MOD 2 - North West Mains Development

Please find attached my submission for Wongawilli Mod 2

As a local resident in the area and having dealings with the mine and knowing their questionable capital/safety/ business ethics, I believe this Company is not a good fit for our Community as bills are not paid and the Mine facilities and surrounds are not kept up to date.
Mining within 100 metres under a water catchment is not in the best interests of all of our Community.
I have heard there is only one way in and one way out of the shaft, which presents a safety issue for the miners.
The environmental and noise factors for the Community would continue for another 5 years, damaging the Community lands and wildlife.

Wollongong Coal Ltd, Wangawilli Colliery Modification 2 of Project Approval PA-09 0161
I object to Modification 2
This proposal involves building an underground roadway under the Special Areas of the drinking water catchments, including under the Avon Reservoir. Avon Dam provides water to the Illawarra, MacArthur and Wollondilly Shire, as well as Metropolitan Sydney. Whilst surface cracking and subsidence are predicted to be minimal, there can be no guarantees. All mining in the catchments must be assessed bearing in mind the accumulative impacts, as no project stands alone. Water is becoming more and more precious and, I believe, should take precedence over coal.
As the predicted effects of climate change are becoming clearer, GHG emissions must be seriously considered, including Scope 3. We are one planet, wherever the coal is burnt.
Whilst this is a proposal for a 5 year project, I understand that Wollongong Coal intends, during this time, to seek approval for mining activities within the North West and South West Domain, utilising the existing Wongawilli pit top infrastructure with a 30 year mine life. Surely this needs to be taken into account in the assessment? How can the 5 year project be considered on its own?
In August 2020 it was reported that Wollongong Coal had debts exceeding $1 billion. Furthermore, they have a history of breaches and non-compliance. I don’t see how they could pass the fit and proper test?
I oppose approval of this project.

See attachment

I am writing this submission to object very strongly to Wongawilli Coal Mine Modification-2
My name is Cherrida Hardaker and I am really concerned that this company is not a fit and proper organisation to be doing any mining in our water catchment for many reasons. As there is such a short time allowing us to submit our concerns, this submission will not be of the standard that I would have preferred but it is especially important that you understand that there are many of us in the community that are totally against this modification.
Below I will list some of the reasons why I object and why I believe strongly that you should also object. These reasons are not necessarily in order of importance.
Water catchment protection
Our water is one of our most precious resources and the reality is that we can not live without it.
That anyone would be allowed to mine in this area is beyond belief.
Drivages
We do not need more damaging driveages 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.
Modification 2 seeks approval to tunnel underground in the Metropolitan Special Area of the water catchment, a total distance of about 8 kms, extracting coal and rock. It is not a conventional coal mine but is needed for access to the big areas to the West which they hope to mine in the future.
I understand that even though WCL do not yet have permission to mine in the Western area, they would like to do this to use the North West Mains Driveage (NWMD) as future leverage to get approval, as well as a source of income meanwhile. In the newsletter WCL states “Approval of the modification will enable the NWMD to be completed, and during this period Wollongong Coal propose to seek separate approval to mine within the North West and South West Domain utilising the existing Wongawilli pit top infrastructure with a 30-year mine life. “
Another 29 years!!! What about Net Zero Emissions by 2050?

No Clear Estimate Upfront
Neither WCL or DPIE have a clear estimate of how much coal and rock will be extracted. This is not good enough.
Not a fit and proper company
Over the years this company has shown again and again that they are not a fit and proper company to hold a mining licence.
The economics - Risk of insolvency
Wollongong Coal is at risk of bankruptcy. Will this company become a stranded asset?
I am a CCC member of Russell Vale Coal Mine and I am very aware of the dire financial situation of Wollongong Coal Ltd.
We note that the NSW Planning Department itself will make the decision whether to approve this modification of an existing approved project. This project only serves the interests of Wollongong Coal Ltd.
Interesting sections of the DPIE report…
Vol 2 p. 184
“DPIE has previously identified that the financial viability of projects is a risk assumed by the project owners. Wollongong Coal is willing to incur a financial loss associated with MOD2 to facilitate access to the North West Domain and ensure continuity of mining operations.” This surely is a major problem.
As MOD2 is the first stage of a larger project it is recognised that subsequent stages would require a separate approval and that there is uncertainty around obtaining it. This is WCL ultimate goal and by the time 2026 rolls around, the world will not be wanting coal and hopefully Australia will have a climate change plan/policy.

Incomplete economic assessment
This project should be assessed as part of a larger proposal to mine the North-West and South-West domains.
Greenhouse gas emissions - Climate change
Greenhouse gas emissions are underestimated, and we just do not need more coal extraction and combustion contributing to climate change!
We need to be cutting greenhouse gas emissions as soon as possible i.e., urgently.
People with more expertise will, I am sure, have explained the need and urgency for this. Net zero emissions cannot be achieved by approving more coal mining whether it be modifications, expansions or heaven forbid, new coal mines.
Offset and Renewable Energy Purchasing Power Agreement
Despite NSW commitment to reduce GHG emissions by 35% by 2030, there is no plan to offset or even a plan to use a renewable energy Purchasing Power Agreement.
To achieve this commitment, we (and all fossil fuel industries) need to start now
While it is not Australian policy to consider Scope 3 emissions when exporting coal, we need to realise that wherever the coal is burned the impacts on climate change will be global, including Australia. There have been extreme temperatures, extreme weather, bleaching of the Great Barrier Reef, catastrophic bush fires and the Scientific world telling us we must act now as we don’t have a lot of time left to change.

Potential for cracking and damage
There is potential for cracking of Lake Avon reservoir floor; groundwater depressurisation; mine inflows; greenhouse gas emissions and more.
These are all things that should be considered and are enough reason to not allow mining to go ahead in our water catchment area.
As some of the tunnelling is only 60m below the reservoir floor and WCL acknowledge that there will be cracking caused by the tunnelling!
Vol 2 p. 140 “Dam Safety NSW prohibit mining below stored waters at a depth of less than 60 m. Given that the proposed NW mains below the base of Avon Reservoir are close to this minimum, the modification will be referred to the Dams Safety NSW by DPIE for consideration. “
Has there been any reports or information from Dam Safety NSW or Water NSW? Has this been made public before submissions are requested from the community? How can the public comment effectively if they have not been properly informed?
Loss of water
Externalities are not costed such as loss of water through mine inflows.
According to the Groundwater Impact Assessment (SLR Consulting Australia Pty Ltd, 2020, more than 7 million litres of polluted mine water per day will be pumped out at Licensed Discharge Point 2 (LDP2) and ultimately into Lake Illawarra.
There is no plan for a water treatment plant, just settlement ponds. Isn’t it time the EPA improved the requirements for mine water discharges?
Even though there will be voids and cracking created by the tunnelling, no significant impacts to surface water are predicted. There is one large upland swamp near the Ventilation shaft but again WLC predict no impacts. Swamps are so important to our water catchment areas and should never be put at risk like this.
Risk to Groundwater
During mining, groundwater will be pumped from the active mining areas to maintain dry working conditions. Consequently, the Permian sandstone units overlying the mined seams will become depressurised, lowering the potentiometric head within the Permian sequence to below the Bulli Seam. Above the workings where coal is extracted, cracking will be induced due to subsidence effects caused by the mining void. Similarly, cracking is likely in strata above historic bord and pillar mining where secondary extraction has occurred. The cracking is expected to extend into the Scarborough Sandstone enhancing vertical leakage into the workings.
Discharge of polluted water
Discharge of polluted water into Robins Creek which flows into Lake Illawarra will also be happening. This is another situation that should not be allowed.
Damaging Drivages
We do not need more damaging driveages 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.
WCL are applying for time (5 years) to build the driveage necessary to start underground mining in the Western area. Driveage means 4 roadways, (underground tunnels with interconnects) each 5.5m wide and 3.6m high.
WCL claim this new part of the driveage, which goes under the Avon Reservoir, meets the legal requirements that “The development as modified must be substantially the same development as the development authorised by the consent “
The driveage will now go under Lake Avon plus Gallahers Creek and another watercourse.
All the driveage mining will be “first workings” and therefore WCL claim there will be no subsidence, no negative impacts on the environment or water. I do not believe this to be the case.
WCL have made a commitment that there will be no longwall mining in the catchment in the future. What happens if Wollongong Coal is sold?
While I acknowledge that there are people who consider profits to be the most important consideration, I and many others do not agree. We live on the driest inhabited continent in the world and we must do everything to preserve our water.
Although coal has been very important in the past, it has now become much less important as there are alternatives. Mining in a water catchment does not make any sense!
Please reject this modification which would also allow further mining in the future.
Cherrida Hardaker
[email protected]
0408674305

I oppose this project for the following reasons-
Incomplete economic assessment - this project should be assessed as part of a larger proposal to mine the North-West and South-West domains.
Externalities are not costed such as loss of water, through mine inflows, and discharge of polluted water into Robins Creek, which flows into Lake Illawarra. Risk of Insolvency - Wollongong Coal is at risk of bankruptcy.
Greenhouse gas emissions are underestimated by using a low carbon price and proportioning the cost to NSW as a fraction of global population.
Noise dust and traffic impacts on residents.

Reasons for objecting include:
• Incomplete economic assessment - this project should be assessed as part of a larger proposal to mine the North-West and South-West domains.
• Externalities are not costed such as loss of water through mine inflows and discharge of polluted water into Robins Creek which flows into Lake Illawarra.
• Risk of insolvency - Wollongong Coal is at risk of bankruptcy.
• Greenhouse gas emissions are underestimated by using a low carbon price and proportioning the cost to NSW as a fraction of global population.

Please find attached letter.

I object to this project primarily because it is in the Sydney water catchment Metropolitan Special Area, close to the Avon Reservoir.
The documents are incomplete as they do not state the amount of coal to be extracted, so how can the project be assessed?
Any further mining in the Special Areas should be halted until more is known about the cumulative effects of mining over 100 years.

1. I note that the proposal comprises only development headings. This seems to be as a preliminary to future longwall mining of coal to the NW and SW of the lease area. If this is the intention then it should be considered at the same time as this proposal.
2. There is an ongoing risk that water losses may occur, due to intersections of roadways with faults or dykes connecting to the surface.
3. Wollongong Coal has demonstrated over many years many non-compliances with regulations. It remains of questionable financial viability.
The project should be rejected.
Yours sincerely
Peter Lamb

Oatley Flora and Fauna Conservation Society Inc.
Objection to Wollongong Coal (WCL), Wongawilli Colliery, Modification 2 Proposal
Impacts on water
The North West Mains Driveage (NWMD) is proposed to be excavated under the Gallahers Creek arm of Lake Avon reservoir. This reservoir is a vital part of Sydney and the Illawarra’s drinking water supply.
Some of the tunnelling is only 60m below the reservoir floor and WCL acknowledge that there will be cracking caused by the tunnelling.
The Groundwater Impact Assessment (SLR Consulting Australia Pty Ltd, 2020) found that there would be mine inflows, for both the approved and proposed NWMD, of up to 37ML/yr.
A maximum discharge rate to Licensed Discharge Point (LDP) 2 of 7,226 kL/day may be required which is below the current discharge limit of 10,000 kL/day.
However, this still means that more than 7 million litres of polluted mine water per day will be pumped out at LDP 2 and ultimately make its way to Lake Illawarra.
There is no plan for a water treatment plant, just settlement ponds. It is time the EPA improved the requirements for mine water discharges.
Greenhouse gases and Climate change impacts
Annual scope 1 and 2 GHG emissions generated by the Colliery represent approximately 0.291% of total GHG emissions for NSW and 0.071% of total GHG emissions for Australia, based on the National Greenhouse Gas Inventory for 2018. “
“The Air Quality and Greenhouse Gas Assessment (EMM, 2020) identified average annual Scope 1 and Scope 2 emissions of 361,297 t Co2-e and 22,029 t Co2-e, respectively. “
These amounts may be regarded by Wollongong Coal as minimal however we believe they are still significant.
There is no plan to offset these emissions and there is no plan to use a renewable energy Purchasing Power Agreement. This is despite the NSW commitment to reduce GHG emissions by 35% by 2030. We must implement these strategies now.
Further mining expected in future
WCL’s stated intention is as follows “Approval of the modification will enable the NWMD to be completed, and during this period Wollongong Coal propose to seek separate approval to mine within the North West and South West Domain utilising the existing Wongawilli pit top infrastructure with a 30 year mine life.“
In effect this application is the ‘thin end of the wedge’. If we are to take effective action on reducing global Greenhouse Gas emissions it must start now.
Summary
We recommend the application be rejected or at least any approval that might be granted be conditioned to ameliorate the above impacts on water supplies and the environment.

This proposal will further entrench our region, state, country and world as one that relies upon coal. This is not the way we must be moving if we are to mitigate the worst effects of climate change.
The proponent argues that the NSW population is approximately one thousandth of the global population, and so the climate change effects felt by NSW residents are going to be one thousandth of that felt by the global population. This may be the case, but that does not absolve Wollongong Coal of the other 99.9% of responsibility for their emissions.
If this kind of argument were standard, the vast majority of global emissions would be unaccounted for in project proposals. This argument also relies upon borders that are completely arbitrary and have nothing to do with the proposal. The IPC has been given 100% authority to reject or approve this mine, and is required to consider all downstream emissions. The IPC ought to consider 100% of emissions from this mine expansion, not 0.1%.

Please reject this proposal,
Dylan Green BSc, BMath

Please find attached some comments on the Wongawilli Mod-2 proposal PA-09_0161. The proposal should be rejected.
Regards, Peter.
Dr Peter Turner
Mining Projects Science Officer
National Parks Association of NSW

I object to the proposed project for the following reasons.

significant ground water loss from 2.4m high tunnels only 60m below main reservoir floor. The high risk of cracking causing water loss and structural damage to the dam is unacceptable.

Incomplete economic assessment - this project should be assessed as part of a larger proposal to mine the North-West and South-West domains.

Externalities are not costed such as loss of water through mine inflows and discharge of polluted water into Robins Creek which flows into Lake Illawarra.

Risk of insolvency - Wollongong Coal is at risk of bankruptcy.
Greenhouse gas emissions are underestimated by using a low carbon price and proportioning the cost to NSW as a fraction of global population.

Sutherland Shire Environment Centre has long been concerned about the impacts of mining in the Special Areas of the Illawarra water catchment. The southern boundary of the Sutherland Shire adjoins the Royal National Park and the water catchment areas with many residents living in electorates that either border or include the Illawarra Special areas.
Peabody’s plan to expand longwall mining under the Woronora reservoir was regarded with disgust by Shire residents. Sutherland Shire Environment Centre collected 10,700 signatures on a petition objecting to Peabody’s expansion which was presented in NSW parliament last year but the State government approved the project regardless. Part of the justification was the provision of jobs so it is interesting to note that operations in this mine have been halted as of January 4 for a period of 4 months and workers forced to use paid leave due to mining being economically unviable.
The current proposal by Wollongong Coal (WCL) to build an underground roadway is preparation for future extraction of coal from the North-West and South-West domains, which has yet to be approved. Therefore the economic assessment is incomplete and the proposal should be rejected on these grounds.
Sutherland Shire Environment Centre raises several other objections to the proposal:

It poses an unacceptable risk to water security.
We do not accept that the driveage under Lake Avon and Gallehers Creek is covered by consent given in 2011.
No costing has been provided for water loss through mine inflows and discharge of polluted water into Lake Illawarra via Robins Creek.

It will exacerbate climate change.
The NSW government has committed to a 35% reduction in Greenhouse Gas Emissions (GHG) by 2030. GHG have been woefully underestimated in the proposal by use of a low carbon price and proportioning the cost to NSW as a fraction of global population.

There is no plan to offset or use a renewable energy Power Purchase Agreement.
Greenhouse gas emissions are underestimated by using a low carbon price and proportioning the cost to NSW as a fraction of global population.
After the 2019/2020 bushfire season, the need to address climate change has never been clearer. The current policy in Australia allows Scope 3 emissions from exported coal to be ignored but to do so is not rational given the damage to environment, lives and economy caused by accelerating climate change.

The Sutherland Shire Environment Centre strongly believes that protection of water and climate should be prioritised over the mining of coal. The coal industry is in terminal decline and projects, such as this one bring an added risk of bankruptcy, leaving a legacy of environmental damage and unemployed workers. We urge the government to reject this proposal and implement policies that retrain workers for a future in renewable energy.

Sincerely,

Tassia Kolesnikow
Chair, Sutherland Shire Environment Centre

I find the proposal concerning and not acceptable across the global and local concerns. The steps to avoid and reduce global warming need to begin now. The specific issues outline including economic, risks of insolvency and potential impacts on fracturing with concerns for the Avon catchment and Sydney’s water supply together with ground water release in to Lake Illawarra do not warrant acceptance. I would therefore ask that is be rejected.

Wollongong Coal must not be allowed to carryout any mining work between Wongawili and Russell Vale either under or near water catchment areas on the escarpment.
This company is constantly teetering on the brink of insolvency and only survives on annual handouts from their owner, Jindal Steel in India. WC has a history of not carrying out remedial enviromental and maintenance work on both the Wongawili and Russell Vale sites which has been a requirement from previous approvals.This company's treatment of their contract workforce in the past has been abominable resulting in the liquidation of companies because WC has failed to pay their bills. I ask that this company should not be allowed any further approvals for work in the escarpment.

See attached document

Please see attachment

Please find attached a brief document describing our objection to this development.