Dendrobium Mine Extension Project

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,
Jamie Walker

​

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 am writing in regards to the proposed Dendrobium Mine Environmental Impact Statement that has been brought to my attention via a mail drop.

Despite the economic benefits of this mine, my concern is that we, as a country, continue to invest large amounts of money into fossil fuels, which continue to destroy our planet. We have so much opportunity in Australia to produce energy from other sources, but we fail to take any sort of lead on this, continuing to supply countries such as China and India with coal. It is so easy to point the finger at other nations and say that they should be doing more, but per head of population, we are one of the worst countries in the world regarding global emissions.

Forward thinking nations around the world are finding alternatives to the use of coal and Australia needs to be a part of that company.

I do not support the continued mining operations at Dendrobium Mine.

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

I was born and raised in Wollongong. Having been raised by a local coal miner of 40 years and myself lived in the northern suburbs of Wollongong for 24 years this matter is close to my heart. I was first alerted to this mine extension proposal recently by a concerned family member when visiting there again recently.

In short, South32 is seeking approval for an extension to their existing Dendrobium Mine, near Mt Kembla. They are seeking an extension into Areas 5 and 6, which would extend the life of the mine from 2024 to 2048, undermining deeper under the Greater Sydney Water Catchment. This proposed extension is a clear threat to both the water security of 5 million people in the Greater Sydney region, as well as having immense greenhouse gas emissions.

I acknowledge that this application may perhaps be in the financial interest of the owners and investors of the mine, but that is all. It is extremely offensive and alarming to everyone else. This should not be taken lightly. 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.

As a representative minister of the public and elected decision-maker you will be responsible and accountable to the public for all of the consequences of this project should you permit it to go ahead. Your motivations for such an approval and your moral compass will undoubtedly be in question. Note that your electorate is watching. Australia are watching. The world is watching. Our children are watching.

On behalf of all concerned residents of Sydney and the Illawarra, of our indigenous ancestors of the past, our current local residential population, and most importantly our future generations, I ask that you reject this application from Illawarra Coal.

I will go further here to request that you fulfil your duty to your electorate in actively demonstrating a clear objective of transitioning the local and state economies to a clean and sustainable future by instead commencing a process to close the mine at Dendrobium permanently.

The details of my submission are provided below. I expect that you may already be informed of much of the details provided here, yet I implore you to read through it all again and to take it seriously.

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.

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.

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].

Again, on behalf of all concerned residents of Sydney and the Illawarra, of our indigenous ancestors of the past, our current local residential population, and most importantly our future generations, I ask that you reject this application from Illawarra Coal.

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

Keep local jobs supporting local business

I have lived in the local area my entire life. I understand the importance coal has had to our local economy and community. However it is time for change. Australia is a country of drought and we are heading into another one due to changing weather systems. Why would you approve this project and risk our water security. The process of water filling in coal seams isn’t a secret and it is evidence based, it is clear that this will affect our water supply. As a young person I fear for how my life will change due to climate change and with worsening droughts, why would we taken water away from the catchment area just to burn more coal and worsen climate change. Please, think of the future of this area not the profits that can be made in the short term.

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

Please see attached document.

I support the Dendrobium Mine Extension Project for the following reasons;

• It will support 500 full time operational jobs
• It will create 200 additional jobs during construction
• A $2.8 billion net economic benefit to NSW
• A $1.1 billion net economic benefit to the Illawarra region
• It will generate A $714 million in rates, royalties and taxes
• It will continue the supply of high-quality metallurgical coal for steelmaking to our local and international customers

The proposed Mine Extension for Dendrobium (Project SSD-8194) by Illawarra Coal should not proceed.

1) Water
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]. No other city in the world allows longwall mining in a publicly owned water catchment and the risks are obvious. 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, our dam levels are below 50% and we face ongoing diminishing water supplies from climate change and yet the Dendrobium proposal has the highest water loss of any mine operating in the Greater Sydney Water Catchment area. This project is clearly not in the public interest. We cannot afford the risk to our water. It would be reckless, immoral and, frankly, stupid for the Department of Planning to support this expansion.

2) Carbon emissions
In addition to the threat it poses to our water supply, the proposal will result in significant quantities of greenhouse gas emissions. The proposal is estimated to create up to 23.7 million tonnes of carbon dioxide equivalent (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 cut greenhouse gas emissions sufficiently to meet its targets. The recent Rocky Hill case clearly 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 estimated Australia’s greenhouse gas emissions for the year to December 2018 as 538.2 million tonnes [iv]. 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 (260.7 million tonnes over 30 years) of CO2e to the atmosphere [v] which is comparable to 1.6% of Australia’s current annual emissions. This mine proposal brings a burden we cannot carry.

3) Timeframe
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.

4) Offsets are an inherently flawed environmental management tool
Offsets do not compensate for mining-induced destruction of catchment land and ecosystems. First, offset systems, as practised, simply result in an overall reduction in the extent of land and ecological community under protection. Second, truly like-for-like offsets are rare and in the case of water catchments, there is no “equivalent” land that could compensate for damaged and compromised water catchment. The proposal by South 32 to offset catchment land and ecological communities that have been irreparably damaged by mining is neither sensible nor in the public interest.

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

Kind regards
Rena Friswell
​

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

Illawarra Coal’s Proposed Mine Extension for Dendrobium: No more “business as usual”

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

Rebecca

Supporting 500 full time operational jobs

I support the submission on the following grounds:
• The Project would produce metallurgical coal for steelmaking. There is currently no economically viable, commercial-scale alternative to the use of metallurgical coal in the blast furnace method of steelmaking, which is employed at the BlueScope Steelworks. The Project would provide a local and continued supply of metallurgical coal to the BlueScope Steelworks.
• The Project represents a continuation of mining at the Dendrobium Mine, providing continuation of employment for the existing Dendrobium Mine workforce and additional employment opportunities during construction and operations. In addition to the loss of 300 new jobs created over the project, the 1800 people Illawarra Coal directly employ would be impacted if this project is not approved.
• Underground coal mining is currently the only major revenue generating industry that is both compatible with the catchment status of the Project area, and permissible with consent.
• South32 has committed to a minimum of one-kilometre setbacks from the Avon and Cordeaux dam walls. South32 would also avoid the direct undermining of mapped “key stream features” (significant pools and waterfalls/steps) identified during site investigations
• South32 has committed to pursue opportunities for industrial reuse of excess mine water such that the re-use volume matches or exceeds the predicted Project surface water take.
• The Project will result in a total net benefit to the NSW economy of over $2.8 billion ,including over $1.1 billion to the Greater Wollongong Region.

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
Sarah Caruana

Thank you for the opportunity to make a submission regarding the Dendrobium Mine Extension, SSD-8194.

It is my pleasure to write a letter of support for South 32 in their application for the extension of their operation at Dendrobium beyond 2024, including Areas 5 and 6. I am writing this letter on behalf of the Illawarra Innovative Industry Network – i3net.

The i3net is a powerful network of industry based companies working from the Illawarra. The network was established over 17 years ago to promote the collective capability of Illawarra Industry to local, national and international markets. Industry in the Illawarra continues to be a key foundation of the local economy.

Subject to all environmental checks, the purpose of this submission is to emphasise the proposed extension of operation at Dendrobium beyond 2024, including Areas 5 and 6, will be a significant decision for the region, due to the impact on Illawarra’s industrial supply chain.
We understand from BlueScope that the Port Kembla Steelworks consumes approximately 3 million tonnes per annum of coal, of which over 90 per cent is sourced from mines in the Illawarra region. The principal Illawarra mine sources are the South32/Illawarra Coal Dendrobium and Appin mines, Peabody’s Metropolitan mine and the SIMEC Tahmoor mine. Interrupting this supply would critically jeopardise BlueScope’s ongoing ability to produce coke in the Illawarra.

We quote BlueScope when they say “Without this supply, steelmaking would struggle to remain viable at Port Kembla.” This statement is truly alarming for the Illawarra, NSW and Australia.

As the industry representative for small, medium and large businesses in the industrial supply chain, the flow on effect would be devastating for the immediate 526 Wollongong manufacturing businesses (Business count ABS June 2018 cat. 8165), and the 10,000 individuals (.id, June 2019) who work in the local Manufacturing Professional, Scientific & Technical services. In fact BlueScope generates ~$6.5 billion in regional economic output, which is 24% of the Illawarra total output and directly employs 3,500 workers. Accordingly, community support for mining, coal and industry is strong in the Illawarra. It’s in our DNA and a proud part of our heritage.

We respectfully ask the Department of Planning, Industry and Environment to consider the vulnerability of the industrial supply chain when making its decision. The region’s economic sustainability is incredibly sensitive to price changes. An ongoing supply of competitively priced metallurgical coal from the Southern Coalfields is an essential feedstock for the Port Kembla Steelworks, thereby supporting local businesses, jobs and local economic activity. As the premier network of industry based companies working from the Illawarra, i3net fully supports South 32 in continuing their mining activity beyond 2024, including Areas 5 and 6.

At a local level, South 32 continue to show their commitment to the Illawarra region by participating in i3net workshops and giving keynote presentations. The openness and approachability of South32 is appreciated and to be commended.

i3net is engaged and willing to support this initiative to ensure its success. As such, we would like to invite staff of the Department of Planning, Industry and Environment to attend the 8th Illawarra Industry Showcase which will be held on the 31st October (Dinner) & 1st November (Breakfast) to aid in your understanding of the standard of companies in the industrial supply chain in the Illawarra region.

For further information, or if you have any questions, please do not hesitate to contact our Executive Officer, Bianca Perry on 0401 030 023.

Yours sincerely,
Robert Donsante
i3net Deputy Chairperson
Illawarra Innovative Industry Network – i3net

I oppose this project for the reasons detailed in the attached pdf.

Thank you

The project brings hug opportunity and is sustainable to the environment, water bodies and social responsibilities of the area. The current team operating Dendrobium can continue to sustain the high value adding operation to the area.

I support the Dendrobium Mine Project for the following reasons:
* Continued mining would sustain the employment of Dendrobium's workforce, create a further 100 jobs for the life of the Project and an additional 200 jobs in construction.
*The Project will generate around $714 million in royalties, taxes and rates, contributing to local and state infrastructure and services.
*The Project would allow South32 to continue to support local suppliers and contractors, providing additional security and longevity of employment in the region.
*The Project commits to not longwall mine under water supply reservoirs including dams, or under named watercourses and key stream features.
*The Project commits to a minimum of one-kilometre setbacks from the Avon and Cordeaux dam walls.
*The Project would provide an ongoing and essential local supply of metallurgical coal to BlueScope Steelworks.
*More than 90% of the 1800 employees live in the area creating flow on effects for local busineses.

No more coal, why isn't this message getting through? We are going through a climate catastrophe and these people insist on digging our own graves. Fires in the Arctic, fires in the Amazon, fires in Australia. Crippling drought is affecting much of NSW. All these things are made so much worse by the extraction and burning of coal. There is no way I can support the expansion of this project. It should be shut down, the coal should be left in the ground and the workers should be offered new employment. That is the only right and ethical thing to do in regards to this project. Not to forget about the impacts this has on Sydney's water. Nothing like bright orange iron fixing scum in our drinking water. And all the surface water that is lost to rock fracturing and subsidence. The NSW government needs to act in the interest of our people rather than their pockets and have the courage to say NO to this project. Just to rub salt in the wounds the company has the nerve to call themselves "Dendrobium" after the genus of plants that grow on the very rocks they destroy. Get out.

To whom it may concern,

If this project were to go ahead, dendrobium would contribute to massive amounts of lost water through its long wall mining and impacts, like cracking in the earths crust, caused by South 32. activities. Is this something the state of NSW can honestly afford for the next 30 years when we are facing widespread drought? Dams to the south of Sydney, like the Cataract and Woronona, are now at ever time lows and we are seeing level one water restrictions being put in place.

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.
The current climate emergency means it is no longer morally acceptable for the NSW government to support projects that will severely negatively impact its capacity to meet greenhouse gas reduction targets. The Rocky Hill case supported climate responsibility in its judgement against the Rocky Hill mine, citing the mining SEPP Clause 14 (2): “... the consent authority must consider an assessment of the greenhouse gas emissions (including downstream emissions) of the development.”
To put the volume of emissions in context, the federal government estimates Australia’s greenhouse gas emissions for the year to December 2018 as 538.2 million tonnes. 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 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‘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.

Please look to the future and for alternatives to coking coal like hydrogen gas (H2), which can be used as a reducing agent which results in Direct-Reduced Iron (DRI) and produces only water as a waste product (Fe2O3 + 3H2 → 2Fe + 3H2O). Unfortunately, hydrogen gas is usually manufactured with fossil fuels. There are alternatives, such as electrolysis of water, which are energy intensive. But if these processes used renewable energy sources, there would be no issue in terms of greenhouse gas emissions.

Metallurgical coal is on the way out and its time the state of NSW was on the right side of history.

Thank you for considering this objection.

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. This will result in damage and loss of the water from 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. The Management at the Steelworks should be investigating the use of hydrogen to reduce iron ore rather than coal. This technology could be used to increase Australian exports and provide jobs for our citizens.

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
Anna Harvey​

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