Mod 4

I am opposed to the modification of this mine because I understand that it will encroach upon the biodiversity area which was allocated to offset this mine 6 years ago.

it is not acceptable to keep moving offset areas once they have been determined.

It should not be allowed to use an area that is already protected by a national park as an offset area.

I also oppose this modification on the grounds that Coal mines are contributing to detrimental effects of climate change and we should be ceasing all mining of coal in Australia.

Sincerely,

Charlotte McCabe

I object to the Integra Mine Complex Modification 4 because:

Biodiversity Offsets is being poorly managed in NSW and this is another example of a rushed and hasty modification.

The new Biodiversity offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest .


The Integra Mine Complex has ceased operation and gone into care and maintenance .

John George Kaye

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I object to Integra Mine Complex 4 for the following reasons:
1. The new offset areas will not protect the endangered narrow leafed ironbark spotted gum grey box open forest and
2. because the Integra Mine Complex has ceased operation and gone into care and maintenance.

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I am writing to object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest; and
* The Integra Mine Complex has ceased operation and gone into care and maintenance.

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

Hunter Environment Lobby Inc (HEL) objects to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

HEL will make a full submission at the time of the PAC considerations.

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

The Lithgow Environment Group Inc. totally opposes this proposal to modify the Biodiversity Offset Strategy approved for the Integra Mine in 2008.

The very intention of Biodiversity Offsets is that they must provide Long Term Security for like-for-like vegetation communities, and in particular Endangered Ecological Communities (EEC's), that are set aside to compensate for the destruction of these vegetation communities and EEC's.

Yet just 6 years later Integra are proposing to destroy a significant proportion of these Offsets, replacing them with Offsets which are not like-for-like.

Furthermore, because the Integra Mine Complex has ceased operation and has gone into care-and-maintenance, it is unlikely the company is meeting its current management and rehabilitation obligations under the existing 2008 Biodiversity Offset Strategy.

These existing Bioversity Offsets were set aside to provide threatened species credits and credits for the EEC of Narrow ‐ leaved Ironbark ‐ Spotted Gum ‐ Forest Red Gum Forest. The NSW Scientific Committee Final determination for this EEC\ states 13. "Central Hunter Ironbark - Spotted Gum - Grey Box Forest in the NSW North Coast and Sydney Basin Bioregions is eligible to be listed as an Endangered Ecological Community as, in the opinion of the Scientific Committee, it is facing a very high risk of extinction in New South Wales in the near future, as determined in accordance with the following criteria as prescribed by the Threatened Species Conservation Regulation 2002".

The NSW Scientific Committee demonstrated that this EEC is highly fragmented with around 1000 small remnants less than 10 ha in size, heavily impacted by intensive livestock grazing and weed invasion, and that "Continual clearing related to open-cut coal mining and rural sub-division pose threats to this community."

The NSW Scientific Committee identified that Central Hunter Ironbark-Spotted Gum-Grey Box Forest is known to contain an Endangered Population of Cymbidium canaliculatum, the Vulnerable species Diuris tricolor and Eucalyptus glaucina, the Endangered species Lepidium hyssopifolium and the Critically Endangered species Persoonia pauciflora listed under the Threatened Species Conservation Act 1995.

The OEH identified a shortfall in threatened species credits and credits for the Narrow ‐ leaved Ironbark ‐ Spotted Gum ‐ Forest Red Gum Forest for both the current and revised BOS for the Integra Mine, which contains some like ‐for ‐ like vegetation. The OEH recommended that supplementary measures are required to meet current offsetting requirements. The Lithgow Environment Group disagrees with the findings in this EA found that supplementary measures are not warranted.

The Lithgow Environment Group strongly urges the Department to reject this proposal.

Yours faithfully
Chris Jonkers
Vice President
On behalf of Lithgow Environment Group Inc.

I object to the Integra Mine Complex Modification 4 because the new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest. Offsets are little better than slight of hand at the best of times, but this offset barely even pretends to do what it purports.
Furthermore, the Integra Mine Complex has ceased operation and gone into care and maintenance, so this modification should not even be contemplated

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I object to the proposed Modification 4 of the Integra Mining Complex because the new Biodiversity Offset areas will not protect important endangered ecological communities (EEC) that occur on the floor of the Hunter Valley.

The proposal has not identified the cumulative loss of these EECs in the Glennies Creek catchment and Hunter River catchment areas.

The proposal does not provide adequate detail about the vegetation and habitat values in the western and supplementary onsite offset areas that are proposed to be removed from the Offset Strategy

I understand that the Integra Mine Complex has ceased operation because of economic difficulties. The current approvals allow mining operations to occur until 2035

The Modification 4 proposal has not been adequately justified

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

I object to the Integra Mine Complex Modification 4 because:
* The new offset areas will not protect the endangered Narrow-leaved Ironbark-Spotted Gum-Grey Box Open Forest
* The Integra Mine Complex has ceased operation and gone into care and maintenance

The strategic market signals evident from USA and China on future coal needs are negative, with further industry contraction likely. Large scale finance institutions are abandoning coal extraction in increasing rates for good reason.