MOD 8 - Increase in depth of mining

Please find submission objecting to the project attached

I am not a boffin so am not comfortable analysing all of the reports by Hansen Bailey rationalising the eighth extension of the Boggabri coalmine via Appendices A to U. I am, however, a concerned citizen, concerned about:
1. The dependance of all Australian governments on the extraction of fossil fuels, especially at this time of scientifically acknowledged threats to climate, food and water security, global health and social justice. As well as expanding its footprint to link up with the Maules Creek mine to the north and the Tarrawanga mine to the south, the massive 'modification 8' proposes to go deeper into the earth, extracting 61.6 million tonnes of coal by 2039, an extension to the current operating permit of six years with its concomitant carbon emissions the world is looking to Australia to reduce. We also have a responsibility to recognise the effects on intergenerational equity of this project which has managed to subvert examination by the Independent Planning Commission, the usual process for such a large development.
2. The cavalier disregard of Australia's unique bio-diversity values in the destruction by stealth via Modifation 8 of the Boggabri Coalmine. Leard State Forest is critically Endangered Box-Gum Woodland, a bio-diversity hotspot which is home to 396 species of native plants and animals, 34 threatened species and several Endangered Ecological Communities. The forest was at risk of collapse before this eighth modification, a euphemism for land and water grab. The pusillanimous offer of the inadequate fauna corridor offered as a salve to objectors would be risible if its implications on bio-diversity were not so serious. We all know in our heart of hearts environmental off-sets can never equate to the original habitat which will be destroyed, especially tree hollows which are rapidly depleting Australia wide due to the effects of development and climate change.
3. The reluctance of the business and government sectors to invest in renewable sources of energy and to train their staff in research and development and hands on skills for its implementation indicates cognitive dissonance when presented with the facts of climate change. The Nuremberg Defense will just not cut it .
We know if we search our consciences that the extension of the Boggabri Mine is wrong on so many levels. Please don't compound the damage already done by approving this last ditch and desperate effort on behalf of Idemitsu to wring the last tainted profits from a senescent industry at the expense of global unity and health, not to mention the effects on the local community of deteriorating groundwater quality, impacts to individual bores, reduced air quality, noise due to traffic, including rail traffic and blasting, traffic safety and the cumulative effects of noise and dust.

Whitehaven Coal Submission on Boggabri Modification 8.

I do not believe this project is in the best interests of the area due to ground water impacts and emissions. Alternatives and green energy project projects could supply greater numbers of jobs. This project does not consider impacts on climate and therefore the health and well-being of future generations

Attached submission

I object to Mod 8 as its impacts on local water security, the local environment, human health and its considerable contribution to increasing greenhouse gas emission at a time when the world is quickly decarbonising due increased climate change harms. The adverse impacts of climate change will remain long after the mine has closed due to ghg emissions increasing climate risks. Further the additional harm caused by the Mod 8 to the BC Project will likely impact water beyond the life of the mine and this further make the project unacceptable.
I urge you to not approve this Modification.

MOD 8 should be assessed as a separate project proposal, with IPC review, given the amount of CO2-e emissions projected, the impacts on water drawdown and thus on local farmers who have opposed this and other expansions, and the incompatibility of the total proposed emissions from the mine including MOD 8 with the NSW 2030 reduction commitment in the Electricity Infrastructure Roadmap. MOD 8 would entirely undermine the original Boggabri approval requirement that the mine reduce its emissions over time. Assessment of the acceptability of the proposal must take account of the vast increase in methane emissions projected, given the very high contribution of methane to global warming over a 20 year timeframe, including the danger of breaching earth system tipping points. Given the Hume coal proposal was rejected in large part because of its unacceptable impacts on future generations, it should be inconceivable that this proposed expansion could be approved without destroying the NSW government's credibility in relation to the core intergenerational equity principle of ESD. Three of the 4 major import customers for the mine's coal have committed to very large reductions in emissions by 2030. It would be reckless to expand production, risking a stranded asset, a financial collapse and another hospital pass to the public purse for clean-up. The pattern of mining companies seeking to expand their original approvals without any requirement for the total cumulative impacts to be assessed, and the use of this tactic to avoid full investigation and independent scrutiny, are unacceptable. The proposal should be rejected as it stands. The proponent, Idemitsu, should be required to submit a de novo proposal for full assessment. It is very distressing that this underhand expansion assessment process could be approved in the year that the IPCC has given us such a stark warning of what we face without major decarbonisation, the UN has echoed that warning, and we have witnessed extreme weather events of unprecedented ferocity round the world.

I strongly object to this Boggabri Coal MOD 8 - Increase in depth of mining. 61.6 million additonal tonnes of coal extracted to the depth of the Templemore coal seam & Six more years of impacts to the environment and the surrounding local community, while the cumulative impacts are not considered under a modification.

Attached submission.

See attachment

attached

WE are grateful for the opportunity to provide a submission on this important issue.
Wando’s ongoing concerns are embedded in our understanding of the immediate and catastrophic effects of climate change and the impacts this amended modification has due to its size and nature; its impact on vegetation and groundwater and the deleterious consequences it poses for our region and globally and well into the future.
It is simply untenable to continue to allow mine expansion in a world so changed: we must be looking to carbon sequestration and transition to clean energy societies
The submission in full (attached) deals with 1. The size and nature of the Modification, 2. Issues associated with ground and surface water and 3 Greenhouse Gas Emissions.
Two appendices are included.

Please refer to attachment

Another proposed ‘modification’. The eighth. The practice of mining companies getting approval for a project then applying for extensions that don’t trigger investigation needs to stop. This project has been expanded so significantly it needs to be re-submitted for assessment as a whole.
The new submission will need to show how the proposed ‘modification’ complies with the original approval requirement that the mine reduce its emissions over time.
It will need to show how the surrounding fresh water aquifers have been and will continue to be protected from fugitive leakages.
It will need to show how the neighbouring endangered plant and animal species and communities have been and will continue to be protected from negative impacts relating to the project.
It will need to show how the site will be rehabilitated post mining operation to enhanace the existing plant communities, to be implemented using adequate funds deposited into a trust account before any further ground activity occurs.
It will need to show how noise and air pollution will be controlled so as to not impact on neighbours.
It will need to demonstrate it has the support of the local communities.
The ‘modification’ needs to be assessed on these grounds. At least.

Lock the Gate Alliance objects to this project to extend mining for an additional three years to 2036. This application should be refused consent.

As an opening comment, we note that global heating will not stabilise at any temperature until the world gets to net zero. Approval of this Project - which would add 62.81 Mt CO2-e in lifetime emissions - is not consistent with the goals of the Paris Agreement. The amended project seeks permission to increase Scope 1 and 2 GHGs by ~40% - on average between 2023 and 2036 - compared to existing annual emissions. This is unacceptable.

Please see our written submission for more detail.

At this time of increasing Climate Change where extremes in weather conditions are causing both lost of human and animal life, we can no longer continue to allow the expansion or continuation of Green House Gas producing Coal companies the luxury of approvals.

I object to this modification and consider that the volume of additional coal proposed to be extracted as a result of it is sufficiently large for the modification to be treated as an extension project and new State Significant Development in its own right.
For many years coal mining has altered and degraded the landscape, the social amenity and the water resources of the rural community at Maules Creek. The four large mines operating in the area have changed the area irrevocably and have continued to expand their operations with little thought to its effect on the local community. The modifications and changes have been major and have increased social and environmental impacts in the community which are permanent. I am pleased that we are are able to comment but they should not be seen as modifications but as true expansions. It should be noted that the emissions resulting from this project are very substantial, as deep mining leads to significant levels of fugitive greenhouse gasses such as methane. I am therefore asking the NSW Government to refer this project to the Independent Planning Commission for assessment. It should be clear that the production and release of 359 million tonnes of greenhouse gasses is totally irresponsible in light of our understanding of the implications of climate change on the planet. We need to move to zero emissions as soon as possible.
Christina Smith

The reason for my objection, as an ordinary citizen of NSW, is the increase in greenhouse gas emissions which would occur as a result of approving this modification.
I am concerned that the Modification Report is misleading, suggesting that the greenhouse gas impact (Scope 1 and 2 emissions) of this modification is unimportant: “essentially equivalent to those [emissions] generated from existing operations continuing for a further six years from 2033 to 2039”. Boggabri Coal’s annual report gives the mine’s 2020 greenhouse emission as 174 kilotonnes. Yet the assessment shows that volume increasing to 740kt and 800kt in the coming years. This represents both an increased rate of emission, plus an extension of the time frame in which these emissions will continue.

The Boggabri Coal project should also be rejected because of the impacts on local land and water, but more appropriately it should be referred to the Independent Planning Commission. The problem with assessing these types of project individually is that the Department is not considering the cumulative impact on the environment, which local farmers have drawn attention to.

To continue to approve new coal extraction projects is to ignore their contribution from scope 1 , 2 and 3 emissions to our rapidly worsening climate crisis. It is no longer appropriate to regard coal as a resource rather than a pollutant. Existing coal mines for reasons of expediency may run their courses, but for NSW to reach its targets of net zero by 2050, the time to stop approving new coal projects, even where they are couched as “modifications”, is now.