Dendrobium Mine Extension Project

The expansion of the mine will continue to support many families in the area by providing a large number of jobs. We moved to Wollongong specifically for the unique job opportunities it offers and should this expansion not proceed it is likely we and many others will need to leave.

Dear Ministers and Decision Makers,
I totally object to creating new coal mines, or extending existing ones, because we're currently on track to warm the planet by a disastrous amount by the end of this decade. All levels of government in Australia should be reacting to this national emergency and doing everything in their powers to educate the population and reverse previous mistakes like allowing the mining and burning of fossil fuels.
Even the 2% target increase in global emissions is known at the UN level and below as highly dangerous. More than this will probably mean the death of most life on the planet. Our children's lives will be severely, adversely affected.
Australia is the driest country on the planet, and is currently having major fires, which started very early this year, in late winter. 90% of NSW is currently in drought, at the start of spring!
Climate change needs action NOW! We need to put 100% of our effort into renewable energy. We have stacks of renewable energy sources, many of them almost untapped (unlike Europe, who are way ahead of us}. Even China is leading us in switching to solar & wind power and electric vehicles. We need to get with the program and become a leader in this vital transformation, which also presents a huge opportunity for smart businesses. There are new industries to be exploited, from using waste to generate power and make recycled building materials to small scale wind (a wind turbine on every house and building). We also need to do away with our outdated, 19th century reliance on dirty, polluting coal.
This mine also puts water supplies at risk. At a time when water is becoming scarcer, this is absolutely not on! Most dams, rivers and water supplies are already dangerously low yet state and federal governments seem too paralysed to show the leadership and take the action we need. What are YOU doing about mines and irrigaters ruining our water systems?
Please use this mine as an opportunity to demonstrate that you can be real leaders and stop putting our kid's and our future at risk.
Thousands of school and university kids are marching for action on Climate Change this Friday. Show them you actually care and reject this mine extension!

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

The Project proposes 30 years of longwall mining in the water catchment for Wollongong, Macarthur and Sydney. Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. This, to me is insanity. The Project will result in damage to/loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs. The mining proposed is in the protected “Special Areas” of the water catchment upon which five million people rely for drinking water. We are in drought and paying for desalinated water. Our dam levels are below 50% and yet the Project has the highest water loss of any mine operating in the Greater Sydney Water Catchment area.

I do not believe the Project to be in the public interest. In my view it would be irresponsible and iniquitous for the Department of Planning to support the mine extension.

Additionally, the Project will result in significant quantities of greenhouse gas emissions:
• The Project 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. (Statistics sources available upon request.)
• 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.”
• 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. 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. This is comparable to 1.6% of Australia’s current annual emissions.


South 32’s intimidatory tactics 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.
• 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. In addition to South 32’s misleading statements one also has to question the truth of and motivation for their political manoeuvring.

30 years 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 irresponsible for the New South Wales Department of Planning to support a 30 year approval.

South 32 has not provided alternatives to this 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 its 305 meter wide long wall 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.
• 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. 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 million litres per day in the year 2035.
• Consultants estimate that up to 9,500 megalitres 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.

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.

Yours sincerely

Janet Castle

Emphasising the broader socio-economic benefits of the mine extension.

I would like to lodge my strong opposition to any extension of the Dendrobium Mine.

I am a Sydney resident, who relies on water from our major catchment areas. My children and grandchildren depend on this water, along all my neighbours and with millions of other Sydney residents.

Sydney, and many other areas across Australia, is facing severe water shortages this summer, and increasing danger of on going water scarcity as our planet continues to heat up in the future. As a nation, as a State, we have to recognise that water is becoming one of our most precious assets. We can live without coking coal but without water there is no life.
Really. Seriously.

We have irrefutable evidence that the existing long walk mining operations of the Dendrobium mine under the catchment area have already irreparably undermined upland sandstone. Cracking in river and creek beds, and under the swamp sandstone , is causing major leakages of water, and is seriously threatening vital natural water storage in this area.
This can not be repaired.
WaterNSW, the Independent Expert Panel for mining in catchment areas in NSW, all credible 'experts' in this field oppose an extension.
To allow further long wall mining anywhere near water catchment areas anywhere in this State would be irresponsible and reckless and,in the very near future, could well be considered an act of criminal negligence.

Mining in our Water Catchment areas must be stopped completely. In this drought ravaged country water, especially drinking water, is our most vital resource and its protection and conservation must take precedent over all other activities. It has been well known for many years that cracking of the rock of creek and river beds above underground mining has caused enormous water loss with some water courses drying up completely. This must not be allowed to continue.

Quoting Duncan Rayner, principal engineer at the UNSW Water Research Laboratory in this ABC piece https://www.abc.net.au/news/2019-09-17/longwall-mining-impact-on-drinking-water/11519970?fbclid=IwAR3e5zMv8OzRY5AVRMQgo1paOshEy61HB9zKFnyzoEDsVyX01w7UiT_Nn38
"Temperate highland peat swaps are endangered ecological communities that act like a sponge and a filter, releasing pure drinking water," "What we're seeing from swamps [in the water catchment] that are undermined, or that have had longwall mining going underneath them, is that those swamps no longer hold water. Their underlying sandstone is cracked and the swamps have dried out."

Extensive cracking of rock and subsidence of up to 3 meters has been noted. Such land disturbances are unable to be repaired and water catchments are permanently diminished. Our water supply is too important to be sacrificed for a short lived profit from coal mining.

An additional concern is that mining is also polluting surrounding creeks and rivers and valuable water is used for coal mining operations, further compounding the deleterious effects on water supply and ecological damage.

I urge the Dendrobium mine extension be rejected and no permits for future mining in water catchment areas be issued. All mining in water catchment areas should be halted and priority given to job creation in ecological restoration and remediation to the highest standards.

This project is vital to the survival of many businesses and individuals in the Illawarra, and is essential for the local and state ecconomy.
A lot of wok at great cost has been undertaken to minimise environmental impact, and I believe that details from the EIS have been misconstrued by some.
Social and ecconomic benefits to the region far outweigh any arguement against it going ahead.

I outright oppose coal (and gas) mining in our drinking water catchment areas. I have witnessed the situation at Waratah Rivulet and have video footage of sandstone slabs in the river bed the size of a bus up-ended from cracking and subsidence. The mining company were drilling and pumping polyurethane into the river bed like humpty dumpty. The water was clearly contaminated. The notion of approving the catastrophic destructive nature of this heavy industrial activity in our most sensitive areas is an outrageous and dangerous proposition. NSW needs water security and this proposal poses a significant threat to that. The proposal should be rejected in its entirety. Thank you.

I support the proposed Dendrobium Mine: Coal for Steelmaking Project for the following reasons:
* Continued mining would sustain the employment of Dendrobium's Workforce and create a further 100 jobs for the life of the Project and an additional 200 jobs in construction.
* The Project would allow South32 to continue to support local suppliers and contractors, providing additional security and longevity of employment in the region.
* South32 supports biodiversity research in the water catchment, incuding swamps and endangered species such as the Giant Dragonfly and the Littlejohn's Tree Frog.
* The Project commits to pursue opportunitis for industrial users to reuse our excess mine water
* The Project would provide an ongoing and essential local supply of metallurgical coal to BlueScope Steelworks.

I am concerned that South 32’s impact monitoring just measures water levels at discrete points, but fails to provide a water balance model that shows what water is lost from the surface, groundwater and ultimately our drinking water reservoirs, and what water is loss deeper underground and into mine workings.

I am also concerned that longwall mining will result in the heavy metal pollution of the groundwater, which will then pollute the surface water where it re-emerges, as documented by Dr Ian Wright from the Berrima Colliery.

I am particularly alarmed that the proposed longwalls will destroy the recognised Endangered Ecological Communities, temperate upland peat swamps on sandstone. Longwall mining cracks the bedrock, draining the swamp, and causing it to dry out. I visited Swamp 1A, swamp 14 and watercourse 21 on Monday 16th September in the special catchment area and witnessed that Swamp 1A, which has been undermined, has dried out. The vegetation is desiccated and dying, and eucalypts start to grow in the drier soils. Overtime, the swamp vegetation will be replaced by schlerophyl forest species.

It alarming that the peaty substrate which usually retains soil moisture is dried. The long wall mining turns the upland swamp from a carbon sink that acts as a water sponge, to a dry substrate that is as flammable like a match-head.

The proposed long walls are exceedingly wide and deep, making the destruction from hundreds of metres below all the way to the surface inevitable. I note that a longwall mining proposal at Russell Vale was recently rejected because of the impact it would have on our drinking water catchment. See news item here: https://www.illawarramercury.com.au/story/4331721/coal-case-thrown-out/

I have had local Aboriginal community members raise concerns that the geological fracturing caused by long wall mining is destructively impacting Aboriginal heritage. Not only are rocks with significant carvings cracking, but water is being lost from sites in which water is essential to the cultural context. Axe grinding grooves are always along stream beds, and water is needed to sharpen the axe head. When water is lost from water courses through undermining, then the cultural landscape is degraded.

Mining buffer zones for watercourses will fail to protect cultural, ecological and reservoir-feeding water flow. This is because the water flow in watercourses relies on being fed by the slow, gradual water reticulation from the swamps. I object to the proposed mine expansion because it destroys the cultural landscape, failing to recognise the on-going living cultural importance of water to Aboriginal spirituality and heritage.

Area 5 and 6 are not 20km from the site of the Appin massacre. While these mining actions may not be as horrific as the murder of 14 Aboriginal men, women and children on 17 April 1816, it reflects the same hostility and disregard to Aboriginal life and culture. It’s time the social impact of desecrating Aboriginal artefacts, sites, landscapes and wishes is given greater consideration and respect. Please reject the proposed mine expansion, and protect the living Aboriginal heritage of this area.

I have also had concerns expressed by local Aboriginal community members that access to these areas is limited and difficult to obtain. 

I am also concerned about what legacy mining activity leaves. There are numerous historic and recent cases of remediation being underfunded, and failed.

I am concerned that the local economic importance of the proposed mine expansion is overstated. The majority of the coal currently mined by South32 is exported, not used in the local steelworks. Not all of the metallurgical coal Bluescope buy from Dendrobium and process in the coke ovens into coke is used in the blast furnace. Some of this coke is being exported. The economic benefits of short-term extractive resources is limited compared to the sustained in perpetuity water resource of over 5 million people. 

I am alarmed that South32’s stated approach to the climate change induced water scarcity is to further exacerbate carbon emissions through the use of energy-intensive desalination as seen in their Mozal (Mozambique) and Hillside (South African) Aluminium smelters. Water conservation and preservation are more rational, effective and long term solutions for the public good. Recent rainfall records has shown that Wollongong’s rainfall has been getting increasingly erratic and intense. (See Wollongong Flood Study, adopted by Wollongong City Council on 2nd September 2019: https://wollongong.nsw.gov.au/__data/assets/pdf_file/0008/42020/Wollongong-City-Flood-Study-2019.pdf).

South 32 are pursuing short term profits, despite long term environmental impacts to our drinking water supply and climate stability. The “Our approach to climate change” document outlines their “portfolio resilience to transition risks”, highlighting that metallurgical coal will be displaced by greater steel recycling using electric arc furnaces. (See page 33: https://www.south32.net/docs/default-source/all-financial-results/2018-annual-reporting-suite/our-approach-to-climate-change-2018885a4a9c121c46eea7c448f90f45114b.pdf?sfvrsn=8e343b48_4

ANU Energy Change are researching how solar power in the Pilbara can power coal-free iron and steel making: https://energy.anu.edu.au/eci-grand-challenge
Beyond Zero Emissions is an Australian research initiative that is also exploring ways to transition manufacturing to means that don’t require coal as a fuel source or a reactive agent. See: https://bze.org.au/research/manufacturing-industrial-processes/electrifying-industry/
ARENA is the federal government agency that has expressed support for providing a pathway to commercialisation for coal-free steel making technologies and businesses that would otherwise struggle to get off the ground or be potentially lost to overseas markets. During this transition Bluescope has sufficient access to metallurgical coal markets to feed its blast furnaces at Port Kembla. This expansion of Dendrobium long walls into Area’s 5 and 6 are not required for the immediate coking coal supply.

I am concerned about coal mining in Areas 5 and 6 will also have a deleterious impact on climate change. The greenhouse gas emissions from the mining, processing and then use of the extracted coal must be avoided. The recent Rocky Hill mine judgement, as well as decisions in the Bylong Valley, have shown that long-lasting environmental, heritage and social impacts of mining activities must be given credence.

Wollongong City Council has recognised that we are in a state of climate emergency. The Council completed an inventory of local government area (LGA) wide emissions, with the majority of emissions being derived from the industrial sector. The inventory has determined that the Wollongong Local Government Area has a carbon budget of 49 Mt CO2-e, which it must stay within in order to avoid the impact of catastrophic climate change. (Read more here: https://wollongong.nsw.gov.au/__data/assets/pdf_file/0012/43014/Item-6-Emissions-Reduction-Target-Global-Covenant-of-Mayors.pdf ) It is essential that the carbon emissions from this project are avoided for our cities, our state, and our nation are to have a safe and stable climate.

I request that you reject this application from Illawarra Coal so they can commence a process to close the mine at Dendrobium permanently and have a planned transition for its workforce.

I object to the proposed extension of Dendrobium mine . The Special Areas of the Sydney water catchment should be off limits to extractive industries. I am concerned about subsidence, cracking and impacts on quality and quantity of drinking water. I am concerned that past mining at Dendrobium has damaged ecological communities, swamps and water courses. NO level of damage to the Sydney drinking water catchment Special Areas is acceptable in these "protected" areas. I am also concerned about the substantial greenhouse gas emissions from both production and use of the extracted coal. I believe that this proposal should be rejected. I would like to see government support for a transition to fossil free steel production in Wollongong.

I may submit further comments upon release of the final Office of the Chief Scientist's Independent Panel Report on Mining in the Catchment.

I strongly object to the expansion of the Dendrobium mine under the Sydney water catchment. In these days of increasing concern over the future prospects of this country it is essential that a concerted effort is made to plan for the time when water security is the number one priority for the WHOLE community in the country's largest urban agglomeration. Profit-seeking (via coal exports) and the continued burning of fossil fuels are extremely short-sighted goals given the imminent, calamitous climate emergency facing this, the world's driest continent. I believe the time is right for responsible state governments to make a stand on this most arresting issue, given the long-term lack of real planning on such matters emanating from the national government.

A company which will cease to exist once it has ceased operations and will not have to live with the consequences is putting forward a proposal that creates damage and risks to the society, economy and environment long past its demise.

We have been asked to reduce our water usage long term and more immediately and severely because of drought conditions. We are paying for desalination plant operations which requires further power generation and increased salinity of seawater and other impacts on the marine environment. More desalination is not the answer. The population has increased and our economic policies will drive further growth as growth is considered to be important. We are at greater bush fire risk as climate change and weather events cause our forests to dry out. Increased average temperatures make having water accessible more important to maintaining quality of both the natural and urban environments.

Anything that risks the exacerbation of these risks and particularly where they will cause irreversible damage such as the destruction of rock structures impacting on drainage and seepage is unacceptable.

I have read the submission prepared by the Protect Our Water Alliance which outlines in more detail concerns consistent with mine. I am attaching an adapted version of that submission as an addendum to these comments.

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. 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.

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. Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative.
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. 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

This project is not in the public interest; it is in the wrong place at the wrong time.
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.

We 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

Please find attached preliminary submission from NPA Macarthur Branch.

I wish to object to the proposed Dendrobium mine extension, Project SSD-8194, on the flowing grounds:

Noise. I regularly visit Mount Kembla, the site of the Dendrobium mine, and find the noise that can be heard when bushwalking or visiting friends is very loud. I think that this level of noise is incompatible with a residential area. I note in the South 32 EIS they have no plan for reducing noise other than methods that are already in place and don’t seem to be working well.

Traffic. I find a high level of mine related traffic currently in the area, and see that the EIS is proposing a significant increase in mine traffic. I think this is objectionable in a residential area with only one road in and out.

I note that South 32 is proposing to build a large carpark on Cordeaux rd, as well as a significant number of other buildings, and even a tunnel under the road. I believe all these constructions are incompatible with the surrounding residential and natural environment. I also do not think that South 32 has addressed the visual impact these constructions will have on visitors and residents. I believe such a visual assessment was required as per the Planning Secretary’s Environmental Assessment Requirement, and I do not believe it has been done. “Visual including an assessment of the likely visual impacts of the development on private landowners in the vicinity of the development and key vantage points in the public domain, and minimising the lighting impacts of the development”.

I do not believe it is appropriate to have this expansion approved in a residential area. I note that at some stage South 32 are suggesting they access the workings from the Cordeaux mine, they should do that both now, and for any future mining. It is not a residential area and would not have the significant impacts that the current Dendrobium mine has. I also believe the 30 year time frame proposed is objectionable.

I also object to the quantities of greenhouse gas emissions that would result from any expansion. We are in a climate emergency, Wollongong Council has declared a climate emergency and yet South 32s plan would add an average of 8.69 million tonnes per annum (260.7 million tonnes over 30 years) of CO2e to the atmosphere.

I object to South 32 not providing any alternative to the 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.

I also do not believe offsets 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. 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. The mining will cause loss of water from water courses and swamps that feed the reservoirs.

I request that you reject this application from Illawarra Coal.

This project provides great economic benefit to the region of Wollongong and Australia. Without the employment of over 500 people in this industry, Wollongong and it's surrounding areas would suffer great financial hardship and the onflow effects would damage the economic safety of thousands.

Please find attached a submission from the Nature Conservation Council of NSW (NCC).
NCC is the peak environment organisation for New South Wales, representing over 150 member organisations across the state. Together we are committed to protecting and conserving the wildlife, landscapes and natural resources of NSW.
NCC objects to the proposed Dendrobium coal mine extension project. The submission focuses on 3 reasons which are of particular concern to our organization:
1. Future surface damage to the Sydney Drinking Water Catchment, based on past damage associated with the current mine activities.
2. Loss of drinking water to the catchment contrary to the principles of ESD.
3. The level of greenhouse gas (GHG) emissions associated with the project is unacceptably high and is inconsistent with National and State commitments to GHG reduction.

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

In a time of drought, I find it highly distressing to imagine that approved mine expansion will threaten our existing water supply.

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].



We 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

​

References

[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

Beyond Zero Emissions objects to the project.
Please see the attached document for comprehensive reasons including:
Global emissions and the Paris Agreement
The capacity and economic opportunities of renewable energy
Emerging trends in energy supply and exports, including investment and finance
Effects on local communities, water security, the environment and public health
Opportunities to support regions with sustainable economic development including zero carbon steel