MOD 8 - Water Transfer to Western Coal Services

To The Office of Planning,
Re: MOD 8 – Water transfer to Western Coal Services

I am very concerned about the modification proposals by Centennial Coal to pump water from its Angus Place and wish to object to these.

Although I appreciate that the company will wish to ensure that its Angus Place mine, currently in care and maintenance status, is safe for potential though not yet approved future operations, namely the Angus Place West extension, their request for increased outflow to the Springvale Water Treatment Plant has significant consequences. Their current modification proposals (MOD 8 and MOD 5) have the potential to lower the water table significantly, possibly up to 30 metres.

This would then have flow-on effects with water drawn down nearby streams and swamps downstream and close to the mine workings.

Critically endangered ecological communities depend on the integrity of these water sources. There is concern about the Peat Swamps on Sandstone (THPSS) and water dependent faunal and floral species. The mine area contains the EPBC listed endangered ecological community of Temperate Highland Peat Swamps on Sandstone (THPSS). These swamps are associated with a triassic sandstone plateau and are dependent on a regular supply of surface or seepage water (Whinam & Chilcott 2002 cited in SPRAT: THPSS) They act as water filters and release water slowly to downstream watercourses (Young & Young 1988 cited in SPRAT: THPSS).

The integrity of THPSS communities will be challenged if their hydrology is changed, as they are highly susceptible to changes in water flow, water table level and structural damage. Such changes can come about through activities within or below the swamps themselves, or in their catchment areas. Obvious threats from mining are water extraction from aquifers or surface water, water leakage, land surface subsidence, bedrock fracture, road construction and drainage works (SPRAT: THPSS).
The particular swamps at risk on this occasion are the Cox’s River Swamp, Long Swamp, Kangaroo Creek Swamp and Lambs Creek Swamp (LEG 2022).

Various species found within the proposed extension site are classified as endangered or vulnerable under the federal Environmental Protection and Biodiversity Conservation Act 1999 (EPBC) and/or the NSW Biodiversity Conservation Act 2016 (BCA). They include:
• the endangered Giant Dragonfly (Petalura gigantea),
fauna listed as vulnerable:
• Greater Glider (Petaurus volans), Large-eared Pied Bat (Chalinolobus dwyeri), Giant Burrowing Frog (Heleioporus australiacus), Gang-gang Cockatoo (Callocephalon fimbriatum), Little Eagle (Hieraaetus morphnoides), Brown Treecreeper (eastern subspecies), Varied Sittella (Daphoenositta chrysoptera), Scarlet Robin (Petroica boodang), Flame Robin (Petroica phoenicea), Diamond Firetail (Stagonopleura guttata), and
flora listed as vulnerable:
• Eucalyptus aggregata, Eucalyptus cannonii, Pultenaea glabra, Veronica blakelyi, Velleia perfoliata, Xerochrysum palustre, Kunzea cambagei.
The Lithgow Environment Group (2022) commented that it had never encountered such a large number of threatened species and communities within a single mine proposal: 10 EPBC listed and 17 NSW BCA listed.
There are also two listed migratory species:
• Rainbow Bee-eater (Merops ornatus), Latham's Snipe (Gallinago hardwickii).

The water to be pumped from the Angus Place mine would not of course be pure and this represents another hazard – not only to plants with which the expelled surface water comes into contact. This water will also move into creeks that are part of the Cox’s River catchment, and that catchment forms part of Sydney’s water supply, a point acknowledged by the project’s proponent.
Some components of concern in the water that will be removed are heavy metals. Some of these are quite toxic to living organisms. Evidence of toxic metals is still quite obvious in creeks along Long Swamp after Centennial Coal’s previous mishap twenty years ago (personal observation 2023). Hence the question - what independent monitoring might be done of the metal concentrations – will those concentrations be anywhere near those anticipated in section 7.1.3 of their current advertised Impact Assessment, or might they conform to their previous invidious track record as described below?

In 2006 the Department of Planning acknowledged the Angus Place Coal Project as presenting a potential risk to some peat swamps on sandstone on the Newnes Plateau through subsidence arising from coal extraction and required Centennial Coal to develop a Newnes Plateau Shrub Swamp Management Plan that would detail “a strategy for monitoring any impacts of mining on the swamps, as well as a management plan to investigate, notify and mitigate any identified impacts” in addition to carefully monitoring subsidence levels caused by mining operations, conducting regular vegetation and fauna surveys in environmentally sensitive and unaffected control sites, monitoring ground water levels, quantity and quality, and monitoring surface water volumes and quality (Department of Planning 2006). It appears that not all of these requirements have been rigorously met (LEG 2022, Wilderness Australia 2022). In fact numerous sources describe a poor environment record by Centennial Coal in its operations in the area including mining discharge contaminated with heavy metals, swamp damage, coal fines spills into the Wollangambe River and surface cracking in Mugii-Murum-Ban State Conservation Area above the Airly Mine further to the north (Belmer & Wright 2019, Favell 2018, Hannam 2022, LEG 2022, Lock The Gate Alliance 2016, Wilderness Australia 2022)
We should also bear in mind that the federal environment department has determined that the project would have “likely significant impacts on world heritage, national heritage, listed threatened species and communities, migratory species and a water resource” (as cited in Gregory 2022).

It is unfortunate that so little time was allocated for exhibition of this proposal so that it coincided with school holidays and a long weekend. It is concerning too that these proposals for modification have not been incorporated into the greater Angus Place West project with which it is logically connected. It is as if bits are being carved off a whole so as to look insignificant and so not draw close scrutiny. Such an approach should be condemned and the company advised accordingly.

I am thus asking that you reject Centennial Coal’s current application and require that all proposed modifications form part of an entire environmental impact statement.

Carole Stanford
5 Jersey Parade
Mount Victoria
NSW 2786

References
Biodiversity Conservation Act 2016 (NSW) No 63, Current version for 26 August 2022 to date (accessed 25 October 2022), https://legislation.nsw.gov.au/view/html/inforce/current/act-2016-063
Centennial Angus Place Pty Ltd & Springvale Coal Pty Limited 2023, Western Coal Services and Angus Place Colliery: Modification report for modifications MP 06_--21 (MOD 8) and SSD-5579 (MOD 5), 19 September, https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=MP06_0021-MOD-8%2120230925T010612.632%20GMT
Department of Climate Change, Energy, the Environment and Water n.d., Species profile and threats database (SPRAT): Temperate Highland Peat Swamps on Sandstone, http://www.environment.gov.au/cgi-bin/sprat/public/publicshowcommunity.pl?id=32#status
Department of Planning 2006, Major project assessment: Angus Place Coal Project: Director-General's Environmental Assessment Report Section 75l of the Environmental Planning and Assessment Act 1979, August, retrieved 25 October 2022, https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=MP06_0021%2120191015T010440.864%20GMT
Environment Protection and Biodiversity Conservation Act 1999 (Cth) No. 91, compilation date: 28 March 2021, https://www.legislation.gov.au/Details/C2021C00182
Favell, J 2018, ‘Angus Place Mine modification 5 - water management’, 10 June, submission, https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=EXH-1120%2120190517T112957.451%20GMT
Fleming, C, Belmer, N, Reynolds, JK, Robba, L, Davies, PJ & Wright, IA 2022, ‘Legacy contamination of river sediments from four decades of coal mine effluent inhibits ecological recovery of a polluted world heritage area river’, Water, Air, and Soil Pollution, vol. 233, pp. 15-35.
Gregory, X 2022, 'Centennial Coal to require bilateral approval for mine near Lithgow in nationally significant environment', 1 September, ABC News, https://www.abc.net.au/news/2022-09-01/lithgow-coal-mine-state-and-federal-government-assessment/101390440
Lithgow Environment Group Inc. (LEG) 2022,'Re: Angus Place West EPBC Number: 2022/09270', 15 July, https://www.gardensofstone.org.au/files/page/2022-07/LEG%20Submission%20-Angus%20Place%20West%20EPBC%20Referral%20-%2015%20July%202022.pdf
Lock The Gate Alliance 2016, Free-loaders: air and water pollution from NSW coalmines, March, https://d3n8a8pro7vhmx.cloudfront.net/lockthegate/pages/2754/attachments/original/1458616247/LTG_Load_Based_Licensing_Report.pdf?1458616247
NSW Planning Portal 2022, 'Angus Place West', retrieved 24 October 2022, https://pp.planningportal.nsw.gov.au/major-projects/projects/angus-place-west
The Gardens of Stone n.d., 'More nationally endangered swamps at risk', retrieved 16 October 2022, https://www.gardensofstone.org.au/more-nationally-endangered-swamps-risk
Wilderness Australia 2022, 'Angus Place West (EPBC Ref# 2022/09270) should be a Controlled Action', 22 July, https://www.gardensofstone.org.au/files/page/2022-07/Wilderness%20Aust%20submission%20EPBC%20Angus%20Place%20West%20Referral.pdf

The planned changed will ensure the miners can work safely and job security keeping the coal flowing. This isn't just about the workers either - its keeping our community employed and our energy supply sustainable. These Mods are not going to stick around forever; its just temporary, and the water being released to the environment wont mack much of an impact, if at all.