State Significant Development
Determination
Dendrobium Mine Extension Project
Wollongong City
Current Status: Determination
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- Prepare EIS
- Exhibition
- Collate Submissions
- Response to Submissions
- Assessment
- Recommendation
- Determination
Proposed extension to the Dendrobium Coal Mine.
Link to the Independent Planning Commission's page for the Project
https://www.ipcn.nsw.gov.au/cases/2020/10/dendrobium-extension-project-…
Attachments & Resources
Request for SEARs (1)
SEARs (2)
EIS (47)
Response to Submissions (3)
Agency Advice (14)
Amendments (2)
Additional Information (12)
Recommendation (7)
Determination (3)
Approved Documents
There are no post approval documents available
Note: Only documents approved by the Department after November 2019 will be published above. Any documents approved before this time can be viewed on the Applicant's website.
Complaints
Want to lodge a compliance complaint about this project?
Make a ComplaintEnforcements
There are no enforcements for this project.
Inspections
There are no inspections for this project.
Note: Only enforcements and inspections undertaken by the Department from March 2020 will be shown above.
Submissions
Showing 241 - 260 of 775 submissions
Name Withheld
Object
Name Withheld
Object
RANDWICK
,
New South Wales
Message
I object to the project on the grounds of climate change - we already have a dangerous level of greenhouse gases in the atmosphere (about 410 parts per million carbon dioxide), and the concentration is increasing at an accelerating rate due to emissions from human activities, like burning coal and fracking for natural gas.
The level of warming is still catching up to the level of greenhouse gases (think of the greenhouse gases like a thick blanket over Earth - it takes a bit of time for us to heat up). We can't afford to add even more greenhouse gases to the atmosphere - we need to get our emissions to zero and then start drawing down existing stocks of greenhouse gases within the next few decades (the sooner the better, as there are multiple risky feedback loops that could make the problem uncontrollable once we reach a certain threshold e.g. melting ice exposing darker ground that absorbs more heat that causes warming to occur faster and melting more ice, more numerous bushfires that burn down trees that would have sequestered a lot of carbon dioxide, etc.) The science on this is sound - I urge you to read up on this and base your decision on the overwhelming evidence that extending this coal mine would be a very bad idea.
The risk to our drinking water catchment is also a sufficient reason by itself not to grant this mine extension.
The level of warming is still catching up to the level of greenhouse gases (think of the greenhouse gases like a thick blanket over Earth - it takes a bit of time for us to heat up). We can't afford to add even more greenhouse gases to the atmosphere - we need to get our emissions to zero and then start drawing down existing stocks of greenhouse gases within the next few decades (the sooner the better, as there are multiple risky feedback loops that could make the problem uncontrollable once we reach a certain threshold e.g. melting ice exposing darker ground that absorbs more heat that causes warming to occur faster and melting more ice, more numerous bushfires that burn down trees that would have sequestered a lot of carbon dioxide, etc.) The science on this is sound - I urge you to read up on this and base your decision on the overwhelming evidence that extending this coal mine would be a very bad idea.
The risk to our drinking water catchment is also a sufficient reason by itself not to grant this mine extension.
Bronwen Evans
Object
Bronwen Evans
Object
DARLINGHURST
,
New South Wales
Message
The Water NSW Act 2014 requires the government provide clean and secure water, unpolluted by contaminants. If the extension of the Dendrobium Mine project is allowed the predicted "high level of uncertainty about likely success of future remediation efforts in both water courses and swamps"as per the WATERNSW notes is unacceptable. The current mine has already created high levels of surface cracking and drying of a large percentage of the rock pools with two swamps that filter and clean our water currently drying out. Groundwater levels are not recovering. More mining will only worsen these adverse effects.
Thereby I object to the project
Thereby I object to the project
Annie Marlow
Object
Annie Marlow
Object
BERKELEY
,
New South Wales
Message
Thank you for the opportunity to make a submission to this proposal.
I strongly oppose the Dendrobium Mine Extension project SSD-8194 for the following reasons:-
1/ Threat to Our Drinking Water Security
The simple statement ‘no water, no life’ qualifies the Special Areas of the Sydney drinking water catchment as THE most important environment to the 5 million people who depend on it for drinking water. Other than the historically good quality water supplied to the Illawarra & Sydney area, the most outstanding aspect of the Special Areas of the catchment was its near pristine environmental condition. The protection of this area was due to the wisdom of past regulators, and they achieved this principally by restricting public access. For a long time that same restriction on public access protected the miners & the government from public outrage because the mining damage was effectively hidden from the community behind the locked gates in the catchment as well as government silence. I am optimistic that the situation is changing. In more recent times the emerging evidence from the passionate people who have painstakingly gained official access to the area to inspect & take photos, as well as government reports on the environmental condition of this place, paint a very different & alarming picture to the old one of a near pristine environment. The recent escalation of the degradation of the Special Areas is squarely placed with longwall coal mining. With every new approved mine & mine expansion over the last 40 or so years, the damage from longwall tunnel subsidence to the hydrology of the catchment that the reservoirs depend on, increases exponentially. Drained creek beds & dried out Upland Swamps have become the accepted norm of the mining companies’ expectation of their coal extraction activities & the Dendrobium mine’s proposal SSD-8194 is additional evidence of South 32’s intention to continue its aggressive extraction methods. (Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at: https://www.planningportal.nsw.gov.au/major-projects/project/9696)
This mine’s history makes it easy to define it as the biggest threat to the reservoirs of the southern part of the catchment.
In their report Nov 2018, the Independent Expert Panel for Mining in the Catchment, says of Dendrobium mine’s current operation, “it is plausible that an average of around 3 ML/day of surface water and seepage from reservoirs is currently being diverted into the mine workings” (Independent Expert Panel for Mining in the Catchment Initial report on specific mining activities at the Metropolitan and Dendrobium coal mines 12 November 2018, ExecutiveSummary, top of page, 2nd dot point). By a conservative estimate this lost water could service the daily needs of at least 15,000 people! The Sydney water supply cannot afford that wastage but the expansion if allowed will immensely increase the water loss.
In the same report, same page & next dot point the IEPMC warns of the same mine’s current licensed activities - “faulting, basal shear planes and lineaments need to be very carefully considered and risk assessed going forward, especially when planning for further longwall panels to the south of Longwall 16”.
Again in the same report the IEPMC warns “Although a large amount of investigations, modelling and monitoring have been undertaken at Dendrobium Mine, the Panel concurs with the PSM study that, in relation to groundwater, these have been insufficient for the scale and complexity of the technical issues in relation to groundwater. Similarly, it concurs with the 2016 Audit of the Catchment regarding the inadequate availability and quantity of data and monitoring in relation to surface water in general in the Special Areas.” (Independent Expert Panel for Mining in the Catchment Initial report on specific mining activities at the Metropolitan and Dendrobium coal mines 12 November 2018, Executive Summary, piii).
The IEPMC Nov 18 report plus the 2 studies they mention in the above passage makes 3 warnings from groups of scientific experts of the dire outcomes (potential or existing) of damage from mining to the water security of the Sydney drinking water catchment. I also refer you to Dr Ann Young’s revealing book “Upland Swamps of the Sydney Region” see table p84 Ch 9. Note the Dendrobium mine has the highest ‘maximum total subsidence at the surface’ of the 3 mines listed. Please read the whole chapter. (“Upland Swamps of the Sydney Region” Dr Ann Young, table, p84 Ch 9 “Canaries Above the Mines”)
These warnings from the NSW government’s scientific advisors are clear messages for caution going forward. If we value the drinking water for the biggest city in Australia then here is the overwhelming evidence to apply the precautionary principle when assessing mining applications that will undermine the Sydney drinking water catchment Special Areas with unquantifiable damage.
At a time when the population of Sydney & the surrounding areas is rapidly expanding & our climate is trending to more droughts of greater severity, expansion of mining that threatens the dams of the Special Areas which supply water to the largest number of people of any water catchment in Australia is truly senseless.
Our NSW state government has a duty of care to the people of NSW, & to our future generations to secure our drinking water. Security of drinking water now & into the future far outweighs any income the government may earn from royalties from this mining. A previous NSW government Chief Scientist has stated that there is nowhere else in the world where mining is allowed in a public drinking water catchment. It is time to apply the precautionary principle & protect our water.
2/Threat to our climate
The proposed coal to be extracted from this expansion has a large carbon foot print particularly when the carbon released to the atmosphere is taken into account when it is burnt, ie the end use of the coal. The responsibility for the impact of all of these emissions on our climate sits squarely with the miner & the permitting public authority, in this case the NSW government. The Intergovernmental Panel on Climate Change has warned repeatedly that if we are to keep temperature rise at 1.5c we must quickly faze out coal mining. All of our governments including NSW state government have a duty of care to the people of NSW, & to our future generations to protect our climate.
3/Local Industry
The Dendrobium mine owner, South 32, has publicly stated that if this expansion is not granted it will severely impact the viability of the local steel making industry. https://www.illawarramercury.com.au/story/6295531/bluescope-wont-say-dendrobium-closure-could-finish-steelworks/ As there has been no response from Blue Scope Steel to support this claim & the coal Dendrobium supplies to the local steel works is just a third of what comes out of the mine, & the rest it exports, I can only conclude that South 32’s claim is self interested fear mongering. At this time of runaway climate change, fast tracked technology is driving innovation for progressive change. BHP must be acutely aware of this for the commercial viability of Blue Scope. It knows of the progress in using hydrogen to replace coking coal in steel making, it knows it must reduce its green house gas emissions, it knows of the progressive moves towards greener construction alternatives to steel, more recycling of steel & cleaner manufacturing methods.
4/ Off sets in the Special Areas
This arrangement that has allowed large developers & in this case miners, permission to damage public land has inevitably been at the cost of the health of the environment as a whole. The principle reason for this is that it is impossible to replace a mature, fully evolved working ecosystem with one that will take time for its rehabilitation to achieve similar function. Further complications come when maintenance commitments are inadequate or just not adhered to. The mining industry is renowned for its reputation to reneg on its rehab responsibilities. Most important in this case is how can the ‘like for like’ principle apply. The ecosystems of the Special Areas are unique, so where else is it possible to find enough Upland Swamps in need of rehabilitation to compensate for the immense damage the mines have already done to them & admit they will continue to do?
5/ Fixing the damage
The resulting size & complexity of subsidence that changes the structure of the physical geology after a longwall collapes has apparently completely befuddled the fixing abilities of the mining companies responsible for the damage. I have found no reference to anywhere in the world where there has been success in filling the great cracks & voids where the water is lost from longwall subsidence. There is much evidence locally of kilos of synthetic filler being lost apparently going the same way as the water.
6/ Commercial risk & public money
The proposal comprises an aggressive plan for twenty one 305 meter wide longwall panels over 30 years. As well as the above reasons for caution in the assessment of this proposal, it would be stupid in the current commercial markets for government to risk a stranded asset of this proportion falling on the responsibility of the public purse. A 30 year coal mining license is out of the question at this time of climate emergency & surely from the commercial risk of the falling demand for coal.
In conclusion: To protect the security of our drinking water now & into the future; for the sake of a safe climate for the well being of future generations; and to insure the public purse is not burdened with stranded assets, I believe the Dendrobium mine expansion project should not proceed.
Yours sincerely Annie Marlow
I strongly oppose the Dendrobium Mine Extension project SSD-8194 for the following reasons:-
1/ Threat to Our Drinking Water Security
The simple statement ‘no water, no life’ qualifies the Special Areas of the Sydney drinking water catchment as THE most important environment to the 5 million people who depend on it for drinking water. Other than the historically good quality water supplied to the Illawarra & Sydney area, the most outstanding aspect of the Special Areas of the catchment was its near pristine environmental condition. The protection of this area was due to the wisdom of past regulators, and they achieved this principally by restricting public access. For a long time that same restriction on public access protected the miners & the government from public outrage because the mining damage was effectively hidden from the community behind the locked gates in the catchment as well as government silence. I am optimistic that the situation is changing. In more recent times the emerging evidence from the passionate people who have painstakingly gained official access to the area to inspect & take photos, as well as government reports on the environmental condition of this place, paint a very different & alarming picture to the old one of a near pristine environment. The recent escalation of the degradation of the Special Areas is squarely placed with longwall coal mining. With every new approved mine & mine expansion over the last 40 or so years, the damage from longwall tunnel subsidence to the hydrology of the catchment that the reservoirs depend on, increases exponentially. Drained creek beds & dried out Upland Swamps have become the accepted norm of the mining companies’ expectation of their coal extraction activities & the Dendrobium mine’s proposal SSD-8194 is additional evidence of South 32’s intention to continue its aggressive extraction methods. (Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at: https://www.planningportal.nsw.gov.au/major-projects/project/9696)
This mine’s history makes it easy to define it as the biggest threat to the reservoirs of the southern part of the catchment.
In their report Nov 2018, the Independent Expert Panel for Mining in the Catchment, says of Dendrobium mine’s current operation, “it is plausible that an average of around 3 ML/day of surface water and seepage from reservoirs is currently being diverted into the mine workings” (Independent Expert Panel for Mining in the Catchment Initial report on specific mining activities at the Metropolitan and Dendrobium coal mines 12 November 2018, ExecutiveSummary, top of page, 2nd dot point). By a conservative estimate this lost water could service the daily needs of at least 15,000 people! The Sydney water supply cannot afford that wastage but the expansion if allowed will immensely increase the water loss.
In the same report, same page & next dot point the IEPMC warns of the same mine’s current licensed activities - “faulting, basal shear planes and lineaments need to be very carefully considered and risk assessed going forward, especially when planning for further longwall panels to the south of Longwall 16”.
Again in the same report the IEPMC warns “Although a large amount of investigations, modelling and monitoring have been undertaken at Dendrobium Mine, the Panel concurs with the PSM study that, in relation to groundwater, these have been insufficient for the scale and complexity of the technical issues in relation to groundwater. Similarly, it concurs with the 2016 Audit of the Catchment regarding the inadequate availability and quantity of data and monitoring in relation to surface water in general in the Special Areas.” (Independent Expert Panel for Mining in the Catchment Initial report on specific mining activities at the Metropolitan and Dendrobium coal mines 12 November 2018, Executive Summary, piii).
The IEPMC Nov 18 report plus the 2 studies they mention in the above passage makes 3 warnings from groups of scientific experts of the dire outcomes (potential or existing) of damage from mining to the water security of the Sydney drinking water catchment. I also refer you to Dr Ann Young’s revealing book “Upland Swamps of the Sydney Region” see table p84 Ch 9. Note the Dendrobium mine has the highest ‘maximum total subsidence at the surface’ of the 3 mines listed. Please read the whole chapter. (“Upland Swamps of the Sydney Region” Dr Ann Young, table, p84 Ch 9 “Canaries Above the Mines”)
These warnings from the NSW government’s scientific advisors are clear messages for caution going forward. If we value the drinking water for the biggest city in Australia then here is the overwhelming evidence to apply the precautionary principle when assessing mining applications that will undermine the Sydney drinking water catchment Special Areas with unquantifiable damage.
At a time when the population of Sydney & the surrounding areas is rapidly expanding & our climate is trending to more droughts of greater severity, expansion of mining that threatens the dams of the Special Areas which supply water to the largest number of people of any water catchment in Australia is truly senseless.
Our NSW state government has a duty of care to the people of NSW, & to our future generations to secure our drinking water. Security of drinking water now & into the future far outweighs any income the government may earn from royalties from this mining. A previous NSW government Chief Scientist has stated that there is nowhere else in the world where mining is allowed in a public drinking water catchment. It is time to apply the precautionary principle & protect our water.
2/Threat to our climate
The proposed coal to be extracted from this expansion has a large carbon foot print particularly when the carbon released to the atmosphere is taken into account when it is burnt, ie the end use of the coal. The responsibility for the impact of all of these emissions on our climate sits squarely with the miner & the permitting public authority, in this case the NSW government. The Intergovernmental Panel on Climate Change has warned repeatedly that if we are to keep temperature rise at 1.5c we must quickly faze out coal mining. All of our governments including NSW state government have a duty of care to the people of NSW, & to our future generations to protect our climate.
3/Local Industry
The Dendrobium mine owner, South 32, has publicly stated that if this expansion is not granted it will severely impact the viability of the local steel making industry. https://www.illawarramercury.com.au/story/6295531/bluescope-wont-say-dendrobium-closure-could-finish-steelworks/ As there has been no response from Blue Scope Steel to support this claim & the coal Dendrobium supplies to the local steel works is just a third of what comes out of the mine, & the rest it exports, I can only conclude that South 32’s claim is self interested fear mongering. At this time of runaway climate change, fast tracked technology is driving innovation for progressive change. BHP must be acutely aware of this for the commercial viability of Blue Scope. It knows of the progress in using hydrogen to replace coking coal in steel making, it knows it must reduce its green house gas emissions, it knows of the progressive moves towards greener construction alternatives to steel, more recycling of steel & cleaner manufacturing methods.
4/ Off sets in the Special Areas
This arrangement that has allowed large developers & in this case miners, permission to damage public land has inevitably been at the cost of the health of the environment as a whole. The principle reason for this is that it is impossible to replace a mature, fully evolved working ecosystem with one that will take time for its rehabilitation to achieve similar function. Further complications come when maintenance commitments are inadequate or just not adhered to. The mining industry is renowned for its reputation to reneg on its rehab responsibilities. Most important in this case is how can the ‘like for like’ principle apply. The ecosystems of the Special Areas are unique, so where else is it possible to find enough Upland Swamps in need of rehabilitation to compensate for the immense damage the mines have already done to them & admit they will continue to do?
5/ Fixing the damage
The resulting size & complexity of subsidence that changes the structure of the physical geology after a longwall collapes has apparently completely befuddled the fixing abilities of the mining companies responsible for the damage. I have found no reference to anywhere in the world where there has been success in filling the great cracks & voids where the water is lost from longwall subsidence. There is much evidence locally of kilos of synthetic filler being lost apparently going the same way as the water.
6/ Commercial risk & public money
The proposal comprises an aggressive plan for twenty one 305 meter wide longwall panels over 30 years. As well as the above reasons for caution in the assessment of this proposal, it would be stupid in the current commercial markets for government to risk a stranded asset of this proportion falling on the responsibility of the public purse. A 30 year coal mining license is out of the question at this time of climate emergency & surely from the commercial risk of the falling demand for coal.
In conclusion: To protect the security of our drinking water now & into the future; for the sake of a safe climate for the well being of future generations; and to insure the public purse is not burdened with stranded assets, I believe the Dendrobium mine expansion project should not proceed.
Yours sincerely Annie Marlow
Lock the Gate Alliance
Object
Lock the Gate Alliance
Object
Sydney
,
New South Wales
Message
The reasons for our objection are described in the PDF attached.
Attachments
Julie Ashby
Support
Julie Ashby
Support
GERRINGONG
,
New South Wales
Message
Dendrobium Mine Extension is essential to the ongoing economic success of the whole Illawarra Region. The Dendrobium Mine is a major supplier of metallurgical coal to the Blue Scope Steel Works. Thousands of jobs in the mining sector and at Blue Scope Steel will be put at risk if the Dendrobium Mine Extension is not permitted. The Dendrobium Mine, owned and operated by South 32 Company, has always maintained the highest standards of mine safety and environmental protection.
I fully support the application for the extension of the Dendrobium Mine.
I fully support the application for the extension of the Dendrobium Mine.
Kristen Mcdonald
Object
Kristen Mcdonald
Object
BULLI
,
New South Wales
Message
I strongly 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[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
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
Robyn Parkinson
Object
Robyn Parkinson
Object
KURNELL
,
New South Wales
Message
I object as its a protected water supply. Desal is only 15% for Sydney and Eastern Suburbs and is not sufficient. There is a fine of $44,000 for trespass, however Mines can do what they want to the land and catchment area. These expansions of mines within the water catchment area cannot continue to be approved. Its our water supply. We can't drink coal. I know its important for jobs and the country but NOT in the water catchment areas!
Name Withheld
Object
Name Withheld
Object
AUSTINMER
,
New South Wales
Message
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. 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
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
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
Susan Gay
Object
Susan Gay
Object
APPIN
,
New South Wales
Message
I object to coal mining in the drinking water catchment areas. Just look at the George’s River as a perfect example of why this should be not allowed Marneys hole at Appin & the cataract River. You can not argue History. Don’t let it repeat itself.
Kerry Lassila
Object
Kerry Lassila
Object
EAST CORRIMAL
,
New South Wales
Message
I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium, Project SSD-8194, on the grounds of water security and environmental impacts.
Coal mining is an industry with a rapidly approaching use-by date and we must do more to adjust our industries and economy away from reliance on coal. We must increase our renewable energy industries and technology, along with building an economy based on sustainable production and sustainable industries. We must also ensure that water and future water security, is given top priority in all considerations. Occurence and duration of droughts is predicted to increase and water availability will, at some point, become the major concern in all areas of our economy, in society and government at all levels.
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 short sighted in the extreme.
The requested 30 year’s of further mining 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.
Proposed 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.
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 firmly believe it would be a grave error of judgment for the NSW Department of planning to support this level of destruction and water loss in Greater Sydney’s water catchment.
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
Kerry Lassila
References:
[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
Coal mining is an industry with a rapidly approaching use-by date and we must do more to adjust our industries and economy away from reliance on coal. We must increase our renewable energy industries and technology, along with building an economy based on sustainable production and sustainable industries. We must also ensure that water and future water security, is given top priority in all considerations. Occurence and duration of droughts is predicted to increase and water availability will, at some point, become the major concern in all areas of our economy, in society and government at all levels.
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 short sighted in the extreme.
The requested 30 year’s of further mining 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.
Proposed 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.
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 firmly believe it would be a grave error of judgment for the NSW Department of planning to support this level of destruction and water loss in Greater Sydney’s water catchment.
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
Kerry Lassila
References:
[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
Name Withheld
Object
Name Withheld
Object
ERARING
,
New South Wales
Message
There will be substantially more damage to the 'Specials Areas' of Sydney's water catchment. Furthermore the temperate highland peat swamps are endangered ecological communities that act like a sponge and a filter, releasing pure drinking water according to scientific opinion. These swamps no longer hold water where they have been undermined as the sandstone cracks and the water drains from the swamps. I object to the potential damage to the natural water systems that we have come to rely on. I object to the damage to the wildlife that have evolved around the swamps. We live in a dry continent. I object to the damage from mining to the water supplies. I further object to mining coal which when burnt increases CO2 and is causing crises around the world with calamitous weather events. Coal mining in Australia must stop to be fair on the island nations and low lying lands.
Name Withheld
Object
Name Withheld
Object
wollongong
,
New South Wales
Message
The economic imperatives being forwarded to explain the continued viability of the steel making process has relatively short term economic benefits. The impact of long wall mining on the eco system with the fracturing of the ground and loss of water will have permanent damaging effects. The Sydney water catchment area will be severely impacted. The greater long term benefit for future generations will be to maintain what has not already been damaged. Our duty of care is to the future and not pander to a short term commercial urgency which has as the only solution the continued extraction of coal by longwall mining within the water catchment area.
Name Withheld
Support
Name Withheld
Support
ALBION PARK
,
New South Wales
Message
I believe that this is a good opportunity for the community. I believe coal mining in the Illawarra secures many local jobs, directly and indirectly. There are thousands of people in the Illawarra region that would find themselves without work if the Dendrobium project doesn’t go ahead.
I believe that the controls put in place by South32 are more than adequate to protect our catchment area and I believe that there has been a lot of exaggerated talk/information from opposing groups blaming mining for issues caused by the current drought.
I believe allowing this project to go ahead is the right and responsible decision for the Illawarra and I would find it very disappointing if the government were to block the project.
I believe that the controls put in place by South32 are more than adequate to protect our catchment area and I believe that there has been a lot of exaggerated talk/information from opposing groups blaming mining for issues caused by the current drought.
I believe allowing this project to go ahead is the right and responsible decision for the Illawarra and I would find it very disappointing if the government were to block the project.
Paul Lynch
Object
Paul Lynch
Object
PORT KEMBLA
,
New South Wales
Message
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
Paul Lynch
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
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
Paul Lynch
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
Name Withheld
Support
Name Withheld
Support
LANE COVE
,
New South Wales
Message
I support the extension application, the mine provides employment opportunities for the Illawarra area and supports the local economy. I believe South32 manage the mine with respect and care, ensuring there is minimal impact on the environment.
Name Withheld
Object
Name Withheld
Object
MOUNT PLEASANT
,
New South Wales
Message
I am making a submission because I want to object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium Project SSD-8194.
My reasons follow. In a nutshell though, I believe that the value of the water in the Sydney water catchment - both to human water-users and to the natural ecosystems that depend upon it - should take priority over other asserted values such as employment for a small number of mine workers. Additionally, I am concerned about the direct and indirect greenhouse gas emissions associated with the project - the recent finding of the Independent Planning Commission against approval of the Bylong coal mine in NSW indicates that the courts take greenhouse gas emissions into account in their judgements.
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
My reasons follow. In a nutshell though, I believe that the value of the water in the Sydney water catchment - both to human water-users and to the natural ecosystems that depend upon it - should take priority over other asserted values such as employment for a small number of mine workers. Additionally, I am concerned about the direct and indirect greenhouse gas emissions associated with the project - the recent finding of the Independent Planning Commission against approval of the Bylong coal mine in NSW indicates that the courts take greenhouse gas emissions into account in their judgements.
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
Jon Reed
Object
Jon Reed
Object
Chatswood
,
New South Wales
Message
We cannot eat or drink coal. Even minimal risk is too much on something as vital as our water supply. Alternative power sources are developing and the greedy search for profit at the expense of a healthy environment is not justified. And what about the effects on the ecological system? Mining companies do not take the long view. There is no going back on the destruction caused, especially so close to large and growing populations. How can we look our grandchildren in the face when we leave them with polluted water, land no longer fertile and air that contains contaminants? Has this project received full and unbiased examination by scientists? Is the wider community fully aware of it? Surely enough coal is being dug out in other projects. Surely this one will bear little fruit. The Adani decision was bad enough. Is there no end to ripping up the earth for the benefit of a few?
Yul Scarf
Object
Yul Scarf
Object
Woonona
,
New South Wales
Message
I put forward my objection to Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194. My objection is due to the greenhouse gas emissions associated with the project, the dangers the extension pose to greater Sydney’s water catchment and on the grounds of intergenerational equity.
Illawarra Coal’s proposed extension of the Dendrobium mine will have a devastating impact on greater Sydney’s water catchments. We are currently in drought and there is much public debate on how we will manage the little water available and yet with this proposal water loss from the catchment would increase, with surface water loss expected to peak at 27.6 ML per day in the year 2035[i]
I was able to meet with Ben Fitzsimmons who is in the role of Principal Community Engagement Corporate Affairs for South 32 to hear the company’s rationale for the proposed extension. I left this meeting unconvinced- and in fact distressed- at the company’s misuse of the concept of ‘intergenerational equity’. Ben argued that keeping the mine open would aid intergenerational equity as future generations should be able to access as much steel as adults today.
This argument fails to take into account the lack of equity faced by future generations who will inherit a world that is further climate affected by the carbon emissions associated with this project. The proposed extension 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].This is comparable to 1.6% of Australia’s current annual emissions.We are currently at 409.95 ppm of CO2 and need to do all that we can to limit the amount of CO2 released into the atmosphere.
Ben Fitzsimmons argument on behalf of South 32 fails to take note of the research projects currently seeking to develop alternatives to steel [iii]. Or to develop steel using less coking coal [iv]. To extend the mine until 2049 would be to lock our economy into fossil fuels at a time when it is critical to put energy elsewhere. The environmental impacts, will last long after the mine is decommissioned.
Earlier today the NSW Independent Planning Commission released its decision to refuse Kepco’s proposal for an open-cut and underground coal mine in the Bylong valley, citing its unacceptable impacts on surface and groundwater as a significant factor[v]. The Commission also made it clear that the mine would have been contrary to the principle of intergenerational equity and that it would contribute to climate change through greenhouse gas emissions.
Along with February’s historic ruling on the Rocky Hill coal mine[vi], a new legal precedent has been set. It is not in the public interest for coal mining to be expanded at this point in our climate crisis. The tide is turning. Socially and legally. This is the wrong time and wrong place for expanded coal mining.
I ask that you reject this application from Illawarra Coal in reference to the decisions already made at Bylong Valley and Rocky Hill. The predicted economic benefits would accrue to the present generation but the long term environmental costs will be borne by future generations and by those most vulnerable to climate inaction now.
Thank you for considering this submission.
Regards
Yul Scarf
[i] Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[ii] ii] Environmental Assessment Part 2, Section 6, pp 150 – 151 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[iii] Gupta, Ashok & Ganguly, Rajiv & Mehra, Ankit. (2015). Bamboo as Green Alternative to Steel for Reinforced Concrete Elements of a Low Cost Residential Building. Electronic Journal of Geotechnical Engineering. 20. 1523-1545.
[iv] Green Steel making research CSIRO accessed at: https://www.csiro.au/en/Research/MRF/Areas/Community-and-environment/Responsible-resource-development/Green-steelmaking
[v] New South Wales Independent Planning Commission Media Release 18 September 2019 ‘Bylong Coal Project Refused Development Consent’, accessed at https://www.ipcn.nsw.gov.au/resources/pac/media/files/pac/general/whats-new/190918bylong.pdf?la=en&hash=94EE53299A3E32B0570120B88DB94E2A
[vi] Gloucester Resources Limited v Minister for Planning [2019] NSWLEC 7, Item 491, accessed at:
https://www.caselaw.nsw.gov.au/decision/5c59012ce4b02a5a800be47f#_Toc431203
Illawarra Coal’s proposed extension of the Dendrobium mine will have a devastating impact on greater Sydney’s water catchments. We are currently in drought and there is much public debate on how we will manage the little water available and yet with this proposal water loss from the catchment would increase, with surface water loss expected to peak at 27.6 ML per day in the year 2035[i]
I was able to meet with Ben Fitzsimmons who is in the role of Principal Community Engagement Corporate Affairs for South 32 to hear the company’s rationale for the proposed extension. I left this meeting unconvinced- and in fact distressed- at the company’s misuse of the concept of ‘intergenerational equity’. Ben argued that keeping the mine open would aid intergenerational equity as future generations should be able to access as much steel as adults today.
This argument fails to take into account the lack of equity faced by future generations who will inherit a world that is further climate affected by the carbon emissions associated with this project. The proposed extension 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].This is comparable to 1.6% of Australia’s current annual emissions.We are currently at 409.95 ppm of CO2 and need to do all that we can to limit the amount of CO2 released into the atmosphere.
Ben Fitzsimmons argument on behalf of South 32 fails to take note of the research projects currently seeking to develop alternatives to steel [iii]. Or to develop steel using less coking coal [iv]. To extend the mine until 2049 would be to lock our economy into fossil fuels at a time when it is critical to put energy elsewhere. The environmental impacts, will last long after the mine is decommissioned.
Earlier today the NSW Independent Planning Commission released its decision to refuse Kepco’s proposal for an open-cut and underground coal mine in the Bylong valley, citing its unacceptable impacts on surface and groundwater as a significant factor[v]. The Commission also made it clear that the mine would have been contrary to the principle of intergenerational equity and that it would contribute to climate change through greenhouse gas emissions.
Along with February’s historic ruling on the Rocky Hill coal mine[vi], a new legal precedent has been set. It is not in the public interest for coal mining to be expanded at this point in our climate crisis. The tide is turning. Socially and legally. This is the wrong time and wrong place for expanded coal mining.
I ask that you reject this application from Illawarra Coal in reference to the decisions already made at Bylong Valley and Rocky Hill. The predicted economic benefits would accrue to the present generation but the long term environmental costs will be borne by future generations and by those most vulnerable to climate inaction now.
Thank you for considering this submission.
Regards
Yul Scarf
[i] Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[ii] ii] Environmental Assessment Part 2, Section 6, pp 150 – 151 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[iii] Gupta, Ashok & Ganguly, Rajiv & Mehra, Ankit. (2015). Bamboo as Green Alternative to Steel for Reinforced Concrete Elements of a Low Cost Residential Building. Electronic Journal of Geotechnical Engineering. 20. 1523-1545.
[iv] Green Steel making research CSIRO accessed at: https://www.csiro.au/en/Research/MRF/Areas/Community-and-environment/Responsible-resource-development/Green-steelmaking
[v] New South Wales Independent Planning Commission Media Release 18 September 2019 ‘Bylong Coal Project Refused Development Consent’, accessed at https://www.ipcn.nsw.gov.au/resources/pac/media/files/pac/general/whats-new/190918bylong.pdf?la=en&hash=94EE53299A3E32B0570120B88DB94E2A
[vi] Gloucester Resources Limited v Minister for Planning [2019] NSWLEC 7, Item 491, accessed at:
https://www.caselaw.nsw.gov.au/decision/5c59012ce4b02a5a800be47f#_Toc431203
Jess Whittaker
Object
Jess Whittaker
Object
Irene Tognetti
Object
Irene Tognetti
Object
Pagination
Project Details
Application Number
SSD-8194
EPBC ID Number
2017/7855
Assessment Type
State Significant Development
Development Type
Coal Mining
Local Government Areas
Wollongong City
Decision
Refused
Determination Date
Decider
IPC-N