Glendell Continued Operations Project

The Glendell mine should not be expanded. Coal is rapidly becoming an obsolete source of energy. Continuing to mine coal produces no benefit to our society but greatly harms the people and the planet. Coal dust, coal trains, and the processing facilities in Newcastle all cause massive amounts of air pollution which negatively impacts the health of people in the region. This proposal is not going to produce any new permanent jobs - which is what people actually need, and economically, will not greatly benefit the people of Australia. The future is renewable energy. The sooner we start investing in renewable power and training people for these industries, the better off Australia and Australians will be. Stop coal.

I object to the proposed Glendell Continuation Project because the approval of any further extraction of coal to burn for electricity is the absolutely wrong direction to be heading under our global climate emergency situation. We need to be decreasing the amount of carbon in the atmosphere, not adding to it. We must head towards a zero-carbon economy. No further coal extraction projects should be approved.
It is incumbent upon NSW Government to accept its responsibility to act on the need for a sustainable future. Our recent Summer (and Spring!) of drought and fire and pain and suffering of animals (including humans) and plants and the ecosystems that we support and are supported by has pushed us, at last, to the awareness of the interrelated consequences of climate change. We cannot afford to burn coal for power when we admit we have an unsafe climate. It is a self-evident fact that there is a global carbon budget and we have overspent. The IPCC reported that the majority of fossil fuels need to remain in the ground to come even close to keeping global warming below two degrees.
The collaboration of the government with the fossil fuel industry is not in the public interest. Glencore is very aware that the Coal Age is over but this transition era to renewable energy must be facilitated as a matter of urgency. It is very important to take every opportunity for action on minimising climate change impact. The rejection of this project would send the appropriate message to the coal mining industry of the vital need to accept the declining coal demand worldwide.
It is patently wrong to approve the continuation of the Glendell Mine. The assessment of the impact of this proposed continuation records that the project is consistent with the IPCC’s “high emissions A2 emission trajectory scenario.” This is a remarkable admission of overwhelming significant impact. This scenario has a planet warmed by 3.4 degrees C by 2100.
I object to this project . I submit that the application should be rejected as it is not in the public interest. It does not comply with the requirements of ecologically sustainable development. There is clearly no intergenerational equity. The long term environmental costs far outweigh the private economic benefits.

This project offers continued financial stability to the region through retained employment and local expenditure.

GLENDELL PROPOSAL

I object to this project on three grounds

1 the impact on ground water
2 the inadequacy of the stygofauna impact study
3 the impact on climate

1 GROUNDWATER IMPACT

The groundwater model uses hydraulic property data (refer Appendix B - table B9). These are not site-specific parameters and the model is probably very sensitive to these values (especially for the alluvium). The groundwater model is used to estimate the groundwater take and if the model parameters are not close to what they are in reality, then the water take is likely not correct.
Section 7.3 talks about post mining conditions. Modelling shows that the “water level within the final void will slowly recover over a period of approximately 450 years stabilising at approximately -60 mAHD”, which is 130m deeper than the natural water level in that area.This means that the groundwater will always be flowing toward the pit void and PERMANENTLY removing that water from the greater groundwater system. Such a long-term impact is not acceptable

The gross disruption of the ground surface and the removal of two tributaries of Bowmans Creek must surely be removing water flowing to the hunter river and to the hunter river alluvium aquifer. The Bowmans Creek alluvium are dry NOW and is likely that the existing mines have impacted the creek recharge from groundwater.
The Ashton mine (downstream) annual groundwater review
https://www.ashtoncoal.com.au/icms_docs/307762_2018-annual-review.pdf (figure 4.1 on page 112 of PDF and figure 4.5 on p114) and the Liddell Mine (upstream of Glendell) annual groundwater review also shows parts of Bowmans Creek alluvium running dry - https://www.liddellcoal.com.au/en/Publications/AnnualReports/Annual%20Review%202018.pdf (p177 of the PDF sampling results tables ALV 8S) water level goes from 9.02 to 15.67m below ground level.

If tributaries of Bowmans creek are mined then the creek may not flow even outside of drought times. There is already a serious cumulative impact from existing mines.

It is questionable that On the topic of alluvium drawdown in post mining recovery conditions, it is unclear how long it will take the Bowmans Creek to recovery and if it will even fully recover.
The post mining chapter states “the drawdown attributable to the Approved Operations and the Project within the Quaternary alluvium are therefore unlikely to be detectable from seasonable fluctuations and the recovering system.” This does not say that there will be NO on-going impacts. The report shows that there will be impact the alluvium groundwater system for greater than 450 years!! This is unacceptable. Also this is just the report impacts from the Project and NOT the cumulative impact of the all of the surrounding mines!

The conclusions chapter states that the “The Project proposes to remove alluvium associated with Yorks Creek and Swamp Creek.” The conclusion also states that seepage and water take will not increase significantly. How can a project of this size not increase the total impact significantly?

The report describes the alluvium as not being significant, but this is a subjective view. Bowmans Creek catchment is circa 215km2 (from Google earth) the area likely to be removed by Glendell North project is circa 22km2 (including unmined upper creek catchment). That is a 10% reduction in contribution to Bowmans Creek either via surface water flow or groundwater recharge.

2. STYGOFAUNA ASSESSMENT
Stygo fauna tested only once
Sampling was conducted between 4 and 6 September 2018 (Section 7 of EcoLogical
report dated 26 November 2019)
Sampling also occurred during a drought cycle of Bowmans Creek. This can be seen
through the comments regarding 9 of the 22 bores were DRY at the time of sampling.

The report states that the stygofauna identified are endemic to the Hunter River basin,
which is true, BUT they only tested one round in winter and during a drought. ANY other flora and fauna assessment need both spring and autumn surveys to assess for seasonal variability in the ecosystem. Why is the stygo/troglofauna and or hyporheic fauna being treat differently. Bowmans Creek may host stygo/troglofauna during a
Spring cycle or when the alluvium is saturated. There could be fauna that migrates to the area during wetter cycles that haven’t been identified.

Secondly, the groundwater impact assessment identifies impact to the Bowmans creek
alluvium water level causing a potential permanent separation of the saturated portions of the alluvium. This is unacceptable in relation to maintaining stygo/troglofaunal and or hyporheic fauna habitat in the area, especially considering that the stygofauna assessment is not complete.
Stygofauna should be treated the same as other fauna AND should also be considered a groundwater dependent ecosystem (GDE.)
In the case of the stygofauna being a GDE, then according to the NSW aquifer
interference policy (2012) the GDE must not be impacted without make good measures being put in place…and the stygofauna assessment actually recommends NO FURTHER MONITROING IS REQUIRED!?! For a start, there needs to be a proper baseline study during a wet season.

3 CLIMATE IMPACT
Scientists have been warning us about the impacts of greenhouse gas emissions on climate since the 1980s. And emissions are still rising. After the summer we have just experienced I am amazed that anyone would be even suggesting that mining not only be extended, but accelerated. How is this in anyway in line with what we know, with certainty, has to be done? This last January was, globally, the warmest January ever recorded. We are currently on track for warming of 4 degrees C or beyond. If we do not change direction, and actually stop what we are doing, this is exactly where we will end up.

TO FURTHER INCREASE COAL PRODUCTION IS UNCONSIONABLE.

Anthony Lonergan
[email protected]
0428189585

Climate Action Newcastle objects to this project proposal.
Please see attached submission.
Sincerely
Committee, Climate Action Newcastle

I OBJECT to this proposal.
Please see comments attached.
Sincerely
Su Morley

Email sent on 14/2/2020

BCD's comments on the EIS are attached.

As per attached letter

Good afternoon
Please see attached Resources Regulator response
Regards
Matt

BCD's bilateral assessment has been completed. A copy is attached.