Mod 4 - Further Longwall Panel Changes

Ulan Continued Operations Project - Modification 4 Longwall Optimisation
Project
Ecological Impact Assessment

While I do not object to the proposed action in theory, as an industry
expert, I object to the action purely on the fact that the current
Ecological Impact Assessment by EcoLogical Australia presents a
grossly inadequate assessment of the likely/potential impacts of the
proposed action on the biodiversity of the locality. The proposed
mitigation measures are not satisfactory in accordance with the
standards required for major projects in NSW (including all former 3A
and current/future SSD projects). Should more adequate impact
assessment and offsetting been proposed for this SSD, I would hve
likely supported this proposal. Undeotunately in its current form I
object, and I explain in detail why.

Eco Logical Australia has overlooked the likely presence of the
following threatened species that are known to Occur in UCML (refer to
Umwelt 2009). ELA has not included any of these known species in the
list of `likely occurring' (a list of 27 species in their report) but
should be at least 34 when including all of the following:

Ninix strenua (Powerful Owl)
Ninox connivens (Barking Owl)
Chalinolobus picatus (Little Pied Bat)
Petaurus norfolfensis (Squirrel Glider)
Dasyurus maculatus (Spotted-tailed Quoll)
Square-tailed Kite (Lophoictinia isura)
Little Eagle (Hieraaetus morphnoides)

The potential for impact upon these species needs to be better
addressed in this report.

Impacts to the following two Endangered plants known to occur in UCML
including within the study area has been overlooked:

Homoranthus darwinioides - this state and commonwealth listed
Endangered plant has been recorded on the UCML coal mine during a
previous impact assessment by an experienced botanist, Roger Lembit in
1996. A population was recorded in the study area and mapped and
discussed in
http://www.ulancoal.com.au/en/about-us/approvals-licenses/EAVol3/Appendix8_B_Sec5-13_Appendices.pdf
Eco Logical Australia have completely ignored this record, instead
they have referred to a distant record made in Ulan in 1955.

Pomaderris queenslandica - the impacts if the proposed subsidence upon
this species have been inadequately assessed. UCML is a known
stronghold for this species and the species occurs extensively above
the proposed underground mining (subsidence areas). Effects of
subsidence on roots (eg root shear) and available habitat is not
adequately studied and largely unknown. A third party expert is
required to assess potential impacts to this species since it was so
overtly ignored by Eco Logical Australia.

The proposed loss of 25.68 ha of woodland habitat is considered to be
a significant impact to all occurring and potentially occurring
threatened woodland birds, particularly the Critically Endangered
Regent Honeyeater and Swift Parrot, and Vulnerable Glossy Black
Cockatoo which are known to forage and ( the Glossy Black Cockatoo)
breed in the area. This impact is further exacerbated by the proposed
surface and subsidence impacts to the Durridgere State Conservation
Area.

The proposed loss of 25.68 ha of woodland habitat is considered to be
a significant impact to Koala. This is further exacerbated by the
proposed impacts to the Durridgere State Conservation Area.

Page 34 states: "Removal of threatened fauna habitat may occur through
the removal of native vegetation as described above. No dams were
identified within the proposed surface infrastructure corridor and
therefore will not be subject to vegetation clearing. Thus, no impact
to Grey Crowned Babbler and Glossy Black Cockatoo habitat within these
areas is predicted." This does not make sense and fails to identify
the actual impacts since neither species is aquatic and relies on
dams. The enhanced loss of stands of Allocasuarina gymnanthera and
Allocasuarina diminuta are certain to occur as a result of this MOD.
These trees are essential feed trees for Glossy Black Cockatoo. This
impact has been ignored by Eco Logical in their report.

The impacts to Koalas has been overlooked and an indecent attempt at
implementing SEPP44 has been undertaken. Koala have been recorded in
Ulan Coal Mine leases and Moolarben Coal Mine in numerous occasions in
the past. In this region, Koalas shelter by day in dense Callitris
endlicheri growth and forages by night in Eucalyptus spp. The primary
feed trees of Kola in the study area are, Eucalyptus punctata (Grey
Gum), Eucalyptus parramattensis (Parramatta Red Gum), Eucalyptus
blakelyi (Blakelys Red Gum) and Eucalyptus dwyeri (Dwyers Red Gum).
Losses of individuals of these species is certain. The exact number
and extent of Kola habitat loss has not been quantified and impact
assessments upon Koala are not satisfactory.

It would be preferrable for UCML to implement an Independent Koala
Plan of Management is produced for Ulan Coal Mine to address imoacts
to Koala under the BC Act and SEPP44.

Tbe likely direct and indirect impacts to EPBC Act listed EEC/CEEC
"White Box - Yellow Box Blakelys Red Gum Grassy woodland" and
threatened fauna/flora species as a result of clearing and subsidence,
including Koala, Regent Honeyeater, Swift Parrot, Homoranthus
darwinioides and Large-eared Pied Bat warrants an EPBC Act Referral
which the author, Eco Logical Australia has ignored in their report.

The impacts associated with clearing of a surface infrastructure
corridor into the Durridgere State Conservation area is unsatisfactory
and inadequately addressed. No adequate offset has been proposed.
Proposed offsets (ie Biodiversity Credit retirement) must be subject
to additionality rules considering the significance of impacts to a
protected State Conservation Area.

Section 4.7 Impact Mitigation Measures provides a distressingly
inadequate and unsatisfactory set of impact mitigation measures. There
is not a single offering of appropriate offset purchase (ie
Biodiversity Offset Credit retirement) as would be typically required
for any SSD project that involves removal or impacts to threatened
species and communities.

The only impact mitigation measures offered in the report by Eco
Logical Australia are restricted to the typical, actions that are
expected for the standard operations of any coal mine in NSW including
the implementation of a Biodiversity Management Plan (BMP), future
promised rehabilitation of surface impacts, planting of trees in rehab
areas, retaining woody debris and allocating a clearance protocol (eg
paying for fauna spotter Ecologists to supervise clearing works). The
outcomes of these compensatory measures are uncertain and likely to
fail in adequately addressing impacts to all the known/likely
occurring threatened species and CEEC therefore these proposed
measures are not satisfactory. The proposed measures soften the
impacts but do not mitigate or offset them.

Section 4.7.2 `Compensatory tree planting' provides an severely
inadequate "offset" to the proposed clearing activities through the
arbitrary offering to `enhance tree plantings within an existing
offset area'. This type of `double dipping' presents a grossly
inadequate attempt at offsetting the proposed direct (clearing) and
indirect (subsidence) impacts from
the proposed activity.

The only adequate offset for this type of impact would be the purchase
and retirement of a substantial volume of ecosystem and species
biodiversity credits to address the likely and potential significant
impacts to all ecosystem and species credit species, including Koala,
Large-eared Pied Bat, Regent Honeyeater and Swift Parrot.

The impacts from on-going subsidence upon Yellow Box - White Box -
Blakelys Red Gum Grassy Woodland EEC/CEEC and the Endangered
Pomaderris queenslandica (Scant Pomaderris) are uncertain and casually
overlooked by Eco Logical Australia. The comments made by this
consultant about lack of `historical impacts' from subsidence upon
this threatened plant and EEC/CEEC are unsubstantiated. The consultant
who prepared this report, Eco Logical Australia has a strong
relationship with UCML. The effects of mine subsidence upon threatened
species is not one of the specialties of this consultant. It is
strongly recommended that an independent third party is called upon to
advise regulatory authorities on the extent and severity of currently
undiagnosed impacts from the proposed works and associated subsidence
upon the Endangered Pomaderris queenslandica and Yellow Box - White
Box - Blakelys Red Gum Grassy Woodland EEC/CEEC.

Observing the precautionary principal in line with the guidelines for
threatened species assessment (http://www.environment.nsw.gov.au/resources/threatenedspecies/tsaguide07393.pdf)
the impacts of the proposed works upon the following species is
inadequately addressed by Eco Logical and remain uncertain. The
proposed impact mitigation measures are grossly inadequate by current
industry standards for major projects and since there is a high degree
of uncertainty regarding the effectiveness and future success of the
proposed impact mitigation measures it must be made clear that
pursuant section 5A of the Environmental Planning and Assessment Act
1979 the impacts/effects of the proposed action on the following
entities should be deemed significant:

* Yellow Box - White Box - Blakelys Red Gum Grassy Woodland
* Pomaderris queenslandica
* Homoranthus darwinioides
* Koala
* Glossy Black Cockatoo
* Powerful Owl
* Regent Honeyeater
* Swift Parrot
* Large-eared Pied Bat (Chalinolobus dwyeri)
* Corben's Long-eared Bat (Nyctophilus corbeni)
* Brown Treecreeper, Grey-crowned Babbler, Scarlet Robin, Flame Robin,
Varied Sittella, Black-chinned Honeyeater, Painted Honeyeater, Dusky
Woodswallow and Speckled Warbler.

Unless more detailed study and offer of more appropriate and realistic
biodiversity offsets are put forward by UCML.

As an expert Ecologist with a strong knowledge of the regions' flora
and fauna, and a sound understanding of current, best practice
biodiversity offset requirements, I reccommend that the proposed
action is not approvrd until the proponent adequately addresses all of
the issues identified above.

Dear Officers

This application should not move forward. The regional cumulative
impact of mining on the Goulburn River has not been assessed. This
research needs to be undertaken as part of any risk assessment and
environmental impact process.

regards
Jenny Brown

Ulan Coal Mine has been operating across the headwaters of the Goulburn
River since the mid-1980s extracting up to 23 million litres per day
of groundwater. This is the major western rising tributary of the
Hunter River.
The cumulative damage to the river is now very evident with two
additional neighbouring mines, Moolarben and Wilpinjong. The Goulburn
River stopped flowing over the summer period despite large storm
events and smaller nearby creeks continuing to flow.
All three mines continue to expand in the absence of an independent
regional water study.
The drawdown of groundwater and interception of surface flows over a
large area of the river catchment has impacted on essential base flows
that sustain the Goulburn River. This water loss has caused it to
become highly dependent on the discharge of treated mine water.
The ongoing drawdown and interception of regional groundwater that
supports base flow in the river and reports to the iconic natural
landscape feature known as The Drip, cannot continue.
1. The underground mine expansion will further threaten regional
groundwater sources to the north of The Drip
2. More base flows to the Goulburn River will be intercepted
3. The cumulative regional impact of mining on the health and
integrity of the Goulburn River has not been assessed
4. Good quality water discharge from Ulan Mine into the Goulburn River
must be regulated under a set of environmental flow rules that mimic
natural flows
5. Do not support mining under the Durridgere State Conservation Area
6. The additional extraction of coal will increase the impacts of
climate change that future generations with suffer greatly under.

I object very strongly to underground mine expansion near the Drip gorge
on the Goulburn River. That this area has not been added to the
Goulburn River National Park as PROMISED by the government is
disgraceful . The Premier will pay the price at the next election. The
river has not run all summer and this is because the mines are taking
23 MILLION LITRES OF WATER A DAY.

I am sure that the money spent on the car park at The Drip was to
mollify the many visitors to The Drip so that mining can go ahead. It
is a very cynical and condescending move. We are not fooled so easily.

I also object to mining under the Durridgere State Conservation Area.
When is this government going to UNDERSTAND that coal mining and the
burning of fossil fuels is contributing to global warming, that there
are many more jobs in renewable energy and that governments in favour
of coal mining will be derided and blamed for climate change in the
future.

Further assessment of the impact to the water supply to the Goulburn
Rive and an undertaking to keep commitments by politicians who are
facing elections very soon, is necessary.

I wish to strongly object to this modification/expansion of the Ulan
underground mine. This is especially because of the threats to water
it would pose.
It would further threaten groundwater sources to the north of The Drip
on the Goulburn River, as well as intercept more base flows to that
river. Ulan mine already extracts up to 23 million litres a day.
No more water risks should be allowed until there is an assessment of
the cumulative regional impacts of mining on the Goulburn River. It is
appalling that this still has not occurred, given that the Ulan,
Moolarben and Wilpinjong mines all keep expanding and are clearly
impacting the River.
An independent regional water study MUST come first.

Because of the continuing drawdown of groundwater and the interruption
of surface flows over the River catchment, the River has become
dependent on the discharge of treated mine water. A sad situation in
itself, but which makes it also imperative that the discharge of good
quality water from the Ulan mine be regulated under environmental laws
that are similar to natural flows.

In addition to these grave water issues, there ought not to be any
mining under the Durridgere State Conservation Area.

And as in any extra coal extraction allowed, you must take
responsibility for the resulting burning, emission of carbon and
increase in global warming. The World Bank says 'leave it in the
ground'; as a grandmother of five, so do I.

I am writing to object to the Ulan Coal MOD 4 proposal.

The extraction and burning of coal is a leading cause of global
warming and climate change. As the devastating consequences of
releasing more greenhouse gasses into Earth's atmosphere are well
understood, I consider it immoral and inexcusable that new coal mines
such as this should be approved and that profits are to be made from
this increased coal extraction.

I live in a low-lying area of Newcastle that is set to be inundated by
rising seas: one of many areas across the world which will become
unliveable in the decades to come - including our neighbouring Pacific
island nations where people are already being forced from their homes
due to rising seas. Will the mining proponent compensate any people or
communities for the damage resulting from their avoidable
contributions to global warming? Will the NSW Department of Planning
and Environment, the PAC and the NSW Minister for Resources full
responsibility for the climate consequences of this a mining approval?
These are not rhetorical questions.

I also object to this mine due to direct local impacts. There should
be no mining underneath the Durridgere State Conservation Area and The
Drip gorge. These is a fragile system and should be protected from
mining and other invasive impacts.

The underground mine expansion will further threaten regional
groundwater sources to the north of the gorge. This is likely to
reduce base base flows to the Goulburn River. There has been no
cumulative regional impact assessment of mining on the health and
integrity of the Goulburn River and any determination prior to an
assessment would be premature.

I object to this proposal and ask that it not be approved.

Yours sincerely,

Su Morley

Ulan Coal Mod 4
I strongly object to Ulan Coal Mod 4 as it will continue relentless
coal mine expansion destroying the Goulburn River and water sources to
The Drip.
Water is our most precious resource.
The drawdown of groundwater and interception of surface flows over a
large area of the river catchment has impacted on essential base flows
that sustain the Goulburn River. This water loss has caused it to
become highly dependent on the discharge of treated mine water.
The ongoing drawdown and interception of regional groundwater that
supports base flow in the river and reports to the iconic natural
landscape feature known as The Drip, cannot continue.
The cumulative damage to the river is now very evident with two
additional neighbouring mines, Moolarben and Wilpinjong. The Goulburn
River stopped flowing over the summer period despite large storm
events and smaller nearby creeks continuing to flow.
All three mines continue to expand in the absence of an independent
regional water study.
Good quality water discharge from Ulan Mine into the Goulburn River
must be regulated under a set of environmental flow rules that mimic
natural flows.
I strongly object to Ulan Coal Mod 4.

The underground mine expansion will further threaten regional groundwater
sources to the north of The Drip. More base flows to the Goulburn
River will be intercepted. The cumulative damage to the river is
evident and not being addressed.
The cumulative regional impact of mining on the health and integrity
of the Goulburn River has not been assessed
Good quality water discharge from Ulan Mine into the Goulburn River
must be regulated under a set of environmental flow rules that mimic
natural flows i.e. water can't just be dumped into the river system
according to their production requirements. it should be in line with
environmental processes.
I do not support mining under the Durridgere State Conservation Area.
And further, the additional extraction of coal will only increase the
impacts of climate change on a world that is getting hotter.

1. The underground mine expansion will further threaten regional
groundwater sources to the north of The Drip
2. More base flows to the Goulburn River will be intercepted
3. The cumulative regional impact of mining on the health and
integrity of the Goulburn River has not been assessed
4. Good quality water discharge from Ulan Mine into the Goulburn River
must be regulated under a set of environmental flow rules that mimic
natural flows
5. Do not support mining under the Durridgere State Conservation Area
6. The additional extraction of coal will increase the impacts of
climate change

I wish to comment on the proposed expansion of coal mining activities in
the Goulburn River catchment,and headwaters.I am requesting an
investigation of the existing situation where the River is not flowing
at its source,and feeder creeks are being made incapable of
contributing by mining activities. Moolarben Creek is a case in
point.Allowing expansion underground will only make the situation more
dire at Ulan. The public is relying on the NSW Government to commit to
the protection of our Rivers and ground water resources.

1. The underground mine expansion will further threaten regional
groundwater sources to the north of The Drip
2. More base flows to the Goulburn River will be intercepted
3. The cumulative regional impact of mining on the health and
integrity of the Goulburn River has not been assessed
4. Good quality water discharge from Ulan Mine into the Goulburn River
must be regulated under a set of environmental flow rules that mimic
natural flows
5. Do not support mining under the Durridgere State Conservation Area
6. The additional extraction of coal will increase the impacts of
climate change

I object to the ulan mine expansion due to loss of water in the Goulburn
River. The water has been depleted for many years since the mine
opened and there needs to be a balance between mining practice and
environmental concerns.

I object to the extension of this mine for the following reasons 1.The
underground mine expansion will further threaten regional groundwater
sources to the north of The Drip gorge
2. More base flows to the Goulburn River will be intercepted
3. The cumulative regional impact of mining on the health and
integrity of the Goulburn River has not been assessed
4. Good quality water discharge from Ulan Mine into the Goulburn River
must be regulated under a set of environmental flow rules that mimic
natural flows
5. Do not support mining under the Durridgere State Conservation Area
6. The additional extraction of coal will increase the impacts of
climate change

Base flows on the Goulburn River have already been compromised. further
disruption to this important waterway is enactable.
We must stop burning coal if we are to avoid catastrophic climate
change.

Submission regarding the Ulan Coal Mine Mod 4 extensions.
I wish to object to the proposed development modifications at the Ulan
Mine.
While Ulan Coal does acknowledge that "the EP&A Regulation states the
aim for conservation of biological diversity and ecological integrity
.... should be a fundamental consideration", this proposal does not
address these issues adequately.
One major concern is the issue of mining under the Durridgere State
Conservation Area, which should be a protected site. The very real
possibility of subsidence and subsequent impact on vegetation should
be sufficient to deny this activity.
Of even greater concern are impacts on water and the river systems in
the area which are similarly unacceptable, with increased threats to
regional groundwater sources to the north of The Drip gorge. Long term
consequences for the Hunter and Macquarie catchments, to which the
Goulburn and Talbragar Rivers are tributaries, have not been
adequately assessed. Interference with base flows and the subsequent
cumulative regional impact of mining on the health and integrity of
the Goulburn River has not been assessed. The cumulative damage to the
Goulburn River is already very evident, especially with two additional
neighbouring mines, Moolarben and Wilpinjong also impacting on water
flows. All three mines continue to expand in the absence of an
independent regional water study. Base flows to the Talbragar River
will also be intercepted, as will a large volume of groundwater from
the NSW Murray-Darling Porous Rock Groundwater Source. This drawdown
on important western groundwater sources is not sustainable.
Ulan Coal Mine has already, over roughly 30 years of mining, impacted
on its regional environment, particularly in respect of water
resources, despite its range of Management Plans. The drawdown of
groundwater and interception of surface flows over a large area of the
river catchments has impacted on essential base flows and this water
loss has resulted in high dependence on the discharge of treated mine
water which itself is not adequately regulated. Our water resources in
an age of climate change should be given the highest protection. Coal
as a source for power is no longer sustainable.
At the very least, this proposal needs a more thorough environmental
assessment.
Yours faithfully,
(Mrs) Jenny Medd.
593 Cargo Rd, Nashdale. NSW 2800.

I am writing to express my strong opposition to the expansion of the Ulan
Coal mine. Overwhelming scientific evidence has linked fossil fuel
burning with climate change, and it is unconscionable to continue to
develop coal fields in light of this.
Furthermore, I am aware of the more immediate environmental impacts:
1. The underground mine expansion will further threaten regional
groundwater sources to the north of The Drip gorge
2. More base flows to the Goulburn River will be intercepted
3. The cumulative regional impact of mining on the health and
integrity of the Goulburn River has not been assessed
I urge you not to support this application.

The underground mine expansion will further threaten regional groundwater
sources to the north of The Drip.
More base flows to the Goulburn River will be intercepted.
The cumulative regional impact of mining on the health and integrity
of the Goulburn River has not been assessed.
Good quality water discharge from Ulan Mine into the Goulburn River
must be regulated under a set of environmental flow rules that mimic
natural flows.
Do not support mining under the Durridgere State Conservation Area.
The additional extraction of coal will increase the impacts of climate
change. The Department of Planning will be held responsible for the
destruction of our environment and ultimately our planet.
Show some integrity and reject this proposal.

It is about time that the impacts mining has on the groundwater of the
lands. There has been ongoing evidence of water losses to many creeks
and rivers throughout NSW and this is continually overlooked by the
state government and particularly the Department of Planning and
Environment. The complete disregard for the resource and shifting of
blame and responsibility by the government is put onto the landowner
by the promotion of plans further restricting water usage regulations
by Water NSW rather than protecting the resource.
Mines should not be allowed to continue this destruction to the
restricted resource and this must be stopped. This mine has already
shown impact but does not accept responsibility and will further
threaten regional groundwater sources to the north of The Drip.
More base flows to the Goulburn River will be intercepted and it has
and will have ongoing cumulative regional impact on the health and
integrity of the Goulburn River which has not been assessed.
As well as impacting directly on aquifers there is the adverse impact
on water quality from discharge from Ulan Mine into the Goulburn River
that may be mildly reduced by a scheme of regulated measures under a
set of environmental flow rules that mimic natural flow as seen with
the Hunter Salinity scheme. This only reduces, not prevents the
increases to stream salinity.
There is no basis to provide any support for mining under the
Durridgere State Conservation Area. All evidence indicates there will
be irreparable damage and the DoPE must accept responsibility for this
and other impacts.
The additional extraction of coal will increase the impacts of climate
change and this also needs to be addressed.
We have too much demand on the environment by the continued promotion
of Coal Extraction which is totally to the benefit of the
Multinational mining companies with a pittance in royalty to the State
to encourage approval.
The DoPE must realise the destruction and have the intelligence and
courage to refuse this expansion rather than continue the charade we
see in order to approve this application.
At some time in the future responsibility for the base destruction
must be accepted and all parties that promote and allow it to continue
must be held accountable to the people of NSW and Australia and pay
for the part that has been taken.

I am opposed to this proposal because
1. The underground mine expansion will further threaten regional
groundwater sources to the
north of The Drip
2. More base flows to the Goulburn River will be intercepted
3. The cumulative regional impact of mining on the health and
integrity of the Goulburn River
has not been assessed
4. Good quality water discharge from Ulan Mine into the Goulburn River
must be regulated
under a set of environmental flow rules that mimic natural flows
5. I do not support mining under the Durridgere State Conservation
Area
6. The additional extraction of coal will increase the impacts of
climate change. As a doctor, I understand that climate change is the
number one threat to public health in the world, and that continued
increases in greenhouse gas emissions threaten lives and livelihoods.

I formerly lived on the Goulburn River, west of Wollar. In 1973-6, when I
lived there, the river was in a pristine state. Since Ulan Coal Mine
has been operating across the headwaters of the Goulburn River, from
the mid-1980s, they have been extracting up to 23 million litres per
day of groundwater, from a major tributary to the Hunter River.
Two additional mines, Moolarben and Wilpinjong, have added to the
cumulative damage to the river. Water loss to the Goulburn River has
caused it to become damagingly dependent on the discharge of treated
mine water. The damage this causes cannot be allowed to continue.
The cumulative regional impact of mining on the health and integrity
of the Goulburn River has not been assessed.
The underground mine expansion will further threaten regional
groundwater sources to the north of The Drip gorge and more base flows
to the Goulburn River will be intercepted. Good quality water
discharge from Ulan Mine into the Goulburn River must be regulated
under a set of environmental flow rules that mimic natural flows.
I do not support mining under the Durridgere State Conservation Area
and I believe, supported by overwhelming evidence, that the additional
extraction of coal will increase the impacts of climate change.
Yours sincerely,
Dr Cassi Plate