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SSD Modifications


MOD 2 - North West Mains Development

Wollongong City

Current Status: Determination

Interact with the stages for their names

  1. Prepare Mod Report
  2. Exhibition
  3. Collate Submissions
  4. Response to Submissions
  5. Assessment
  6. Recommendation
  7. Determination

Modification 2 proposes to extend the life of development (MP09_0161) to 2027 and facilitate the North West Mains Development

Attachments & Resources

Notice of Exhibition (1)

Notice of Exhibition_11022021_085831

Modification Application (17)

Modification Report Part 1
Modification Report Part 2
Appendix A to E
Appendix F - Air quality and greenhouse gas
Appendix G to H
Appendix I - Groundwater Part 1
Appendix I - Groundwater Part 2
Appendix I - Groundwater Part 3
Appendix I - Part 4 to J
Appendix K - Subsidence
Appendix L - Biodiversity
Appendix M - Historic Heritage Part 1
Appendix M - Historic Heritage Part 2
Appendix N - Aboriginal Heritage Part 1
Appendix N - Aboriginal Heritage Part 2
Appendix O to P
Appendix N - Aboriginal Heritage Part 1_AHIMS

Response to Submissions (12)

Submissions Report
Appendix A - Submissions Summary
Appendix B - Register of Submitters
Appendix C - Updated table of proposed mit msres
Appendix D - ACHA - Part 1
Appendix E - Subsidence assessment
Appendix F - Amended Statement of Heritage Impacts
Appendix G - Economic Letter Report
Appendix H - Sup. Groundwater Impact Assessment
Appendix I - Sup. Groundwater Model Peer Review
Appendix J - Surface Water Letter Report
Request RTS_Letter

Agency Advice (10)

Dams Safety review of RTS
DPIE Water Review of RTS
Resources Regulator review of RTS
MEG review of RTS
Water NSW review of RTS
EPA review of RTS
SANSW review of RTS
Heritage NSW review of RTS
HNSW ACH review of RTS
TfNSW review of RTS

Additional Information (12)

RFI 1 - Production clarification
RFI 2 - Heritage NSW
RFI 2 - Heritage NSW advice
RFI 2 - WCL Response
RFI 3 - DPIE Water
RFI 3 - DPIE Water advice
RFI 3 - WCL Response Letter
RFI 3 - WCL Response Supplementary Surface and Groundwater Assessment
RFI 3 - WCL Response Peer review
RFI 4 - Greenhouse gas
RFI 4 - Greenhouse gas addendum
RFI 4 - WCL Response

Determination (3)

Assessment Report
Instrument of Modification
Notice of Decision

Consolidated Consent (1)

Consolidated Consent


Showing 1 - 20 of 47 submissions
Name Withheld
Concerned Wollongong Rate Payers/Residents.
West Wollongong & Wongawilli, New South Wales

Object to Wollongong Coal's application for a time extension for its Wongawilli Colliery - Major Project 09_0161, Modification 1. Some of the reasons for my objection are:
- Wollongong Coal has had 5 years to make a go of this mine and they haven't succeeded. The company does not have the resources or the expertise to safely and responsibly carry out the project.
- Longwall mining has left a legacy of damage in Sydney's water catchment, including cracked and dried up river and creek beds, damaged and desiccated swamps, damage to and leakage from major storage dams and contamination of water. The Sydney Catchment Authority Special Areas provide drinking water to 4.6 million people of Greater Sydney. This area should be protected from longwall mining. Sydney is the only city in the world that allows longwall mining in a publicly owned drinking water catchment. This project has the potential to negatively impact Avon Dam, Cordeaux Dam, Upper Cordeaux No. 1 Dam, Upper Cordeaux No. 2 Dam and associated watercourses.
- The collapse of Nebo 2 longwall in February 2014 demonstrates that Wollongong Coal is not competent to carry out this mining. The Nebo longwalls are too close to the Cordeaux Reservoirs No 1 and No 2 and associated watercourses to risk further reckless and careless mining mishaps.
- The project fails to consider the cumulative impact of previous and intended future mining in the area.
- The unpredictable nature of multi-seam mining poses unacceptable risks where overlying coal seams have already been mined.
- The Wongawilli Colliery is currently in care-and-maintenance mode therefore, should this application not be approved, there will be negligible or no economic and employment impacts to the region.
Concerned Wollongong Rate Payers/Residents.
Deidre Stuart
KEIRAVILLE , New South Wales
REGARDING Wongawilli Coal Mine - MP09_0161-Mod-2


(1) We need to protect the water catchment rather than allow more mining. Even though this modification is for bord-and-pillar coal mining, all mining is damaging. Moreover the proponent WCL, has already undertaken longwall coal mining at their Wongawilli mine. Further bord-and-pillar mining adds to existing damage in the water catchment. We need to consider CUMULATIVE DAMAGE impacts rather than consider each proposal (like this one) in isolation.

(2) We need to protect our climate and try to limit and reduce GHG emissions, rather than approve further significant emissions associated with projects like this:
a. The TOTAL GHG emissions will be [5 years X (361,267 (scope-1) + 22,029 (scope-2) + 6,129,211 (scope-3)) tonnes CO2e/year] = 32,562,535 tonnes CO2e. This is equivalent to almost 9 million tonnes of extra C into the atmosphere. This is a lot to be allowing when we need to be cutting fossil fuel emissions urgently if we want to climate warming limited to 1.5 oC. The total budget for the whole world is 35,000 million tonnes C and the world already emits more than 11,000 million tonnes C annually, so there is not scope for yet more emissions (Sackett,2020) !
b. So considering Australian/NSW emissions only: Scope-1 & scope-2 total GHG emissions will be [5 years X (361,267 (scope-1) + 22,029 (scope-2)) tonnes CO2e/year] = 1,916,480 tonnes CO2e, equivalent to 522,676 tonnes of C extra into the atmosphere. The MOD-2 application compares these emissions to NSW and Australia annual 2018 emissions to try to minimise the significance of these emissions. Rather, it should compare these emissions to the NSW and Australia C budgets remaining if we are going to protect our climate, and to HAVE SOME CHANCE of keeping global warming below 1.5oC. Based on the former Chief Scientist of Australia, Penny Sackett's (2020) data, it is scary that NSW 2018 GHG emissions (35.9 Mt C) alone almost exceed the total C emissions budget for NSW (36 Mt C). The same is true for the Australia-wide 2018 GHG emissions relative to the remaining Australian C budget. So instead, the scale of existing NSW and Australian recent annual emissions relative to a population-based fair share of the remaining world C budget, should be a wake-up call that we need to cut emissions where we can right now, and certainly not approve any modification like the one proposed.

(3) WCL is not fit and proper to hold a mining licence. The company has a record on noncompliance with conditions. WCL is in a bad financial state. WCL avoids providing required information to community in CCC contexts. This company flouts the rules and seems to mostly get away with it. Their parent company has faced criminal prosecutions in India. Appallingly for me, though parts of the community, supported by EDO put forward a case that WCL is not fit and proper to hold a mining licence to the NSW government, and our complaint and concerns were assessed as worthy of investigation (in 2016), nonetheless the investigation was ultimately abandoned (Illawarra Mercury, 2020) allowing NSW ministers to wriggle out of their responsibilities to the community. They were able to avoid either having to front up and agree that WCL is not fit-and-proper, or claim that WCL is fit-and-proper and then face appropriate questioning on this latter front. Appalling! I request that the NSW government should properly complete the fit-and-proper investigation and inform the public of their conclusion - PRIOR to any determination of this MOD-2.


SACKETT (2020) sackett-narrabri-gas-project-ipc-advice-revised_final.pdf ( AUG 2020 Penny Sackett Narrabri gas IPC submission.
Sackett discusses a carbon budget in terms of tonnes of CARBON rather than CO2e. I note that 1 tonne C is equivalent to 3.667 tonne CO2e.
Calculations of Australia’s fair share of remaining C budget are based on Australia having 0.33 % of the world’s population.
Table3 in this document shows that GLOBAL C budget remaining is 35,000 Mt C and that Australia's and NSW's fair-share contributions to this are only 114 Mt C and 36 Mt C respectively, if we are to have some chance of staying within 1.5 oC warming.

Illawarra Mercury (June 2020)

EMM (2020) Table 7.9 of the MOD-2 Main Report Part 1, p77;
Based on the NSW and Australian 2018 calendar year emissions provided immediately below Table 7.9:
NSW: 131,684.9 kt CO2e is equiv to 35,914 kt C
Australia: 537,446.4 kt CO2e is equiv to 146,576.3 kt C.
Name Withheld
WONGAWILLI , New South Wales
I wish to provide comments about the mine proposed development at Wongawilli. I am a local Wongawilli resident and am neither in support or objecting to the operation of the mine. It has a great history in the area and provides an opportunity to increase local employment and supply chain opportunities.

My concerns and comments are based mostly around the access. Since the mine has been placed into caretaking, the surrounding suburbs have dramatically changed and increased in size, as such the roads are now not suitable for access to the mine and the train line is in a terrible state. The Mine development should only be considered for approval if they can satisfy the local community that the access to the mine both by road and train will cause little disruption to the access for residents, The applicants should also consider separate access options either for residents or the mine operations as the current access is limited to a single road which will soon have traffic lights installed. Wollongong Council is currently redeveloping this road, but it has been designed as a residential type access road and will have a bridge - has the mine considered the suitability of this to any vehicles or trucks requiring access as the new road will not allow for heaving type vehicles.

Ideally the mine should contribute to the local area by increasing road access and/or providing access so that residents do not have to leave the area as often, perhaps considering a commercial arrangement to open shopping, schools etc closer to the mine that would be of advantage to both workers and the local community.
Crown Lands
For mining operations involving Crown land, Crown roads and Crown waterways the following requirements apply:

1. All Crown land and Crown roads within a Mining Lease (with surface rights), subject to mining or mining related activity, must be subject to a Compensation Agreement issued under Section 265 of the Mining Act 1992, to be agreed and executed prior to any mining activity taking place. The Compensation Agreement may include conditions requiring the Mining Lease Holder to purchase Crown land impacted on by mining activity.
2. All Crown land and Crown roads located within an Exploration Licence, subject to exploration activity, must be subject to an Access Arrangement issued under Section 141 of the Mining Act 1992, to be agreed and executed prior to any exploration activity taking place.
3. All Crown land and Crown roads within a Mining Lease (with sub-surface rights only) must be subject to a Section 81 Consent under the Mining Act 1992 where surface activities are proposed, to be agreed and executed prior to any surface activity taking place.
Subsidence Advisory NSW
See attached response from Subsidence Advisory NSW
John Spira
AUSTINMER , New South Wales
I object to this project on the grounds that it will facilitate expansion of coal mining in the Special Areas of protected water catchments which will lead to further damage to the catchments and loss of water.
Christine Catling
WOMBARRA , New South Wales
I strongly object to this project that only serves the interests of Wollongong Coal Ltd, an extremely disreputable company - you must be aware of their history.
We do not need more damaging drivages in the Metropolitan Special Area, certainly not under Lake Avon, and we definitely do not want to enable future coal mine development in the water catchment. Also we do not need more coal extraction and combustion contributing to climate change!
There ARE alternatives to coal, and this government needs to catch up on and heed the science available in this space.
Warren Birkinshaw
ARCADIA , New South Wales
Any extension to any coal mine within the Sydney catchment special area including this one, must be rejected. Sydney and the Wollongong area have total reliance on our dams and catchments for our water supply with the exception of the Desalination Plant, but that is irrelevant.
We must not put our water security at risk simply to allow big business coal to expand their mining area. We are already seeing the damage done by exisiting longwall mines within our catchment including large subsidence crackers taking vast volumes of water from our inflow creeks and rivers. This damage is permanent and irreversible and as well as losing the water to our support system it is heavily polluted as a result.
Secondly we are at crisis point with climate change and one impact of that is decreasing rainfall, a double whammy when we are also allowing water to be lost to the coal mines.
Finally, and again in relation to climate change, we are in crisis with regard to Green House Gas emissions, and expanding our coal mining furthers the emissions, regardless of whether the coal is burned here or overseas . It is a moot point that Australia sees fit to disre emissions from our coal if burned overseas. It is still adding GHGs, and is something we can prevent
Department of Transport
Chippendale , New South Wales
TfNSW Response
Name Withheld
FAIRY MEADOW , New South Wales
The proposed Modification-2 first workings NWMD will go under the Avon Reservoir, which is only water supply source for over 310,000 residents and businesses in the Illawarra region! I do not trust Wollongong Coal Ltd to create driveages under Avon Reservoir without causing any damage to this vital water supply... Not only this, but it isn't even clear how much coal will be extracted, despite the proposal allowing for upto 2 Mt per year for five years, and despite the urgent need to protect our climate, there is no plan to offset greenhouse gas emissions for even Scope-1 and Scope-2 emissions.

I am extremely against this project, and all mining or extensions to existing mines in this area, especially under water catchments where mining has long contributed to a massive loss of water, the most vital and precious resource we have. No mineral is worth the long term and irreversible loss of our water resources.
BATHURST , New South Wales
Please find attached the EPA's comments on the proposed Wongawilli Colliery modification no. 2
Regional NSW - Mining, Exploration & Geoscience
Maitland , New South Wales
Please see attached response.
Heritage NSW – Aboriginal cultural heritage (ACH)
QUEANBEYAN , New South Wales
Heritage NSW comments for Aboriginal cultural heritage matters attached.
PARRAMATTA , New South Wales
Please refer to attached letter
NSW Resources Regulator
Please refer to the attached letter from the Resources Regulator outlining our review of the modification report
Rada Germanos
CROYDON , New South Wales
I strongly object to the Wongawilli MOD2 proposal to construct the North West Mains Driveage 8km further into the water catchment, clearly in an attempt to open up further mining west, further into the Special Areas of the Greater Sydney Water Catchment. This would go underneath Lake Avon, which forms a crucial part of the water catchment and water supply for this region. This is far too risky to proceed, and this Modification should be rejected by DPIE.
Stephen Young
THIRROUL , New South Wales
Please see attachment
Emma Rooksby
MOUNT PLEASANT , New South Wales
I object to this proposed modification for the following reasons:
(1) The economic assessment is incomplete - this project is really part of a larger proposal to mine the North-West and South-West domains. As such it should be assessed as part of that larger proposal, not on its own. Cumulative impacts are systematically under-considered in relation to proposals such as this.
(2) The project does not cost important externalities, such as loss of water through mine inflows and discharge of polluted water into Robins Creek which flows into Lake Illawarra. The cost of externalities such as these was part of the reason that South32's recent proposal to expand the Dendrobium coal mine was rejected.
(3) The project proposal underestimates greenhouse gas emissions. The documentation uses an inappropriately low carbon price and allocates a proportion of the cost to NSW as a fraction of global population. These estimates are not consistent with the Government of NSW's intention to reduce the state's carbon emissions.
Name Withheld
EAST CORRIMAL , New South Wales
I object to the project because of the following:
The economic assessment is incomplete because it is not being assessed as part of a larger proposal to mine the North-West and South-West domains - the risk is obvious and smacks more than a little of subterfuge.
Not everything has been costed, and some of them are potentially huge, for example: loss of water through mine inflows and discharge of polluted water into Robins Creek which flows into Lake Illawarra, a significant environmental and recreational resource.
Wollongong Coal is at risk of bankruptcy so this project carries a huge risk of insolvency down the track, a cost all ratepayers will no doubt have to carry. And what environmental burden will be left? too scary to contemplate.
Greenhouse gas emissions have been significantly underestimated because of the sneaky trick of using a low carbon price and proportioning the cost to NSW as a fraction of global population. This is significant for more than our local environment and we should not allow such a thing to occur in our time and space.
Biodiversity and Conservation Division
Parramatta , New South Wales
Hi Jack
Please see attached our comments on this mod, happy to discuss further if required.


Project Details

Application Number
Main Project
Assessment Type
SSD Modifications
Development Type
Coal Mining
Local Government Areas
Wollongong City
Determination Date
Executive Director

Contact Planner

Jack Turner