Mod 5 - Borefield & Coal Processing

Regarding the Boggabri Coal application for Constructing 4 Bores we would like to place a submission against this happening as we are immediate neighbours to the East who rely greatly on underground water for stock and personal use. 90 percent of our water usage is from bores and wells and if we were to loose that capacity our buisness would be become redundant as we are sheep and cattle producers.
As we are the only owner/Occupiers immediately to the east of BBC there has been no communication between farmer and mining company.
What water studies have been completed to protect our supply and our livelihood?
We need guarantees that these bores will not effect the capacity and production of the water supply that already exsists.

I absolutely oppose this proposal. It is outrageous that a coal mine can get approval without its water needs being public and approved. This proposal is not approvable because it will badly degrade the local aquifers and affect flows in the Namoi River.

This coal mine and all its associated works are already causing unacceptable damage to the landscape, the water and the global climate.

Submission : Objection to Idemitsu Resources, Boggabri Coal Mine Project Approval Modification Environmental Assessment ( Mod 5)

I object to this modification, and I implore the Department to refuse the approval of this modification, on the grounds that should it be approved, there will be impacts that could be far reaching for the many surrounding landholders as well as other people who are reliant on underground water in zones 5 & 11 of the Namoi Catchment.
I find the Exhibition period of this assessment (15days) which entails 697 pages of details far too short to allow for any reasonable person to peruse and comprehend, let alone make comment on. The issue of water is far too important and all stakeholders should be granted the curtesy of more time to respond to such issues.
Concerns:
*A requirement under Section 3, condition 38(b) of the Boggabri Coal Project Approval, there has to be a Leard Forest Mine precinct Water Management Strategy. 4 Years on and this document has not been developed. A clear breach and disregard for the approval process. And this is a management strategy regarding WATER, the very commodity that they wish to increase so that their production output can continue.
* It appears that Boggabri Coal already have agreements with the landholders where the test bores have already been sunk. The issue is that when these six `test' bores become production bores this bore field could very well extract a considerable amount of aquifer water that will impact on neighbours and their livelihood. I don't believe that the Cumulative drawdown by all three mines has been considered, only the `local' drawdown effect by this modification, there by the proponent would consider their approved modification would be more likely to pass all necessary regulations and get approval if only assessed on its stand-alone merits and not from a cumulative perspective.
9.2 of Appendix B - "the modelling predictions indicate that bores and well on neighbouring properties will experience groundwater drawdown exceeding the 2m decline thresh hold as a minimal impact consideration in the AIP".
We know that modelling and predicted figures can't always be relied on and minimal or not, even a 2m drawdown can make the difference between a productive bore and a dry bore, and stock and domestic bores will be impacted by this modification.
* Boggabri Coal still needs to increase their aquifer water licences to meet their demand. (Are landholders considered on an equal basis when they wish to increase their aquifer water licences..? I hope so).
* Approval for the mining operation was initially granted back on 22nd August 1989 and then in 2012 there was an increase from 5mt pa to 7mt pa, clearly the modelling for the water allowance was not sufficient for the dust suppression and mining operations. Perhaps this was a drastic oversite, or was it a pathway for a positive outcome for the approval of the project to be granted? Clearly this approval should not have been granted given the shortfall in the water needed to enable this increase in production.
*This company finds this modification (5) exempt from the Water Resource Triggers of the EPBC Act., simply because this modification does not involve the `direct extraction of coal'. Yet this water will ultimately be `extracted' from the underground aquifers and used to wash `coal'. Words out-way the `Gateway' process because this modification does not involve `additional mining activities' - drilling a bore to supply water for the coal industry is outside the components of the SRLUP.
*Boggabri Coal already admits that they are deficit half of the water needed to satisfy their production capacity. If there is insufficient water for their demand, then they should cut their production output back, not expect to extract precious water from the Namoi River and the surrounding underground aquifers and put the entire catchment at risk reducing water for Agriculture and domestic use. Boggabri Coal state in their conclusion (7.3) that the modification will result in Environmental impacts including drawdown of alluvial aquifers and reduce inflows to the Namoi River. Expanding its groundwater monitoring program does nothing if there is NO WATER to monitor.
* Matters of National Environmental Significance (MNES) Protection of water resources from CSG development and large Coal Mining Development. I would site this Modification as a significant issue in respect to MNES, especially when the water of a catchment is at stake and is being used by a mining company to suppress dust (which they create) and wash coal. And for that reason again I would request that the department deny this approval.
* We all know that `Offsets' are a contentious issue and in the past the `like for like' properties that have been purchased by mining companies in this district have not in any way compensated for the displacement of fauna or replaced the flora that has been destroyed. Allowing a mining company to clear even more native vegetation, some of which are listed under the TSC Act & EPBC Act is yet another reason to deny this approval.
* There are also predicted impacts to Aboriginal Heritage Sites. I find this a national disgrace that the department would facilitate any disturbance to a heritage site. Especially when so much Aboriginal heritage in the Leard State Forest has already been destroyed. Simply allowing a predominantly foreign owned company to move such Artefacts is un-Australian.
* I am very amused by the comment in their conclusion that they include themselves as beneficiaries of a secure water supply which will resolve their current water deficit. Obviously they don't consider any hardship or loss of income to anyone else other than themselves if the water they extract leaves all others without sustainable supplies.
All of the above reasons show that this Modification 5 to allow Boggabri Coal the approval to extract even more water than they do presently, from our already over allocated reservoirs of both the Namoi River and our underground aquifers is ultimately going to cause much hardship for those that already rely on these water supplies.
Our dry continent cannot sustain this continual abuse by the extractive industries. Destruction of Critically Endangered forests, and now the pillaging of our precious water that should be shared by all, is being handed over without question. These companies expect that approval will be granted whenever they make changes or increase their production, on the basis of a well worded document handed to the department for Approval.
It is up to you the Government, our elected Ministers to stand up and protect what little we have left of our natural environment, and to do this we need you to protect and secure our water. Inter-generational Equity states that the present generation should ensure that the health, diversity and productivity are maintained or enhanced for the benefit of future generations.
I would ask again that this Modification not be approved in any way, not even by the use of a `Controlled Action'.

Boggabri Mine Modification 5
14th December, 2015

People for the Plains is a group of residents from North West NSW, based around the town of Narrabri who are interested in transparent and factual information in regards to extractive industries in our region. We host a range of events, some of which have attracted over 1,000 people and we maintain a database of over 400 people. We hold regular meetings and events to discuss the issues surrounding CSG and coal mining in our region.
Thankyou for the opportunity to comment on the Boggabri Mine Modification 5.

We urge the Department to reject this modification due to the improper process used in identifying the demand and seeking the application for this water.

True Demand Should have been Identified and Sought in the EA
The true demand for water by the mine should have been identified in the original water demand model. To have to request this modification three years later indicates either a deliberate intention to mislead local water users and environmental protectors, or else shabby workmanship. Both of which are completely unacceptable for a development of this scale, risking resources of this quality.

Development consent for the mine was provided on the assumption that "the proponent shall ensure it has sufficient water for all stages of the project and, if necessary, adjust the scale of mining operations on site, to match its available water supply." In direct contradiction to this condition, the mine has been operating, discovered it requires more water and is seeking a modification. The proper outcome should be that the scale of the operation is reduced in accordance with the amount of water that it has.

It is clear in the 2012 application that the approval to expand to 7mtpa was made without due consideration of the full water needs of the project, and that the proponent has now "identified a number of adjustments and additions to previously approved operations that are required to ensure its efficient continuous operation." This is not an acceptable way to plan for and utilise our highly valuable and finite water resources.

Proper Fulfilment of Consent Conditions
Furthermore we understand that Idemtitsu has not fulfilled condition 38 of its consent, which required that a Water Management Plan be developed within six months of the consent. This Plan was supposed to include a Leard Forest Mining Precinct Water Management Strategy to be developed in conjunction with Whitehaven Coal. The Department of Planning has advised local farmers that this strategy has been deemed inadequate by the Department.

We find it unacceptable to allow the development to continue and to seek further modifications in regards to water, when Idemitsu have blatantly breached their consent in this way.

If the company cannot fulfil its existing commitments to water it should not be offered the ability to seek further changes. We demand that no further approvals be granted until Management Plans to a suitable level of detail, have been provided and signed off on by the Department of Planning.

Idemitsu now claim to need 2,082ML more per year to meet the demand in average conditions and up to an extra 2,600ML in dry conditions. We question if the 2012 application should have been granted in the first place but should now certainly be given due scrutiny on the company's assumptions and demands.

Water is a highly constrained resource in our region, and the mine was assessed and given approval on the basis of the water demand and extraction levels identified in the Environmental Assessment. These guidelines must be upheld and this modification rejected.

Part of the Extraction Process
Idemitsu claims this modification is exempt from the water trigger, because the Guidelines for the trigger exempt activities for mines that are "not part of the extraction process."

Clearly the water that Idemitsu is demanding is to assist in their extraction of coal, they are in no other business. The modification will provide significant additional impact on water and therefore is not exempt from the water trigger and must be referred for EPBC consideration.

Impact on other Water Users
We understand that the company does not presently have sufficient aquifer water access licences to meet the additional 2,600ML per year they now say they need to run the mine.

Our members feel concerned about the impact that the acquisition of these licences and the extraction of this water will have on the productive agricultural industry that also seeks to operate (and "co-exist") in the vicinity of the mine. A borefield of 6 new bores and the extraction of an extra 2,082ML p.a. will have drawdown impacts on the existing water users in this zone, the impacts of which have not been appropriately modelled nor discussed with local water users.

If the current trajectory of planning-approval-development continues as we have seen thus far, we have no faith that the mine will not continue to suddenly identify a demand for, acquire more licences, put down more bores and/or pumps and use more and more water without the full and cumulative impact being properly identified, appropriately compensated for and adequately conserved.

We hold grave fears for a finite water source that is supposed to be shared across industries and communities, when full and proper process is not carried out by some of the parties.

We urge the Department of Planning and DPI Water to adopt a precautionary approach and refuse consent for this modification and conduct a thorough audit of Idemitsu (and Whitehaven's) existing use of and impact on water in the Maules Creek area.

Regards

Sally Hunter BBUS
President, P4P

The opportunity cost of MOD 5 is a significant loss of groundwater irrigation capacity for Zone 4 irrigators.
The MOD 5 study area is mainly within Zone 4 yet well outside the mine disturbance area; there is a slight overlapp with the existing project boundary (see Figures 6.2 and 6.3).
Boggabri Coal has been progressively purchasing groundwater WAL's in Zone 4 over a number of years; 2015 purchases have not been listed in the Modification Request - there have been at least 2. This has led to some distortion in the Zone 4 groundwater market.
The mine site is not in Zone 4.
Groundwater is being extracted from Zone 4 and effectively piped and used 'out of Zone' resulting in a net potential recharge deficit for Zone 4.
There is no reference to fate of WALs at end of life of mine; these should be offered for resale back to irrigators.
Productive industry = efficient water use; extractive industry = inefficient water use.

This proposed Modification to PA 09_0182 is grossly objectionable. This application becomes a self-evident fact that the original project approval was inappropriate. The impact of the Boggabri Mine on the water resources and land use of the area was required to be assessed. That assessment was obviously manifestly inadequate, presumably because the volume of water required to mine 7 Mtpa of coal was understated.
This proposed borefield EA states that 9.5 ML/day is required; the minutes of the Community Consultative Committee meeting 19 Nov 2015 record a Hamish Russell answering a query that 4 - 8 megalitres a day is needed if there is no rainfall.
Boggabri coal mine borefield EA records a need for another 2,082ML per year to meet their demand in average climatic conditions. In dry conditions, they'll allegedly need up to 2,600ML.
But the water modelling used originally was apparently wildly inaccurate using inaccurate data and the accounting for the climatic conditions of NorthWest NSW in to our uncertain future of global warming remains in doubt.
Boggabri Coal do not currently have aquifer licences to meet their demand. They say they are in the process of obtaining them. Currently, they have only 848ML of aquifer licences, at full availability.
This modification cannot properly be approved.

Hi Matt,

I refer to your email below seeking comments on and any recommended conditions of approval for the Boggabri Coal Project - Modification 5 (09_0182 MOD 5) (Narrabri Shire LGA).

The EPA has reviewed the EA for the above modification project. The EPA considers that the current EPL (no. 12407) adequately addresses the predicted impacts regulated by the EPA.

The EPA recommends that should the Modification be approved, that the proponent apply to the EPA to varying condition A2 of the EPL to updating the Project Boundary of the premises.

If you wish to discuss this further, please contact myself on 0459 077 360 or Mr Kharl Turnbull in our Armidale office on 6773 7000.

regards,

Rebecca Scrivener
A/Head Regional Operations Unit - Armidale
North Branch, NSW Environment Protection Authority

See attached.

See attached.

Please see attached PDF file

Our submision is attached.

We oppose this application because we are concerned about the impacts the modification approval will have on the local environment.

See attached.

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