Dendrobium Mine Extension Project

I am an environmental engineering student at the University of Wollongong in my 3rd year of studies. Over the past two years specifically I have learnt of the great importance of water catchment security and the implications of degrading or losing a source of clean drinking water will have on the surrounding population and civilisation. Growing populations and future climatic change WILL bring us great stress on water resources. Longwall mining underneath water catchment has to be the most preposterous idea of coal extraction I have ever heard, Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment, is that not a clear indicator of this absurdity?

NSW needs INNOVATION, NSW needs water SECURITY. This state is in drought, and scientific predictions only see it worsening. Don't risk this project, it is not worth the destruction of our most precious resources.

The attached advises that comments on behalf of NPA NSW regarding the proposed expansion of the Dendrobium mine in Areas 5 and 6 will be provided within six weeks following the release of the second report of the Independent Expert Panel for Mining in the Catchment. The NPA regards the IEPMC report as an essential pre-requisite in being able to provide adequately informed comments on these important proposals for further mining beneath the Special Areas of the Sydney catchment.

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].



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
Jennifer
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

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.
PLEASE follow the lead of the Bylong valley coalmine rejection.
It is ludicrous to be approving mine expansions in the current climate. We should be transitioning to renewable energy and cutting all investment in mining.

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.

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,
Adrienne Corradini

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.
Sydney has been fortunate in having water catchments of natural vegetation clear of farmlands and industries unlike Perth and Adelaide. The concern is that mining beneath water catchments with the acknowledged water loss that results is foolish long term planning for an expanding city.
Mining beneath water catchments is a government policy highlighting desperation for profits over long term water security. It is a risk practise opposed by Water NSW.
In 2017 the Planning Department commissioned consultants PSM to prepare an extensive study which found the sensitive upland swamps – which are ecologically endangered and play an important role in moderating surface water flows – were being affected by the Dendrobium mine “at distances of around 250 to 900 metres” from the mining panels.
"Investigations at [one] site showed new cracks extended through to the ground surface and the permeability increases post-mining by one to three orders of magnitude" or as much as 1000 times, the report found. [1]
Significantly in the current proposal the proponents South 32 by their own admission state that water loss will peak at 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[xii].
This is unacceptable even today with the current dam levels and rainfall seemingly decreasing at alarming rates.
The upland swamps are a vital feature of provide pure water year round even through droughts. They require the simple protection of not having their basements disturbed. Long wall mining fractures the basement Hawkesbury River Sandstone. When this occurs the swamp drain their waters and dry out killing the vegetation. This results in the cessation of water release into the catchment and then allows rain events to cause massive erosion through the dead swamp matter. The geomorphology of the swamp is then lost.
Documented evidence confirms the adverse impacts that previous operations at Dendrobium (and other mines in this area) have had on the water catchment. This proposal will result in further damage to the catchment area and loss of irreplaceable water for Australia’s largest city currently facing the imposition on increased migration and development.


[1] Cracks above Dendrobium mine spark fears for water catchment 13-09-2017
http://www.illawarramercury.com.au/story/4920661/cracks-above-dendrobium-mine-spark-fears-for-water-catchment/

Please see the attached PDF file titled: POWA Submission South32Dendrobium 20190918
WE OBJECT to the proposed longwall coal mining expansion in the Sydney Water Catchment's Metropolitan Special Area.

Dear Planning Commission,

Illawarra Coal’s Proposed Mine Extension for Dendrobium:

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. 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. Special Areas are identified and established through scientific investigation that consider factors of environmental sustainability and therefore protect the interests of future generations. They should never be undermined and threatened from the interests and activities of commercial mining interest.
Claims made to address and mitigate the proposed extension’s risk to water quality of the Sydney water catchment and the area’s ecology do not justify this extension for 30 years.

Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. Please reject this application.

Thank you for considering this submission.

Regards
C. Bilsland

Mining should not have been approved in the Sydney Water catchment. No new approvals or extensions of approval for longwall mining in the Sydney Water Catchment Special Areas should be given. The Department knows full well why an approval should not be given, the Special Area is not named Special Area for fun. Sydney Water planners showed foresight when planning and preserving the water catchment. We seem to have run out of foresight and just hope it will all be alright in the end.

I strongly 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 five 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.

The proposal will also 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.

Further, 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.

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 also 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.

Additionally, 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.

Subsistence is also of great concern. 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[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.

Regarding water loss, billions of litres of water will be lost from Greater Sydney’s Water Catchment if this proposal goes through. 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].

In conclusion, I ask that you reject this application from Illawarra Coal.

Thank you for considering this submission.
​

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

I support the Dendrobium Mine expansion for the significant socio-economic benefits it will bring to the Illawarra/Wollondilly regions and indeed the state of NSW as a whole.

Illawarra Coal is a major employer in the Illawarra and Wollondilly regions, providing many thousands of direct and indirect jobs. Illawarra Coal is also a major contributor to the local and state governments through royalties, taxes & rates.

Illawarra Coal have proposed robust environmental measures and controls to minimise impacts on local flora, fauna and water supply reservoirs.

Much has been made of the issue of water flows from the surface into the mine, but flows into Dendrobium are decimal places when compared to even just the evaporation from the WaterNSW system. When compared with other large businesses around the state the amount of water used at Dendrobium is insignificant. That Illawarra Coal have proposed to pay for the amount of water that is predicted to flow into the mine makes the mine a large water user and nullifies arguments against the mine based on water inflows.

Illawarra Coal are major suppliers to the Bluescope Steelworks, another major economic player in the local region. Providing coal to the Steelworks from the local mines is efficient and makes good economic and environmental sense.

Please support this project.

Please refer to attached submission

I object to the Dendrobium Mine Extension Project.
I am extremely concerned that if this proposal goes ahead it will allow mining for another 30 years in our drinking water catchments, at a time when protection of our drinking water supply has never been so critical.
Predicted subsidence will further impact on the water courses that flow into the reservoirs, with more surface damage and huge quantities of water being lost into the mine. Our dam levels are below 50%, we are now under level 1 water restrictions and the desalination plant is now operating, which only supplies 15% of Sydney with water. NSW is currently in drought. Regional areas are being threatened by imminent loss of water. The Murray-Darling is heavily compromised. Australia is the driest, inhabited continent on earth. We are seeing already the effects of climate change. How can it make sense to continue to mine in the drinking water catchments of the biggest city of Australia?
Surely, further damage to upland swamps is unacceptable and off-sets on a like-for-like basis not possible? Research carried out by NSW University, on behalf of Water NSW, indicates that longwall mining has been drying up upland swamps that provide drinking water and as mining expands so do the impacts. As the swamps store water and release it over time, they are particularly important in times of drought.
Also, with climate change now taking effect, how can we possibly justify the predicted overall GHG emissions for a 30 year plan of further mining? This proposal would emit 260 million tonnes of CO2e (in production, transport and consumption) for the life of the project - significant quantities and most concerning.
Regarding the steel works, I understand that the local plant could keep going for another 11 years under the current approvals. By supporting ‘green steel’ development and using recycled steel to capacity, I like to think that we could soon make steel without coal. This has to be the way of the future.
Short-term profits with long-term consequences cannot be acceptable. With climate change already having serious impacts, we must take responsibility and do everything possible to cut down emissions and protect our land and water.
Water is our most precious resource and must be protected.

Please find attached Lane Cove Coal and Gas Watch's submission

The Dendrobium coal mine should not go ahead. I does irreversible damage to upland swamps in the area, that keep streams flowing in dry times. This is totally unacceptable in this time of drought. And it will continue for the next 20-30 years.
Also the amount of water lost to Sydney catchment is totally unacceptable. Every Sydney household is paying $40 more to have the desalination plant turned on. How much will Dendrobium pay for the loss of water.
The destruction is totally unacceptable

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].



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

Tara Hunt
​

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

Water is the most important resource in this country. The present Dendrobium mine is compromising the catchment area and should be stopped.
Any extension to these longwall mining should be opposed. Not only does the mining use vast amounts of water and has caused subsidence, it is already damaging the water catchment for Sydney, Macarthur, and Illawarra.
Water is too important.
The proposed extension should opposed.

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.
It will result in damage and loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs.
Personally, I oppose any project with the level of environmental impacts of the proposal but it shows a particularly egregious misalignment of priorities to allow a proposal like this in the vicinty of dams considering our continuing issues with water security.
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 in the Special Areas.
The estimated loss of 9500ML/year into the mine makes a travesty of the efforts at water conservation being undertaken elsewhere, it further devalues already undervalued water.
I dispute the assertion included in the Biodiversity Assessment Report by Niche that the subsidence is highly unlikely to have a detrimental effect on native vegetation outside the upland swamps.
The impacts on 25 coastal upland swamps outlined by Niche are unacceptable. I also think it is incorrect to suggest that all swamps that aren't within 60m of a longwall will be unaffected. The report admits that fracturing has been observed up to 400m from longwalls, so the offset should be at least 400m. Even swamps outside this will be affected if they have any changes in their catchments.
The Niche approach of trying to minimise the impacts on the swamps by suggesting that dramatic changes seen elsewhere are attirbuted to a number of causes, that project related imacts to groundwater will have a slow and maybe not discernable impact on vegetation and that losing the native swamps isn't that bad becuase the same threatened species can be found in the vegetation community the swamps will transition to are all specious. The nexus between subsidence related changes to groundwater and changes to the swamps is clear and whilst it is difficult to remove the other factors which have an impact (e.g. long-term changes in rainfall patterns) it should be considered that in isolation the impacts are sufficient to substantially degrade the swamps. The resilience or not of vegetation to changes in groundwater in the short term is not a cover for the accepted realtiy that changing to groundwater in the way predicted will irrevocably destory the swamps. That the same threatened species may be found in the replacement environment doesn't take away the impact to these species of removing this ecosystem.
The Niche report also doesn't agree with the Hydro Engineering & consulting report J1610.r2g which conceeds that there is a potential that erosion and scoruing ould occur as a result of mining induced tilt from subsidence.
I generally don't think offsets are suitable for addressing the impact of clearing of 28.5ha of native vegetation. The spatial and genetic attributes of the site can not be substituted.
I think this application from Illawarra Coal should be rejected.
Thank you for considering this submission.
Yours faithfully,
Angus Dyson

Water supply to Sydney is essential
I object to this mine extension as it has the potential to harm Sydney’s water supply

Illawarra Coal’s Proposed Mine Extension for Dendrobium:

I strongly object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194. This is damaging an already compromised water supply for Sydney. It demonstrates extraordinary lack of representation of community interests, threatening long term water supplies! Coal interests are ludicrously low in significance compared with this.

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.

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[1]. Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative[2].
• 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[3]. 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[4].
• Consultants estimate that up to 9,500 Megalitres[5] (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[6].

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
[1] Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[2] Ibid
3] 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
[4] Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[5] ibid, p 111
[6] 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 live in Mount Kembla. When the Dendrobium mine began we were assured that it was a twenty year project. Now it is proposed to extend its life to 2028, and possibly beyond. There is empirical evidence in the public domain about direct impacts of mining subsidence on water catchments, upland swamps and water quality. Already Avon, Cordeaux and Cataract dams are significantly below capacity as the drought continues. Sydney is an expanding city and its future water needs cannot be met if such a precious commodity is lost to mining leakage and damage to catchment creeks and swamps. This affects everybody. For these reasons I oppose extension of this project for the sake of water security for future generations as opposed to the interests of shareholders. Planning NSW should make a decision for the future for all citizens, not vested interests.