Dendrobium Mine Extension Project

I object to this proposal for reasons including the increased and extended use of water, to the detriment of swampland and the Sydney Water Catchment. I object to the length of the expansion and the associated climate impacts. Offsets are an unacceptable solution and this mine expansion is unnecessary, unjustifiable and should be rejected in full.

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194. The Dendrobium mine expansion will more than likely cause more damage to the Specials Areas of our water catchment. The water losses we are already seeing due to mining in our water catchments is a wasteful disgrace. Water Security should be a priority with no mining in our water catchments.

South 32 is seeking approval for an extension to their existing Dendrobium Mine, near Mt Kembla.
I object to: ILLAWARRA COAL'S PROPOSED MINE EXTENSION FOR DENDROBIUM. PROJECTSSD-8194.
I object to this proposed extension which 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. The 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. 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 mineoperating in the Greater Sydney Water Catchment area. It would be reckless and immoral for the Dept. of Planning to support this expansion.
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 256million and 260.7 million tonnesof 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 impact its capacity to meet greenhouse gas emissions reductions targets. To put the volume of emissions in context, the federal government estimates australia's greenhouse gas emissions for the year to december 22018 as 538.2 million tonnes. Approval of this mine would lockin emissions over the life of the project the equivalent of 48% of the 2018 annual emissions for all of Australia.
30 years of mining is too long in view of increasing population pressure on water resources and impacts of climate change.
South 32 has not provided alternatives to this destructive mining proposal posing unacceptable risks to the Greater Sydney Water Catchment Special Areas.
Offsets do not compensate for mining -induced destruction of catchment land and ecosystems.
Billions of litres of water will be lost from Greater Sydney's Water Catchment.
I ask that you reject this application from Illawarra Coal and commence a process to close the mine at Dendrobium permanently.
Thankyou for considering this submission.
Regards, Jennifer Fitzgerald

I object to the Illawarra Coal’s Proposed Mine Extension for Dendrobium. Project SSD-8194.
I was born in Wollongong, not far from Cordeaux Dam. I have been a resident of Sydney for 35 years. I am appalled that this project impacts on my water supply, in that the ability of the Avon, Cordeaux and Nepean Reservoirs to collect water is reduced (especially in this age of climate change and period of drought). This is because Dendrobium’s longwall mining is causing subsidence of up to 3 metres in the protected “Special Areas” of the water catchment for Sydney, Macarthur and Illawarra. When the land subsides due to longwall mining underneath, cracks in the earth appear, and water that would normally be collected in the dams drains underground into these voids.
I am an ex-infants’ school teacher and a grandmother (as well as having a 2010 degree in Information Technology) and I can tell you that the kids in my life have no trouble grasping the idea that the above scenario is a very bad idea. I just hope that the decision-makers in the Department of Planning, Industry and Environment have the same good sense.

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

With best regards,
Bronwyn Vost.

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

Recent scientific research by the University of New South Wales has proven that underground mining operations at the Dendrobium Mine have seriously and permanently damaged surface features that are essential to the long term water supply for Sydney and the Illawarra. Further extensions to this mine must not be allowed.

This project will provide continued jobs for our region. If the Dendrobium Coal mine was to close the flow on effect to the rest of the community would be devastating.

See attachment.

it goes ahead there will be substantially more damage to the Specials Areas of our water catchment as described in the proposal. Surely we are feeling the threat of water security this Spring, let alone Summer. Water availability has been an issue for fire fighters already this Spring.
Intelligent life needs to be focussing on the fastest exit from fossil fuel era that we can achieve, to head off the completely catastrophic consequences of climate change not lock in coal mining agreements for the next 30 yrs.

I support the Dendrobium Mine Extersion Project, due to the opportunities and support it provides to the local communities. Not only in the ongoing support in providing full time jobs, but in the contribution that South 32 - Illawarra Metallurgical Coal will continue to provide. The impact that will occur if this project does not go ahead, will impact local businesses/suppliers and also local and international customers that they provide to. Illawarra Metallurgical Coal are commited to ensure that they work with the environment and have demonstrated the care that they have through the ongoing commitment in monitoring and consideration that they go through in designing the mine.

Continued mining would sustain the employment of Dendrobium’s workforce, create a further jobs for the life of the Project and an additional jobs in construction.
The Project will generate around $714 million in royalties, taxes and rates.
The Project will result in a total net benefit to the NSW economy of over $2.8 billion.
The Project would allow South32 to continue to support local suppliers and contractors, providing additional security and longevity of employment in the region.

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].

Pacific National is a strong supporter of Dendrobium Mine Extension Project being approved. Pacific National believes that the Dendrobium mine extension and its associated support services (including freight rail operations) will provide increased economic benefits to the region, the state of NSW and the nation.

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 years 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

Dr Siobhan Irving
​

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

Given the current state of the environment and the level of drought that Australia and NSW is currently experiencing, increasing the term of this endeavour is foolhardy and irresponsible. There is not enough money in the world to replace the water supply to Sydney once it’s damaged. This mine needs to close it doors now if not at its scheduled end date.

It’s the council and governments responsibility to ensure human beings have a fit environment to live in. This mine will destroy that environment and will not be able to be repaired in a time frame that will help repair the extreme amount of damage it has caused.

Please move away from coal and into renewable energies. It might not be a popular opinion but Australia does not need to rely on other countries for our income or supply, we have the ability to be completely self sufficient if we just commit to ourselves and our beautiful country.

Thanks.

I believe the Dendrobium Mine Expansion is an important and valuable project for the local economy and community of Wollongong. The project will provide ongoing employment for workers at Dendrobium mine, and will also create about 100 jobs for the duration of the project and 200 jobs during the construction phase. The project will contribute around $714 million in revenue for local and state governments.
The coal mined at Dendrobium is a vital ingredient in steelmaking. The mine provides high quality low cost resource which supports the viability of BlueScope Steel, which is another important provider of employment for the local community.
While the proposed mining area is under the Sydney Water Catchment, I understand that a number of measures which will keep environmental impacts to a minimum including biodiversity offsets, not mining with a significant distance of the dam walls, not mining under named watercourses and key stream features. I also understand that the longwall width proposed does not have a significant impact on the likelihood of surface water losses, and that the surface water take is insignificant compared to other surface water losses. The main source of water going into the mine is from groundwater (as opposed to surface water), which is unavailable for use as drinking water in any case. The mine is investigating options for beneficial re-use of all water from the mine.
I think the project present very low environmental risks, with significant economic benefits for the region, and I support the project.

I support the continuation of the mining activities at Dendrobium.
The continuation and expansion of the existing mine will create and sustain numerous jobs for the local community. South32 will continue to uphold it's high standards and ensure the impact on the environment is minimal, as opposed to other mines in the region which have been scrutinized in the media for their negative impact on the local environment.
Mining has been a crucial part of the history of the Illawarra Region for over 100 years, providing jobs, creating new careers and supplying coal for use in steel, and should continue to play it's valuable part in the lives of those living throughout the Illawarra for many years to come.

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.

Thank you for considering this submission.

References
[i] Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[ii] Environmental Assessment Part 2, Section 6, pp 150 – 151 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[iii] Gloucester Resources Limited v Minister for Planning [2019] NSWLEC 7, Item 491, accessed at:
https://www.caselaw.nsw.gov.au/decision/5c59012ce4b02a5a800be47f#_Toc431203
[iv] http://www.environment.gov.au/climate-change/climate-science-data/greenhouse-gas-measurement/publications/quarterly-update-australias-nggi-dec-2018
[v] Environmental Assessment Part 2, Section 6, pp 150 – 151, op cit
[vi] https://www.illawarramercury.com.au/story/6295531/bluescope-wont-say-dendrobium-closure-could-finish-steelworks/
[vii] Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[viii] Ibid
[ix] Dendrobium Mine – Plan for the Future: Coal for Steelmaking, Groundwater Assessment for South32 – Illawarra Coal, NPM Technical Pty Ltd trading as HydroSimulations, 2019, p 101 accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[x] Surface Water Assessment, HEC, 2019, p ix, accessed at:
https://www.planningportal.nsw.gov.au/major-projects/project/9696
[xi] ibid, p 111
[xii] Based on an average daily water usage for Sydney residents of 210 litres. Source:
https://theconversation.com/why-sydney-residents-use-30-more-water-per-day-than-melburnians-117656

I have attached our Company letter of support

I have attached my letter of support