32. We need to make sure that we secure these resources to ensure we pave a sustainable future for the local steelworks and Australia going forward.

To whom it may concern,

I wish to express my objection to the proposed Dendrobium Mine Extension Project for the following reasons:

1. The NSW Independent Planning Commission has already rejected a previous form of this project due to the unacceptable risk it poses to the security of drinking water within the Special Catchment Area which supplies not only the Illawarra but also Greater Sydney. Due to global climate change and the high susceptibility of Australia to drought the compromising of potable water supplies by underground coal mining is absolutely unacceptable. Overruling of the IPC by declaring the project state significant is nothing short of a cynical play by the NSW government to facilitate the interests of mining companies at the expense of local communities.

2. Efforts to monitor water losses within the Special Catchment Area highlight the enormous uncertainties associated with mining-induced damage; in short the current monitoring activities are insufficient (too few flow meters and bore holes, relying on industry to self-report on mine inflows, lack of in-depth literature assessment - see NSW chief scientist report by panel for mining in catchment and open letter to premier) meaning that the full impact of mining damage on water losses is underestimated. Furthermore, there is absolutely no guarantee (from academics or industry representatives) that the mine can be sealed at the end of working life to prevent further water losses.

3. Damage and fracturing of overlying strata are already well-documented within the Special Catchment Area. This not only causes water loss but compromises water quality and causes other environmental problems. Fracturing of overlying strata causes high inflows of heavy metals into the catchment due to the extraction of these metals by rain water in direct contact with fresh rock surfaces. This is in contrast to pre-existing exposed rocks which have already been weathered/leached thousands of years before. Furthermore, the fracturing of overlying rock strata permanently compromises the impermeable strata in swamp areas which would otherwise retain moisture all year round (see again chief scientist report). The drying out of swamps results in environmental degradation not only from the destruction of natural habitat for animals such as frogs and koalas (already under enormous environmental pressure), but also creates significant bush fire hazards in the catchment areas due to a lack of moisture.

4. The economic benefits from the mining of metallurgical coal in this mine are highly inflated and exaggerated. The majority of coking coal from the southern coalfields is exported overseas by foreign-owned companies, therefore the majority of economic benefits are not retained by Australian citizens. In addition, BlueScope does not require the use of coking coal from the southern coalfields for steel production and can import it from elsewhere. The production of steel using hydrogen rather than coking coal has already been demonstrated at an industrial scale, therefore the NSW government has an obligation to support BlueScope in transitioning to this technology rather than continuing to allow the use of outdated and the environmentally damaging use of coking coal for steel production. Furthermore, the continuation of coal mining in the Illawarra inhibits the transition and re-skilling of workers to jobs in renewable energy industries as the economic future of coal continues to seriously deteriorate.

5. The NSW Planning Department has shown to exhibit behaviour which may be considered corrupt by the average person. Emails obtained under Freedom Of Information (FOI) laws provided to the ABC show the NSW Department of Planning "coaching" South32 in their application for the mine extension. This is nothing short of deplorable behaviour by public servants who should be investigated by ICAC. This completely undermines the credibility of the NSW Planning Department to undertake its functions in a transparent way, and the function of government to act in the interests of the communities they represent.

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This is not an extension to the current mine, but a new development. Neither can it be considered as critical, or even necessary.
No matter what the proponents claim, there is unacceptable risk to the environment in general, and to the Sydney water catchment, it should be refused.
From a global perspective it is completely at odds with the need to reduce carbon emissions. From a National and State perspective it is completely at odds with the need to reduce carbon emissions.
It flies in the face of the IPCC and the United Nations, who both suggest that no further coal mines be opened.
The mine is not only not necessary, but constitutes wanton vandalism perpetrated by the NSW Government if it is approved.

I support the project. The long history of coal mining in the Illawarra to produce coking coal primarily for steel making has sustained employment in the region for decades. Australian mines have been shown to world leading in technology and driving improvements in safety. The project in my belief considered the environmental impact and adequately addressed concerns.

There is nothing in this Dendrobium Mine Extension that will be an asset to the future planning of our State of NSW and Australia.
To extend the life of this coal mine to 2041 is a slap in the face to younger generations adding to global warming and the disastrous effects of climate change with extreme weather destroying lives and expensive infrastructure.
Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment.
Proposed mining is in the Special Areas of the water catchment upon which 5 million people rely for drinking water.
The stated position of Water NSW: "There should be no mining in the Special areas of Greater Sydney Water Catchment"
How could the Minister even consider giving approval to this project ignoring the advice of his own department ?
Mining induced subsidence will damage the water courses and swamps that feed our drinking water reservoirs.
Our drinking water catchment is essential infrastructure and should be prioritized over a privately owned coal mine.
If approved, the mine will result in water losses to the Avon Reservoir, which is the only source of water supply to over 310,000 residents and businesses in the region. In dry years , water courses in the mined area that flow into the Avon Reservoir are expected to dry up.
Southern Catchment is vital to the sustainability and resilience of drinking water to Sydney and Wollongong.
The expansion is not consistent with current land use of the area as a water catchment.
As water courses fracture due to mining induced subsidence, metals will be dissolved and leach into the water leading to an increase of metals in water courses
worsening in the 100-200 year period of groundwater recovery. It is essential that mi ne infrastructure and monitoring is adequate to the real world conditions already experienced , let alone the predicted and modelled increase in heavy rainfall that could impact sediment ponds and dams as the climate impacts intensify. It is simply not enough to say that the project meets outdated technical requirements, rather than standing up to the conditions that we are all experiencing.
There are 31 Aboriginal Heritage sites in and close to Area 5 , with 6 of these sites directly over longwalls.
Sadly, South 32 have no interest in preserving Aboriginal Culture or Heritage, typically destructive and disrespectful of others and the consequences of their vandalism. South 32 provide no evidence as to why the PROFITS OF A PRIVATE COMPANY should be PRIORITIZED over ABORIGINAL CULTURAL HERITAGE.
Koalas have been declared endangered in NSW and they are present in this Area 5; Eco systems that would be cleared for mining infrastructure would have a devastating impact on koalas present in land to be cleared. Water loss and impact on swamps and waterways means that the eco systems are dewatered.
It is difficult for independent scientists to gain access to the Special Areas of the catchment to undertake research of koala populations.
There are so many reasons for this mine extension to be rejected including : Dewatering the swamps will result in local extinctions in breachof multiple layers of State and Federal legislative protection.
The mine extension will Impact on Aquatic Ecosystems, Impact on Upland swamps , Bushfire RISK and Climate impacts.
In total , the extension would result in 88 million tonnes CO2of greenhouse gas emissions.
To the Minister: as noted in the recent Federal election, Australians want action on Climate Change for their long term survival , that does not include supporting the Fossil Fuel industry, you need to make decisions for the community and support Nature so Nature can look after us.
Thankyou, Jennifer Fitzgerald Bushcarer Cronulla

The environmental impact and destruction caused by approving this mine extension far outweighs any benefit taxpayers and citizens to the Illawarra could ever receive. The threat to drinkable water in the catchment being contaminated is also too great a risk. Please do not approve the extension.

Please see my attached submission.

As a resident of Wollongong I strongly oppose this revised proposal for the expansion of the Dendrobium Mine Extension (SSI-33143123) . My reasons include that:
1. It will threaten our water security further at this time of climate crisis when rainfall is completely unpredictable and devastating fires already threaten the integrity of the Greater Sydney Water Catchment.
2. It will increase Greenhouse Gas emissions (GHG) and so exacerbate global warming. The proposed Area 5 extension will have a gas concentration that will triple current Scope 1 GHG from this operation, becoming the 4th highest GHG emitting coal mine in NSW. These emissions will be predominantly fugitive methane which must be urgently reduced if NSW is to reach its goal of net zero emissions by 2050.
3. It will threaten the integrity of Aboriginal cultural sites in the area. There are 31 Aboriginal Heritage sites in and close to Area 5, and 6 of these lie directly over proposed longwalls.
4. It threatens the environment in a known koala habitat area. This species has been declared Endangered in NSW. The EIS notes there are koalas living in the area that will be undermined, yet no current survey numbers or locations are included. There is no comprehensive management plan for these koalas. The water loss resulting from fracturing, poses a real threat to the survival of flora and fauna in the catchment.

The Dendrobium Mine Extension proposes 19 years of destructive longwall mining in the water catchment for Wollongong, Macarthur and Sydney.
This project was deemed State Significant Infrastructure based on the rationale that it was essential for the continued operation of the Port Kembla steelworks. However Bluescope has revealed they have already made provision for acquiring its coal from other mines.
Sydney is the only city in the world to allow longwall mining in a publicly owned water catchment. The process of longwall mining induces subsidence which is proven to fracture the rock structure overlaying the mine, and drain watercourses and swamps which are both critical to the integrity of our water supply. South 32 itself predicts that the 305 metre wide longwall panels it seeks may result in subsidence of 2-2.45m. This is certainly enough to cause significant further damage to the rock structure and reduce flows of water to our reservoirs, as well as contaminating water in the area. This fugitive water flows into the mines, adding to the cost of mining, and eventually flows out of the mines picking up contaminants on the way. There is no long term solution to this fracturing of the rock structure which can be seen in many locations on the escarpment and further inland.

Approval of this proposal would bring the mine to within 1000m of the Avon Reservoir and result in water loss from the reservoir. The Avon Reservoir is the only source of water supply for the residents and businesses of the Illawarra region. Our water security must be taken seriously and protected.

This decision is one which pits the profits of a private company against the water security of a rapidly growing urban area (now recognised as part of Greater Sydney and an important area for the growth of Sydney itself). It pits profits of a private company against the reduction of GHG emissions and climate security into the future. It pits the profits of a private company against the protection of our Aboriginal and ecological heritage. I urge you to reject this mine expansion proposal.

I object to the Dendrobium Mine Extension Project (SSI 33143123) for the following reasons:
1. The expansion is not consistent with current land use of the area as a water catchment
2. Its adverse impact on:
• Climate
• Koalas and their habitat
• Aquatic ecosystems (coal wash, mine outflow and brine dumping on creeks, waterways, harbours and oceans)
• Upland Swamps
• Sustainable jobs
• Water Quality
3. Damage to Sydney and Wollongong’s drinking water catchment and Aboriginal Cultural Heritage
4. The rationale for State Significant Infrastructure Status is flawed
5. Risk of bushfire and of damage from Phytophthora cinnamomi

I object to this extension.

Dear Commissioner,

It is my pleasure to write a letter of support for South 32- Illawarra Metallurgical Coal’s Dendrobium Mine Extension Project. I am writing this letter on behalf of the Illawarra Innovative Industry Network – i3net.

About Illawarra Innovative Industry Network - i3net
The i3net is a powerful network of industry-based companies working from the Illawarra. The network was established 20 years ago to promote the collective capability of Illawarra Industry to local, national, and international markets. Industry within the Illawarra forms a vital foundation of the local economy. Accordingly, community support for Mining, Coal and Industry is strong in the Illawarra. It’s in our DNA and is a proud part of our heritage.

As the premier network of industry-based companies working from the Illawarra, we represent small, medium and large businesses in the industrial supply chain. This extension project is critical to the 526 Wollongong manufacturing businesses (Business count ABS June 2018 cat. 8165) and the 10,000 individuals (.id, June 2019) who work in the local Manufacturing, Professional, Scientific & Technical services. The i3net fully supports South 32 Dendrobium Mine Extension Project.

At a local level, South 32 continues to show their commitment to the Illawarra region by:

• Employing about 2,000 people, more than 90% live locally.
• Purchase from more than 200 local businesses, equating to $240M annual spend.
• Investing more than $1M annually to community projects and activities.
• Increased spend with Aboriginal businesses about 12% in FY22.



Revised Mine Plan
We welcome the revised mine plan that incorporates feedback from the previous application and reduces environmental and cultural impacts.

The Dendrobium Mine Extension Project will enable the continuation of mining activities at Dendrobium Mine in new areas within the existing mine lease, extending the mine life by approximately 10 years.

 
The extension would create:


• 100 construction jobs
• 50 new permanent project job
• ongoing employment of 650 existing local jobs.

We also support the additional environmental safeguards such as:

• Preserve water catchment - 60% reduction in the longwall mining area
• Preserve key streams and rivers with 400m setbacks
• Significantly reduce mining beneath threatened swamps
• Preserve key dams with the mine plan setback at least 1,000m from dam walls
• Significantly reduce surface water loss by about 78%
• Reduce the number of Aboriginal Heritage sites mined beneath by 73%.


Local impact
The Dendrobium Mine Extension Project is possibly the most significant decision affecting this region, due to the potential impact on Illawarra’s industrial supply chain. If it is not approved, it could result in up to $10 billion per year in losses and detrimental impact to the Wollongong regional economy.

BlueScope Steel generates ~$6.5 billion in regional economic output, equating to 24% of the Illawarra total output while directly employing 3,500 workers. Their Port Kembla Steelworks consumes approximately 3 million tonnes of metallurgical grade coal per annum, of which over 90 per cent is sourced from mines located in the Illawarra region.

These principal coal sources for BlueScope include the South32 - Illawarra Metallurgical Coal’s group of mines comprising Dendrobium and Appin, the Peabody Metropolitan Colliery and the SIMEC Tahmoor Colliery. Any interruption or reduction of capability in this supply chain would critically jeopardise BlueScope’s ongoing ability to produce coke at Port Kembla.

We quote BlueScope (2019) when they stated, “Without this supply, steelmaking would struggle to remain viable at Port Kembla.” This statement is truly alarming for the Illawarra, NSW, and the Sovereign Capability of Australia.

The ongoing economic viability of the premium hard coking coal mining, iron smelting and coal transport and shipping businesses located in and around the Wollongong - Port Kembla area and elsewhere through the Southern Coalfield of NSW is critically dependent on the continuing success of both South32-Illawarra Metallurgical Coal and BlueScope Steel.

Significant changes in either of these businesses would cause adverse flow-on effects to other coal and steel-related businesses that are vital to this region.



Recommendation
We are in full support of the Dendrobium Mine Extension Project and respectfully ask the Department of Planning, Industry and Environment to consider the vulnerability of the local industrial supply chain before making its decision. This region’s economic sustainability is incredibly sensitive to price changes. An ongoing supply of competitively priced metallurgical coal from the Southern Coalfields is an essential feedstock for the Port Kembla Steelworks, thereby supporting local businesses, jobs and local economic activity. The strategic interdependencies between local coal supply and Illawarra steelmaking are significant; one cannot exist for long without the other.


For further information, or if you have any questions, please contact me on the below details.


Yours Sincerely,

Bianca Perry
Chief Executive Officer
i3net

To whom it concerns,

I am writing to you to oppose the Dendrobium mine expansion in the strongest possible terms. There are no other cities in the world that permit coal mining within their water catchements. Mining is incompatible with clean drinking water and with the protection of the sensitive ecosystems that collect and filter this water.

Permission to expand the Dendrobium mine should be refused.

There should be no mining at all in the water catchement. This is a commonsense and popular position - I don't know anyone who beleives that these two activites can co-exist in the same location.

The risk of pollution events created by the mine is real, the value of clean water in the catchement to residents is simply not worth the risk. Discharge from the mine will need to be collected and treated long after the mine has closed - we have seen successive mining companies leave enviromental messes behind for governments and citizens to clean up for decades after.

This mine presents unacceptable risks to wildlife, inlcuding Koalas, which are engangered living in the catchment, fragile swamp reigons and sensitive aquatic ecosystems.

I am yet to see the reasoning for why the profits of a private company should be placed over the interests of generations of people living in Sydney.

I urge you to listen to the people who live in the area and depend on this water supply and please do not approve the Dendrobium mine expansion.

I am objecting to the Dendrobium mine extension.

This is a highly problematic development, and rightly so. Firstly, it is known that the subsidence under long wall coal mines is very damaging, not just to homes, but also to natural structures, such as river beds (e.g. the cracks in the base of the Tahmoor River) leading to extensive water loss undermining the crucially important Greater Sydney Water Catchment.

Secondly, coal mines need to be wound back, not expanded, to limit the emission of CO2, not just from the mining itself, but from the transport and the end use of the coal as a fossil fuel.

Thirdly, the prior rejection of this proposal by the Independent Planning Commission demonstrates that the decision to proceed with the proposal is political and not based on scientific evidence that highlighted the pitfalls this mine expansion will contribute too.

Approval of any coal mine extension in NSW will undermine the state government’s credibility in the eyes of voters. Promoting itself as a government making a speedy transition to renewable energy will be deemed as “greenwahsing”.

The Dendrobium Mine Extension Project is particularly not welcome as it is in the Sydney and Illawarra drinking water catchment. This alone should negate this expansion as it would in any other city of the world.

The news this week that NSW Planning has been “coaching” the mining company on how to get approval shows a complete disregard by Planning for an independent approval process. It also appears “unclear” if the Port Kembla based BlueScope Steel depends on coal from Dendrobium. Previous reports revealed that Bluescope had already planned to obtain coal from other mines . Substantial sums of public money from both Federal and NSW Government have been spent to help the steelworks investigate a transition to low or zero-carbon steel production.

The change of status to State Significant Infrastructure and the Planning department’s interference in the approval process reinforces my lack of trust in the Coalition government and the planning process.

References: https://www.abc.net.au/news/2022-06-10/dendrobium-foi-reveals-coaching-environmentalists-say-/101135878
https://www.illawarramercury.com.au/story/7543140/threat-to-steelworks-overblown-if-mine-closes-says-councillor/

I object to the Dendrobium Mine Extension Project on the grounds that it would unacceptably worsen the climate crisis.

This project would increase the production fossil fuel (with respect to global, Australian, and NSW levels). As such, this project proposal, and
any approval for it, should be regarded as climate crimes.

The criminal nature of such a proposal is evident from the following report published in March 2022 (attached),

Phaseout Pathways for Fossil Fuel Production Within Paris-compliant Carbon Budgets
https://www.research.manchester.ac.uk/portal/files/213256008/Tyndall_Production_Phaseout_Report_final_text_3_.pdf

Based on a 50:50 chance of not exceeding 1.5◦C,

“The report makes absolutely clear that there is no capacity
in the carbon budget for opening up new production facilities
of any kind, whether coal mines, oil wells or gas terminals.”

Also attached, is a document I wrote to explain the urgent need for supply-side measures to address the climate crisis. Notably, these measures include an immediate ban on any new fossil fuel projects in Australia. Of course, this includes coal mine extensions such as the proposed Dendrobium Mine Extension.

Yours sincerely
Dr Andrew Norton