MOD 2 - North West Mains Development

I object to the proposal of Wollongong Coal Ldt known as the Wongawilli Mine Modification 2 North West Mains Development (MOD2 proposal).
My overarching objection to the proposal is the inadequacy of impact assessment. I believe that no area of impact—biophysical, social or economic—has been adequately assessed for the following two reasons:
1) MOD2 impacts should be assessed as part of the larger and anticipated proposal to mine the North-West and South-West domains. The subheading for the MOD2 proposal is clear: “Modification 2 proposes [not only] to extend the life of development MP09_0161 [but also to] facilitate the North West Mains Development (NWMD)”. The purpose of the NWMD is to provide long-term (30-year) access to the coal resources within WCL’s western domains, that is, to the Bulli Coal Seam, Wongawilli Coal Seam and Tongarra Coal Seam. The proposed future development of mining in the western domains, yet to be approved, is a much bigger and impactful project than MOD2. Completion of the NW mains (MOD2) is an essential part of the bigger development. Seeking modification to a current approval in order to pursue a much larger future project has all the problems of incremental approval and risks incorrect estimation of impacts, including underestimation of adverse impacts. To my mind, it is opportunistic and deceptive practice. Just as completion of the NW Mains would be the access pathway to the NW and SW domains, achieving approval for MOD2 would take WCL much closer to approval for 30 years of mining in the NW and SW domains.. With unapologetic confidence, it is stated in the Executive Summary of to WCL’s MOD 2 Report 1 that MOD2 seeks “… to enable completion of the NWMD and prevent the sterilisation of a high-quality coal resource within WCL’s mining tenements whilst utilising existing site infrastructure
- 2) All mining impacts, including those of MOD 2, should be considered in the context of the cumulative mining-generated damage and changes to the Sydney/Illawarra water catchment as a whole. Mining in the catchment inevitably causes significant water loss. Water also is lost to old workings. Yet, it is not known what is a safe quantity of loss, that is, a quantity that will not compromise the Greater Sydney drinking water supply. Furthermore, there is growing evidence that coal mining leaves an inevitable legacy of unacceptable water pollution (e.g. Ian Wright, Nakia Belmer, Regional Comparison of Impacts from Seven Australian Coal Mine Wastewater Discharges on Downstream River Sediment Chemistry, Sydney Basin, NSW Australia in American Journal of Water Science and Engineering 2019; 5(2): 37-46 file:///C:/Users/Administ/Documents/My%20Documents/politics/POWA/2019_Ian%20Wright_10.11648.j.ajwse.20190502.11.pdf ). It is all-too relevant to note that there is no available rehabilitative technology that can restore the integrity of creek beds and groundwater containments lost through mining-generated cracking.

MOD2 proposal has been assessed to a large extent as a stand-alone discrete development. Even this level of assessment leaves much to object to. Below are just a few examples:
- It is unclear how much coal is to be extracted in the 5-year period of the proposal. Permission is sought to mine 2 million tonnes per year, yet the economic assessment (Appendix P, p. 9) is based on “an incremental ROM coking coal production of 385,000 tonnes over the MOD2 life”. This discrepancy calls into question not only the economics of the project but its total carbon emissions.
- SRL’s groundwater impact assessment states that there will be mine inflows of up to 37ML/yrly. This is water lost to drinking water reservoirs and to the natural environment at a time of increasing drought and increasing bushfire.
- SRL’s predicted groundwater impacts indicate that more than 7 ML of polluted mine water per day will be pumped out at LDP2 and ultimately into the catchment of Lake Illawarra. This is at a time when the water quality of Lake Illawarra is under pressure from extensive and intensive urban development in its catchment.
- Five-year total of MOD2 Greenhouse Gas Emissions is 32,562,535 tonnesCO2e (scope1,2, & 3). This is an unacceptable assault on the climate given that coal production is a dying industry and the development of the NW Mains could/should prove a stranded asset. More to the point, it is a profligate waste of the nation’s carbon budget. The world is already in a climate crisis and every effort should be made to keep warming at 1.5 degrees centigrade above pre-industrial levels.

My wife and I own a property at 43 Coral Vale Drive, Wongawilli and are due to commence building of our family home imminently. We understand from the development application provided that there will be minor improvements to the conveyor infrastructure at Wongawilli Colliery.

Our concerns relate to noise from the conveyor belt during the day and at night. Our property has been identified as a ‘sensitive receiver’ in the acoustic report provided. Being a semi-rural environment, the ambient background noise is very low which only amplifies the noise of the conveyor belt.

The acoustic report provided states the following:
• “Background monitoring conducted in the EA was not indicative of the typical existing acoustic environment”; and
• “Based on the results table, the predicted noise levels at each assessment location are estimated to reduce by 3-8 dB at most assessment locations, compared to predicted noise levels from approved operations”.

While we are pleased to read that there is a “predicted” reduction in noise to “most assessment locations”, we question:
- the accuracy of this statement if the background monitoring conducted was not indicative of “the typical acoustic environment”; and
- Whether our property is set to benefit in this “predicted” noise reduction?

We also seek that further noise suppression measures are conditioned in any consent approvals to assist in mitigating the noise pollution from the conveyor belt.

Refer attached

Refer attached

See WaterNSW's response in attachement

Please find attached Wollongong City Council's response to the Wongawilli Colliery Modification 2 Request

Please see attached