Dendrobium Mine Extension Project

Coal mining has been undertaken in the Illawarra Region for over 170 years. The coal mined in the Illawarra region is metallurgical coal, which is a vital ingredient for steel making that has no current alternative supply for primary steel making. Steel is in most products every person uses today, including household appliances, cars, house structures etc.
Whilst metallurgical coal is not destined to producing power, it is part of steel making, and steel is used in most (if not all) of the installations of "green energy" generation devices. Steel casings on generators, steel towers for wind turbines, steel frames for mounting solar panels, steel re-enforcing in concrete foundations etc.
Illawarra Metallurgical Coal made the decision many years ago not to Longwall mine directly under rivers dam walls and dam reservoirs, with significant standoff to these key features to assist minimising risk. The Australian mining industry is continually learning and improving with data collection, and should be allowed to continue to mine as it is a leader in the world at mining responsibly. If the project does not go ahead, it will significantly impact the Wollongong Region, and may have flow on effects to the businesses it supports. The world demand for metallurgical coal will remain regardless of this project, and if not supplied by Australia in a responsible manner, then the same volume will be supplied from an alternate mine that is most likely in a less environmentally regulated country.
The project injects significant cashflow into the economy and maintains jobs in the region. The people and companies paid for services directly by the mines then spend that money at other businesses that goes to paying wages to people being indirectly supported by the mining industry. There are people that are working in shops, tradespeople with small businesses, professionals offering services such as medical, financial and legal services that are often being paid indirectly by people working in the mining industry and not even realise where the money is coming from to support the economy.
The project should be approved.

I’m writing to you as a high school student who is deeply concerned by this mine extension project. This mine is a violation to the climate emergency, which has been declared by the Wollongong Council and countries such as: Britain, France and Denmark. It is my belief that we should be revolutionising our technologies and energy sources. By this I mean we should no longer be stuck in the past by using filthy pollutants like coal as our source of energy. We should be taking steps towards a sustainable, clean future. New South Wales, as Australia’s most polluting state needs to take immediate climate action by encouraging renewable energy sources, like: solar, wind and tidal. This mine extension would be a let down to all environmentalists and anyone who hopes for an enjoyable future. By adding this extension to the already existing mine, it would only be accelerating the rate of the climate crisis, giving us even less time to fix this issue. This mine also holds the potential to poison the water catchment area and many vulnerable species on flora and fauna in the surrounding area. This can have devastating affects on the environment. The water catchment area is meant to be in pristine condition but allowing this Dendrobium mine extension project to take place, would be jeopardising the quality of the water. After all, how clean can water really be with a large, toxic mine beneath it?

I support an industry that employees many local residents and provides a high quality product to our local steel manufacturer.

Water loss occurring due to subsidence in the Cordeaux Dam catchment is an alarming prospect that local residents have had to consider in recent years. There are not adequate environmental checks and balances to ensure economic profit is not tempered by ecological common sense.
The following quote is from Peter Turner, the National Parks Association of NSW mining projects officer.
"The valley bulging, which then causes deformation to the rock underneath and around the reservoirs, generates leakage pathways from the reservoir into the groundwater system, so it is meant to be causing water loss around Cordeaux... For Cordeaux it is uncertain how much water loss is occurring but it is certain with more mining, whatever loss is occurring is only going to get worse."
And it continues,
“A lack of pre-mining data, limited monitoring, and inadequate catchment and reservoir water-balance modelling make it essentially impossible to reliably determine how much water was actually being lost.”
In an article from the Sydney Morning Herald by Peter Hannam:
"In a 2014 report on mining in the catchment, the NSW Chief Scientist found Sydney was alone among major cities to permit such activities."
Entomologist Dr Ian Wright has studied the effects of subsidence on stream macroinvertebrates, and has found significant changes in our wetland swamps due to subsidence caused by mining activities.
Please stop dangerous mining activities that threaten the sustainability of our local area. It is difficult to educate the next generation about sustainability while such reckless practices are occurring in our drinking water catchment.

• Supporting 500 full time operational jobs
• Create 200 additional jobs during construction
• A$2.8 billion net economic benefit to NSW
• A$1.1 billion net economic benefit to the Illawarra
• Generate A$714 million in rates, royalties and taxes
• Continue the supply of high-quality metallurgical coal for steelmaking to our local and international customers.

I support the extension of the Dendrodium Mine Extension Project for the following reasons:
• Supporting 500 full time operational jobs
• Create 200 additional jobs during construction
• A$2.8 billion net economic benefit to NSW
• A$1.1 billion net economic benefit to the Illawarra
• Generate A$714 million in rates, royalties and taxes
• Continue the supply of high-quality metallurgical coal for steelmaking to our local and international customers.

I support the extension of the Dendrobium Mine Extension Project for the following reasons:
. Supporting 500 full time operational jobs.
. Create 200 additional jobs during construction.
. A$2.8 billion net economic benefit to NSW.
. A$1.1 billion net economic benefit to the Illawarra.
. Generate A$714 million in rates, royalties and taxes.
. Continue the supply of high-quality metallurgical coal for steelmaking to our local and international customers.

I support the Dendrobium Mine Extension Project as it good for the countries economy, supports local jobs, supports local businesses, supports BlueScope. The coal is used for steel making and having just built a home we have a colorbond roof made from local coal.

This is an important project for our region for many reasons including helping to sustain the workforce directly and indirectly to the mine but also in providing a cost efficient and secure supply of metallurgical coal the the Port Kembla steel works. The mine has successfully operated for many years now with no record of environmental destruction and no major safety incidents. I think that he company has successfully demonstrated that it is possible to responsibly operate a coal mine in this geographical location without impacting the environment whilst providing sustainable employment and supply to the region.

Australia's export earnings are vital to the future of this nation. Our two biggest export earners are Coal and Iron Ore which are used together to make steel, on which the World relies for future development.

Furthermore, a major economic activity of the Illawarra is the Port Kembla steel blast furnace. This generates many jobs in the region.

Dendrobium Coal Mine is a critical contributor to our nation's export of metalliferous coal and a vital supplier of this type of coal to the Port Kembla blast furnace.

The Dendrobium Mine also provides significant and highly paid employment opportunities (which extend far further than the gates of the mine) for residents of the Illawarra, the Southern Highlands and the Macarthur District where I am located. Without this economic stimulus including its multiplier effect, I fear for the future employment opportunities of people living in those localities.

I have not heard of there being any significant safety or environment issues connected with the operating of Dendrobium since it opened in the early 21st Century.

Our Company is engaged in several contracts with South32 and we have found them to act in a socially, economically and environmentally responsible manner. The Dendrobium Project extension would secure employment for approximately 50 of our personnel in the local area, currently engaged either directly or indirectly with the activities of the Dendrobium Mine. As a privately owned, local company, the project is of significance for our organisation as a whole.

Our View on the extending the life of mining operations at Dendrobium;
• Supporting 500 full time operational jobs
• Create 200 additional jobs during construction
• A$2.8 billion net economic benefit to NSW
• A$1.1 billion net economic benefit to the Illawarra
• Generate A$714 million in rates, royalties and taxes
• Continue the supply of high-quality metallurgical coal for steelmaking to our local and international customers.

I agree with the proposal.

SUBMISSION ON THE DENDROBIUM MINE EXTENSION SSD-8194

Illawarra Coal’s Proposed Mine Extension for Dendrobium:

We object to Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194. TEC was one of the first groups some years ago, to sound the alarm about the adverse water catchment impacts of longwall mining as cracks began appearing in streams and valley sides. Unfortunately our predictions have to come to fruition with clear evidence of loss of water flows and the failure of ‘monitoring’ (the key strategy) to improve outcomes.

The Dendrobium Mine Extension Project proposes 30 years of longwall mining in the water catchment for Wollongong, Macarthur and Sydney. It will result in damage and loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs .
Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment.

We understand the Dendrobium project has the highest water loss of any mine operating in the Greater Sydney Water Catchment area. In the era of drought and a growing population, Sydney and the Illawarra can ill afford to further damage their water catchments.

There are still 11 years of mining at Dendrobium under current approvals (for areas 3A and 3B) and South 32 operates other coal mines in the region. South 32 is selling only one third of Dendrobium’s coal to BHP for use in Port Kembla Steelworks. It is exporting the other two thirds. Bluescope Steel’s Port Kembla steelworks declined to confirm that the steelworks would collapse if the proposed Dendrobium expansion does not go ahead.

South 32‘s proposal to offset catchment land and ecological communities that have been irreparably damaged by mining is not a genuine measure to preserve the integrity of the catchment. While we have criticism of loose offset policies because they do not provide ‘like for like’ – the situation is even more pronounced as the lost water and wildlife habitat can’t be found elsewhere.

The 2016 Audit of the Sydney Drinking Water Catchment has numerous insights into damaged caused by aggressive longwall mining:

“The auditors found that there was reduced water availability across the Catchment in 2013-16 compared to the previous audit period and the overall total surface water extraction has increased since the previous audit periods”. (p13)
“The available data indicates that there has been a decline in the extent and condition of wetlands in some areas of the Catchment and efforts to rehabilitate wetlands that were impacted by longwall mining have been unsuccessful to date”. (p14)

The proposed mining is just 300m from Avon Reservoir and 630m from Cordeaux Reservoir . The mining will cause loss of water from water courses and swamps that feed the reservoirs. Water loss from the catchment due to Dendrobium’s mining will increase over the coming years, with surface water loss expected to peak at 27.6 ML per day in the year 2035 .

Consultants estimate that up to 9,500 Megalitres (ML – million litres) of surface and ground water will flow into the mines each year, which is the equivalent to the annual water usage of 123,940 residents of Greater Sydney .

This impact is unacceptable. We note that no alternative mine layout options have been presented. In our view this indicates a company with no regard for environmental impacts, hoping to push through a very damaging and long term mine layout. Such behaviour should not be rewarded with destruction of essential catchment values.

Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
https://www.illawarramercury.com.au/story/6295531/bluescope-wont-say-dendrobium-closure-could-finish-steelworks/
Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
ibid, p 111
Based on an average daily water usage for Sydney residents of 210 litres. Source:
https://theconversation.com/why-sydney-residents-use-30-more-water-per-day-than-melburnians-117656

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.

The Dendrobium Mine Extension Project proposes 30 years of longwall mining in the water catchment for Wollongong, Macarthur and Sydney. It will result in damage and loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs[i]. 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. We are in drought, paying for desalinated water and our dam levels are below 50% and yet the Dendrobium proposal has the highest water loss of any mine operating in the Greater Sydney Water Catchment area.
This project is not in the public interest; it is in the wrong place at the wrong time. It would be reckless and immoral for the Department of Planning to support this expansion.

The proposal will result in significant quantities of greenhouse gas emissions

The proposal is estimated to create up to 23.7 million tonnes of CO2e in the production stage and 237 million tonnes in the transport and consumption of the coal produced. This brings the total emissions to between 256 million and 260.7 million tonnes of CO2e for the life of the project[ii].

The current climate emergency means it is no longer morally acceptable for the NSW government to support projects that will severely negatively impact its capacity to meet greenhouse gas reduction targets. The Rocky Hill case supported climate responsibility in its judgement against the Rocky Hill mine, citing the mining SEPP Clause 14 (2): “... the consent authority must consider an assessment of the greenhouse gas emissions (including downstream emissions) of the development.”[iii]

To put the volume of emissions in context, the federal government estimates Australia’s greenhouse gas emissions for the year to December 2018 as 538.2 million tonnes[iv]. Thus approval of this mine would lock in emissions over the life of the project the equivalent of 48% of the 2018 annual emissions for all of Australia.

Annually it would add an average of 8.69 million tonnes per annum (260.7 million tonnes over 30 years) of CO2e to the atmosphere[v]. This is comparable to 1.6% of Australia’s current annual emissions.

South 32’s brinkmanship should not compromise public interest

South 32 has said that if this proposal is not approved, it will spell the end for the Port Kembla Steelworks and the Port Kembla Coal Terminal. This is misleading and unhelpful to understanding the public interest in relation to this coal mine.

There are still 11 years of mining at Dendrobium under current approvals (for area 3A and 3B) and South 32 operates other coal mines in the region. South 32 is only selling one third of Dendrobium’s coal to BHP for use in Port Kembla Steelworks. It is exporting the other two thirds.

Bluescope Steel’s Port Kembla steelworks declined to confirm that the steelworks would collapse if the proposed Dendrobium expansion does not go ahead[vi], so we have to question the truth and motivation for this brinkmanship.

30 year’s of mining is too long

South 32 is seeking approval for 30 years of mining at Dendrobium. This is far too long. Increasing population pressure on water resources and impacts of climate change mean that it would be reckless and irresponsible for the New South Wales Department of Planning to support a 30 year approval.

South 32 has not provided alternatives to this aggressive and destructive mining proposal

The proposal comprises an aggressive plan for twenty one 305 meter wide longwall panels over 30 years. It provides no alternatives to this destructive proposal, a proposal which poses unacceptable risks to the Greater Sydney Water Catchment Special Areas.

Offsets do not compensate for mining-induced destruction of catchment land and ecosystems

South 32‘s proposal to offset catchment land and ecological communities that have been irreparably damaged by mining is not in the public interest; truly like-for-like offsets are rare. Furthermore, there is no “equivalent” land that could compensate for damaged and compromised water catchment.

Mining induced subsidence will damage the watercourses and swamps that feed our drinking water reservoirs

South 32 predicts that it’s 305 meter wide long wall panels may result in subsidence of 2m to 2.45m[vii]. Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative[viii].

The mining and associated subsidence will also cause cracking of the land on the surface – including rivers, creeks, smaller watercourses and swamps that feed our drinking water reservoirs – and subsequent water loss to the catchment.

No level of damage is acceptable to the Special Areas. It would be immoral for the NSW Department of planning to support this level of destruction in Greater Sydney’s water catchment.

Billions of litres of water will be lost from Greater Sydney’s Water Catchment

The proposed mining is just 300m from Avon Reservoir and 630m from Cordeaux Reservoir[ix]. The mining will cause loss of water from water courses and swamps that feed the reservoirs.

Water loss from the catchment due to Dendrobium’s mining will increase over the coming years, with surface water loss expected to peak at 27.6 ML per day in the year 2035[x].

Consultants estimate that up to 9,500 Megalitres[xi] (ML – million litres) of surface and ground water will flow into the mines each year, which is the equivalent to the annual water usage of 123,940 residents of Greater Sydney[xii].


I ask that you reject this application from Illawarra Coal and commence a process to close the mine at Dendrobium permanently.

Thank you for considering this submission.

Regards
Stephen Spencer

[i] Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[ii] Environmental Assessment Part 2, Section 6, pp 150 – 151 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[iii] Gloucester Resources Limited v Minister for Planning [2019] NSWLEC 7, Item 491, accessed at:
https://www.caselaw.nsw.gov.au/decision/5c59012ce4b02a5a800be47f#_Toc431203
[iv] http://www.environment.gov.au/climate-change/climate-science-data/greenhouse-gas-measurement/publications/quarterly-update-australias-nggi-dec-2018
[v] Environmental Assessment Part 2, Section 6, pp 150 – 151, op cit
[vi] https://www.illawarramercury.com.au/story/6295531/bluescope-wont-say-dendrobium-closure-could-finish-steelworks/
[vii] Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[viii] Ibid
[ix] Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[x] Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[xi] ibid, p 111
[xii] Based on an average daily water usage for Sydney residents of 210 litres. Source:
https://theconversation.com/why-sydney-residents-use-30-more-water-per-day-than-melburnians-117656

This project will help to support the Illawarra economy. Domestic and international requirements for steel are not diminishing and mining metallurgical coal in Australia is a safer and more sustainable option than most other parts of the world.

The project should be approved based on:
1) Economic benefit to the region.
2) The coal is prodominately used for steelmaking in which there is no current economically viable alternatives.
3) Relatively low environmental impact.

The Dendrobium Mine site produce high-quality metallurgical coal, much of which goes on to the Illawarra steelworks, supporting local manufacturing and regional jobs. To remove Dendrobium mine will mean removing our steel industry from the Illawarra, which will in turn, deny the Illawarra of thousands of jobs and millions of dollars of locally spent projects for the community to benefit from. This project has my full support to give the Illawarra a competitive future.

Mining makes a significant contribution to the local Illawarra area.
South32 directly employ 1,800 people and are the main supplier to the Port Kembla Steelworks.
Coal is the State’s largest single source of export revenue and the industry employs some 25,000 people across NSW.
The extension of the Dendrobium operation will provide the following;
• Supporting 500 full time operational jobs
• Create 200 additional jobs during construction
• A$2.8 billion net economic benefit to NSW
• A$1.1 billion net economic benefit to the Illawarra
• Generate A$714 million in rates, royalties and taxes

Australia's largest steel production facility, BlueScope's Port Kembla Steelworks, consumes over 3 million tonnes of coal per year throughout its steelmaking processes. Over 90% of their coal is sourced from local underground coal mines.
South32 is the primary supplier of steelmaking coal to BlueScope's Port Kembla Steelworks

This project supports local business, employment and the prosperity of our region. It would be detrimental to the community near and far if the Dendrobium project did not get approval. Having lived in the region my entire life, I am very aware that we are proud of our region and the rich coal mining history that makes up our community. This project is essential to continue our way of life in the Illawarra, and this company supports many businesses and the community through local projects.