Dendrobium Mine Extension Project

Please see attached documentation in support of the plan

Continued mining would sustain the employment of Dendrobiums workforce, create a further 100 jobs for the life of the project and an additional 200 jobs in construction. The prjoject will generate around $715 million in royalties, taxes and rates, contributing to local and state infrastructure and services. The project will result in a total net benefit to the NSW economy of over $2.8 billion, including over $1.1 billion to greater Wollongong Region. 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 the 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 commits to pursue opportunities for industrial users to reuse our excess mine water. South32 supports biodiversity research in the water catchment, including swamps and endangered species such as the giant dragonfly and the littlejohns tree frog.

The project would provide an ongoing and essential local supply of metallurgical coal to BlueScope Steelworks. South32 currently supplies around 60% of BlueScope Steelworks' metallurgial coal requirements.

I am in support of the project going ahead

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

Please see attached

My comments are based on person view and not the 1000's of pages involved with the application as I and I suspect most individuals would not have the time nor the jargon to review such.
If I look at the mine it is beneficial to the greater community for work and therefore generation of income.
If I look at it through a narrow lens of living at Mount Kembla the view is different. the mine brings traffic, noise, pollution. It possibly threatens the water supply with the extensions and I wonder if subsidence will be a future cost. So while in principal I support the application it is conditional, the mine contributes 3 cents a ton to community in the proximity of the mine. If i understand it was to cease operation in few years however the proposal allows significant extension in areas to mine and increases in productions staff and facilities. So I would ask in exchange for more traffic, more noise, more pollution and an extension in operation for many more years:
1 Increase the contribution to the community from the 3 cents a ton to reflect todays values and the increased burden to Mount Kembla. Perhaps now 20 cents a ton would be reasonable? (how many years ago was 3 cents a ton declared?)
2 Improve the road up to the highway , along Harry Greyham Drive as the mine will send far more traffic this way and proportions of this road are 1 lane which is not safe
3 Provide walking an extension of footpath /bike track from Mount Kembla to Kembla Heights. More traffic and no other way for kids or anyone to walk except on the road
4 Ground water from the mine should be used productively if practicable and flows monitored (that are lost to the catchment area)
I believe it is reasonable that for significant long term impact to Mount Kembla it is reasonable that there is significant benefits to the area as we life there. I often hear the mine at night, I ofter have issues with leaving my street because of the traffic to the mine. If i had to take a trailer of dirt to the tip I would have to cover it or be fined but the train from the mine has perhaps 500 tons in 20 carriages multiple times a day not covered. My point is there is impact and there should be significant benefit to the Mount Kembla area

Thanks for reading

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 and this needs to end for the sake of our water security. 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. How can this project even be considered!

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. No risk is acceptable.

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. No job is worth the loss of water for millions and these corporations will not stop operating based on one declined application.

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. Again how can we risk our water -and there are ALWAYS risks.

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
Antonia
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].



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
Sharon Pusell.

​

My concern is with damage to our water supply. The rock forming our water catchment is to be broken, solid rock will be rendered to rubble, the ground formed by millions of years of natural erosion will be collapsed. Massive cracks will cross the landscape, riven from deep down where the mine roof caves in after the coal is extracted. The natural course of water through the landscape will be permanently disrupted. The ecological communities that filter the water will be drained. The animals that depend on the surface water will go thirsty. The people of Sydney will be for ever left with less available drinking water. All of this is planned to happen, it is already evident in damage done so far.
The Environmental Risk Assessment prepared for the Dendrobium Extension project clearly outlines a range of subsidence effects that will further damage the topograhy of the Metropolitan Special Area catchment. Water lost to the damage of the land surface can not be accurately estimated, there have been insufficient hydrological studies of the landform prior to mining, however it is self evident that further longwall mining will result in further water losses. It is estimated that the mine itself will drain 26.7 ML per day at peak production. 26.7 ML is enough water to supply 125 000 people with water. An unquantified amount of water will enter the cracks and remain latent in the rock profile. In low rainfall events the water that would have travelled downstream will now travel down cracks from where it may evaporate. Water that does re-emege from the cracks will carry high levels of iron and manganese that feed the bacterial red floc that will pollute the water supply. There is a real risk that the cracking will also create fissures that permanently drain water out of the catchment. All of this damage, once done, is irreversible. The mine operators have prepared documentation that tries to justify the risk to our water supply but they have no contingencies to cover on-going water losses, the people of Sydney are being asked to bear the risk to our water supply.
I ask that the Planning Minister consider the map illustrating the extent of mine work, the profusion of the tributaries, and the boundaries of the Special Catchment area. WaterNSW and previous authorities charged with protecting our water supply have advised against longwall mining under the catchment.
Allowing further permanent geological damage to the catchment would be an abrogation of responsible planning.

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 oppose South32’s application for the expansion of the Dendrobium mine. This is based on the impact mining currently has on the water catchment, the huge risk to the water catchment from the proposed expansion and the negative impact on the climate that burning the coal from this expanded mine will have.

Currently, mining is having serious impacts on the environment within the water catchment. The monitoring sites above the current mining operations of South32 within the catchment area are a major cause for concern. In the middle of a drought, when dam levels are falling, the water catchment for Australia’s most populous city should not be put at risk. South32 cannot guarantee that their current operations aren’t impacting the retention of water for Sydney and Wollongong’s inhabitants. It would be irresponsible in the extreme to put water security for millions of people at risk by allowing extraction of coal further under the water catchment.

Recently, Wollongong City Council declared a climate emergency. The science is well and truly settled that without major reduction in emissions, we won’t keep temperature rises to 1.5 degrees celsius. Within this context, we must take responsibility for our contributions to this emergency. The notion that we can meet our obligations, but use and export increasing amounts of coal, would demonstrate that we as a community are not serious about taking action on climate change. Nation states may want to conveniently think they are operating in a vacuum in relation to this issue, but human-induced climate change is a global problem that will need a global solution. If we were to accept a situation that any emissions reductions achieved were completely cancelled out by our willingness to expand coal mines such as Dendrobium, we would be acting immorally and without logic. For any global action to work, we need to contribute at every level of government. It is our responsibility to say no to this expansion to meet our moral obligations.

Coal mining has played an important part in the history of this area. People can be proud of this history, but we should not let nostalgia lead us to simply repeat attempts to generate economic prosperity, ignoring other possibilities, but also the future of the health and well-being of the wider population, who we must remember, also contribute to the local economy and in greater amounts than coal mining does currently. I would back tax-payer funded initiatives, including re-training programs, that supported affected workers so that they could remain in the area. But even those affected by a rejection of the expansion of the mine will rely on clean and plentiful water. The security of water must be prioritised.

I am objecting to this project for the following reasons:
1. This Project is a very substantial development within Sydney's Water Supply Catchments, much of it also within the Catchments' Special Areas.
Subsidence of at least 2 metres is expected to occur over the area mined and to a lesser extent beyond the mining limits.
Previous Longwall mining has now been shown to cause surface fracturing and cracking leading loss of water from streams and swamps in the Catchment Areas, with the consequent loss of water storage. The scale of this development greatly increases the risk of significant damage to the Water Catchments.
2. The degree and type of subsidence will depend upon the geology of the overlying strata. The structure of the rocks, especially faulting and dykes can have a significant effect on the surface. Fracturing from faulting, or from intrusion of dykes can provide conduits for surface water from streams, creeks and swamps to escape.
Dyke intrusion is often associated with fracturing of surrounding rocks.
The structural geology of these areas is quite complex, with a number of igneous intrusions of dykes and quite large sills, as well as known and suspected faulting.
There are likely to be many other structures which have not yet been detected.
I note that the report indicates that some seismic surveys have been carried out, but results were not given. At any rate these surveys were unlikely to detect faults of less than 5 to 10 metres. This indicates a greater degree of uncertainty when trying to predict likely effects of subsidence.

Our climate is becoming warmer and in many places dryer. In this, the driest of Continents, water is by far, our most vital and valuable resource.
We should not be taking any risks with our water supplies.
For these reasons this project should be rejected
Yours sincerely
Peter Lamb, BSc Geology

Submission - Dendrobium Mine Extension SSD-8194
I totally object to ANY extension of the Dendrobium mine SSD-8194 for many very good reasons, the primary one being the risk of damage to Greater Sydney’s Water Catchments from the super-destructive process of longwall mining.
It’s ironic that, at the same time as Governments are encouraging more and more migrants to come here for economic productivity reasons, we are risking destruction of their clean water needs! That seems really dumb planning!
Groundwater losses from lllawarra Coal’s existing mining in the catchments are already something like 3,000,000 litres/day! Either the longwall process or the mine owners or both cannot be trusted to guarantee that no water will be lost from their mining operations.
Australia is an arid country. A 1997 CSIRO Report said only 5% of it is arable and most of that is degraded! And government authorities want to support undermining our water catchments at great risk to Sydney’s water supplies?
Apparently one third of the coal is used to make steel by our BHP, but the other two thirds are exported. Who profits here? Not the citizens of NSW or Australia in any meaningful way.
What is the meaning of “protected”? The proposed extension is in the protected “Special Areas” of the water catchments...(POWA information night, 5/9/19).
The idea of OFFSETS (a weasel word), was probably invented by multinationals to get around restrictions to what they want to do. For example, cutting down mature trees and planting new trees somewhere else destroys a fully functioning ecology with a bandaid solution. Same with proposed water catchment offsets- a dumb idea.
With 11 years of mining still to go for Dendrobium, it’s time we started looking after our own land and phasing out coal mining under our water catchments. Why do we risk the ecological destruction of our country for a heap of export dollars? Within the next 11 years technology will have developed rapidly the alternatives to coal for steel making. Green steel technology is being already used in some countries but not to scale. Also re-cycled steel is now in use. So 11 years is plenty of years to plan the closure of Dendrobium mine altogether.
Yours sincerely,
ELSA STORY
2/30 Campbell Street Woonona. NSW 2517 O431179830

As a Local Business Chamber, we represent the interests of our broader community and of course our members, many of whom are service providers and/or suppliers to the Illawarra mining and manufacturing industries, as well as the Port and its other tennants.

The mining and manufacturing industries and highly capital intensive and many smaller, family owned and run businesses in the Illawarra have been able to grow based on the success of these local foundation industries. We recognise there is no current alternative to the use of coking coal for the steel making process, and as such realise the interconnectivity between the Dendrobium expansion, the steel works and indeed the broader economic stability and growth of the region.

The approval of the Dendrobium mine would ensure Bluescope’s supply of high-quality local coal is maintained and the company’s long-term viability is not put at risk through the eradication of the local coking coal industry.

For these reasons, we support South32’s application for the continuation of mining in the Illawarra and urge the NSW Government to consider the broader socio-economic impact on the region and the hundreds of local businesses of their decision to approve or not approve South32's application.

My family and I will have to concider our financial position and job security in the future if this project does not proceed. Employment in the Coal industry is one of the main contibuting factors that has kept us in the Illawarra and starting a family here. Many others will be in the same position. This is a great oportunity for the Illawarra to develop long term industrial jobs for the region and help it thrive.

The Wollongong branch of the Australian Youth Climate Coalition (AYCC) objects to this expansion. Please see attached document for details

If approved, this mine will contribute more than 0.125% of Australia's total annual greenhouse gas emission targets (scope 1 emissions only). The total emissions including the combustion of the coal will contribute approximately seven times this amount. Our planet cannot afford this.
The loss of water from the Sydney water catchment is also a huge issue with this mine. Sydney is growing rapidly and the water catchment is getting more and more porous. We must not lose our water down cracks into mines.

To whom it may concern,
I am strongly opposed to any extension to mining under the Sydney catchment area, including the Dendrobium Mine Extension Project. Approving this would be extremely irresponsible, with the potential to impact Sydney drinking water supply, and drain Temperate highland peat swaps, which are endangered ecological communities. UNSW Water Research Laboratory says existing Dendrobium operations are undermining swamps, removing their ability to store water, particularly important during current drought conditions. WaterNSW is also opposed to this proposal, emphasising the seriousness of potential impacts. It is clear that the potential economic benefits of the mine extension are heavily outweighed by negative consequences, including potential impacts to Sydney's drinking water supply, and endangered ecological communities.
Regards,
Brendan Pitt

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

Offsets do not compensate for mining-induced destruction of catchment land and ecosystems.

Mining followed by remediation is no longer acceptable, and does not drive better or more sustainable mining behaviour. Remediation has not proven successful.

Water catchment areas should be protected from mining until techniques can be developed that do not impact on the quality or quantity of water. There may never be a mining technique developed that can prove no impact, and if this is the case, then no mining should occur in Water catchment areas. That is how it should be - the precautionary principle should be applied. At the moment the Water Catchment areas, especially those supplying the Sydney - Macarthur - Illawarra areas are being mined underneath, and heavily impacted. This is not sustainable, and potentially population limiting. The damage cannot be reversed or adequately offset. The Upper Nepean dams are the sole source of supply to the Macarthur region.

Targets and objectives should be included in any regulation of extractive industry. Licences with limits should be placed on water use and heavy metal contamination. Recycling and treatment should be required by all mines.

All mines require a plan which includes maintence in perpetuity. When mines close, ongoing pumping of groundwater and other remediation measures are required to avoid flooding and heavy metal contamination. If the mine cannot economically sustain such costs forever, even after closure, then it is not viable and should not be approved at all.

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

Supports the current full time operational jobs and provides financial boost and stability for the region.