Dendrobium Mine Extension Project

As a small local business, the current mine provides us with numerous works through their subcontractors.

These works are very beneficial to our business as it allows us to keep ticking over and put that money earned back into the local economy via the purchasing of goods.

Every little bit of income within a small business counts. This is especially the case during periods of economic downturn where the larger companies you work with are predominantly the ones who are able to keep spending.

This submission is to support the Dendrobium Mine Extension Project for the following reasons:
1. As a small business owner I derive a significant portion of my income from South32 - Illawarra Coal.
I live locally and spend my money in the local economy.
2. Coking coal is still required for steel making. I believe that the Steelworks at Port Kembla should be using locally sourced coal because:
a. The coal transport costs are small compared to interstate transport or overseas
b. The environmental monitoring will be regulated according to Australian and NSW standards, ensuring best practice
c. Environmental Impact conditions will be transparent - allowing the community to understand the cost of Steel making
d. The Illawarra coal blend is of extremely high quality - which has a reduced environmental impact
e. The blast furnaces at the Port Kembla steelworks are configured for the Illawarra Coal Blend
Thank you for your consideration

I support South32's application to extend the life of Dendrobium Mine. Illawarra coal is supplied to both of Australia's remaining steel manufacturing businesses, both of which rely, in part, on domestic coal supply for their economic success. The manufacturing of steel is of strategic importance to Australia and there is currently no viable alternative to the manufacturing of steel without metallurgical coal. In fact, over 700 kilograms of coal is used to manufacture 1 tonne of steel.
South32 Illawarra Coal's EIS clearly articulates many of the environmental mitigation measures introduced by the company to mitigate and minimise the impact of underground mining on the surface environment. This includes set backs from key features, dams and dam walls and compensating government agencies for water diverted by their underground mining activities. Further to this the EIS suggests undertaking, or contributing to the undertaking of, key environmental management works proposed by WaterNSW within the catchment areas. It is clear that South32 is working hard to mitigate its environmental impacts, while ensuring a sustainable, economically viable and socially responsible mining operation.
South32 Illawarra Coal also contributes to the communities which surround the mine. This includes supporting community groups, schools, sporting clubs and extra-curricular education facilities. This demonstrates the company's commitment to leaving a positive legacy in the Illawarra and the communities which neighbour the mining operation.
In summary, I support South32's application and look forward to the continued contribution of the resources industry, especially Dendrobium mine, to the economic prosperity of the Illawarra and NSW.

The proposed mining extension is in the protected “Special Areas” of the water catchment upon which 5 million people rely for drinking water. No level of damage is acceptable to the Special Areas, yet South 32's own prediction is that its 305 meter wide long wall panels may result in subsidence of 2m to 2.45m. In addition the mining and associated subsidence has already caused 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. The precautionary principle should apply as there is a clear risk of serious or irreversible harm to Sydney's water catchment from this proposal.

I dispute South 32 public statements that if this proposal is not approved, it will spell the end for the Port Kembla Steelworks. (A statement that Bluescope has failed to support.) 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. I.e. there is plenty of metallurgical coal for Port Kembla Steelworks into the future without this expansion. There is no valid economic argument here.

I ask that the NSW Government reject this proposal.

I feel the expansion of the Dendrobium Mine is important to the economy of the Ilawarra. The mine employs directly a lot of people, but indirectly many, many more. I feel if the mine is held accountable to high environmental standards they can mine the metallurgical coal with minimal environmental impact.

The Dendrobium mine extension project will provide an excellent opportunity for jobs locally in the Illawarra region. Not only will it provide a steady supply of jobs for the mine itself but also for the many hudreds of local suppliers that help support the mines operations.

Mining has been a known entity in the Illawarra since the 1800's and the backbone with which the illawarra was built including its support for the steelworks and local industry.

Coal is one of Australia’s and NSW’s most important and valuable exports.

Coking coal from coal mines in the southern coalfield, such as Dendrobium Colliery, has ideal qualities for steel production and it has fewer impurities, such as sulphur, than coal from other countries.

The continued employment of four hundred direct employees in the coal mine is at stake at Dendrobium Colliery.

The federal government’s tables of multiplier effects shows that more than three times as many indirect jobs are created for every person employed in a coal mine.

I fully support the project , mining is and has been a huge part of the Illawarra region for a very long time. It has employed a large portion of the region directly and indirectly and hopefully continues to do so. The mine is already well established and with this proposed extension it may give some certainty in these economic times .

This project will provide ongoing employment and investment in the Illawarra region. This project is vital to the ongoing support of multiple businesses in the greater district.

This project ensures the Illawarra Regions economy remains healthy, this will secure longterm employment for the area.

This project ensures ongoing supply of coal to the steel making industry which is essencial in supporting the wider community with current and future living expectations. The coal and steel making industry in this area was and still is the back bone of this community. Wollongong was built on this industry and simply would not exist with out it.
Steel is an essencial building material used all over the world for items such as cars, buses and trains, industry, housing and infrastructure, and is relied upon heavily by all societies.

It is important for this project to progress to ensure that the three hundred plus people who work for Dendrobium Mine and all the community functions and jobs that the mine supports are maintained into the future. If this extension project is not approved it will result in the closure of Dendrobium Mine, Dendrobium Washery, Appin Mine, (due to the coal blending requirements), Appin Washery, both site logistical chains and also put the BlueScope operations at serious risk, if not closure. This would result in thousands of families being without their primary income and would impact the whole Illawarra area. The mine has a self regulated, conseravative approach to impacts to the environment, and behaves in a responsible manner in relation to the community and environment as has been portayed since 2002. Total extraction mining methods are not practised below the Avon and Cordeaux Dams and an extremely rigerous monitoring system is in place to mitigate any long term impacts to the Sydney Catchment area. It is important that when making these decisions a pragmatic approach is employed to consider all the data and evidence from a scientific point of view, rather than basing them solely on an emotional basis. Dendrobium Mine is a part of South32 which is a large, listed company with heightened social responsibility and as such will ensure that the environmental and social impacts are managed responsibly. South32 will also enforce strict governance controls on Dendrobium Mine. Dendrobium Mine has been a responsible business partner to the Illawarra region since 2002 and will continue to apply the same strategy into the future. Every guideline, directive or recommendation issued to the mine from the Regulator has been managed responsibly and this will remain the case into the future. Dendrobium Mine is a trustworthy, morally responsible and well respected contributor to the local Illawarra and NSW's economy.

Supporting the local community

Dendrobium Mine as operated responsibly in close proximity to the Mount Kembla community for the past 16 years. The expansion should be approved to allow this to continue into the future. Dendrobium Mine has provided a large amount of funding for the local community including sporting clubs, heritage works and other community works.

I believe this to be a very viable proposal for the community of Illawarra and beyond and particularly for the township of Mt Kembla. It will provide ongoing jobs for many people.

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
David & Tracy Heffernan
​

References

[i] Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696

[ii] Environmental Assessment Part 2, Section 6, pp 150 – 151 accessed at:

https://www.planningportal.nsw.gov.au/major-projects/project/9696

[iii] Gloucester Resources Limited v Minister for Planning [2019] NSWLEC 7, Item 491, accessed at:
https://www.caselaw.nsw.gov.au/decision/5c59012ce4b02a5a800be47f#_Toc431203

[iv] http://www.environment.gov.au/climate-change/climate-science-data/greenhouse-gas-measurement/publications/quarterly-update-australias-nggi-dec-2018

[v] Environmental Assessment Part 2, Section 6, pp 150 – 151, op cit

[vi] https://www.illawarramercury.com.au/story/6295531/bluescope-wont-say-dendrobium-closure-could-finish-steelworks/

[vii] Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696

[viii] Ibid

[ix] Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696

[x] Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696

[xi] ibid, p 111

[xii] Based on an average daily water usage for Sydney residents of 210 litres. Source:
https://theconversation.com/why-sydney-residents-use-30-more-water-per-day-than-melburnians-117656

I support the Dendrobium Mine Extension project due to:
- The mine extension maintaining jobs and creating new jobs for the Illawarra. Jobs created directly through mining but also through downstream including suppliers, steel works, port facility etc.
- The mine has had a great record to date with minmising environmental impacts.
- Without the mine expansion thousands of people and their families across the Illawarra will be impacted negatively.

I support the project because of the enormous benefits to the community through direct employment, and also the flow on employment opportunities. Dendrobium supplies coal to make steel at Bluescope, 2 major industrial employers in the region.

Great for local investment growth and jobs

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