MOD 8 - Water Transfer to Western Coal Services

My husband and I are dismayed to read of these two proposed modifications Centennial Coal is applying for. As you are authorised to look at the likely impacts of them, we ask you to read our submission.
We are bushwalkers of over 40 years, and members of the Central West Bushwalking Club. Despite coal mining causing very sad degradation and destruction, because it’s drained swamps and cracked pagodas, The Gardens of Stone and nearby areas have many unique and beautiful places. Bruce led a walk there yesterday, 11/10/23, with 13 others. Bruce especially loves the pagoda country, and thoroughly enjoys showing other people around who otherwise wouldn’t think to go there, or know how to do so safely.
We’ve been told of Centennial’s record of at least 134 licence non-compliances!! And these are spread over many years. It seems that for all time, we’ve lost Narrow Swamp, East Wolgan Swamp and Junction Swamp. And we’ve been there to see for ourselves plenty of permanently cracked, millions of years old pagodas. Centennial’s had plenty of chances to do it right, and we think it is only fair that the highest level of scrutiny and caution be around accepting their proposals as is. A few thoughts:
1. We would like Federal Environment Minister Tanya Plibersek to check if a water trigger would come into play, under the EPBC Act. That way, a really thorough assessment would be made of what surface and groundwater impacts would be caused by these plans.
2. Modifications are supposed to be for minor changes. But here, they’re talking of resuming sending 10ML/day of mine effluent down the Coxs River, and into Sydney’s water supply and World Heritage areas. That is a significant change. The two modification proposals ought to be looked at together with the proposed Angus Place West mine expansion to get the full picture and do a thorough assessment of it all.
3. The mine effluent will have more heavy metals than the natural watercourse has, as Centennial’s paperwork says it wants to treat the unwanted mine water to 350μS/cm. That still means there’d be heavy metals, for example, arsenic and selenium in it (they’ve been found in the water that’s come from this mine area) – no good for macroinvertebrates. Remember, the whole point of Springvale Water Treatment Project (the SSD approved in June 2017) was so that no mine water would go into the Coxs River from Springvale Mine and Angus Place Colliery. If they can’t use that for this water they want to release into the Coxs River, then it seems that another one needs to be built.
4. Another facet is about lowering the water table. It really ‘rings bells’ for us that it’s thought that the proposed pumping is likely to lower the groundwater again. Then, that can cause a knock-on effect of sucking water out of streams and swamps for kilometres away, as mining has caused before to Newnes Plateau streams and swamps.
5. The damage already caused by coal mining in this area is extensive. These two modification requests should be submitted as part of the Angus Place West major project.

I live in Sydney. I find it quite troubling that polluted water from mining operations would be released into the catchment area of Sydney's drinking waters. That on its own deserves far more scrutiny than what Centennial Coal appears to comfortable with, given the changes to the Angus Place operations are being put forward as modifications. Regardless of what these requested modifications may mean for Sydney's water supply, the damage that they would do more immediate ecosystems is something I would not like to see.

I am in full support of the Mods proposed, they will mean safe working conditions along with job security for the locals of the area, meaning the continued viability of the oars in the area creating energy security. it is important to consider environmental impact and the water that will be released will have either a small or completely negligible impact on the environment.

I support this project, as I feel like it will be a good thing to happen and a good idea.

This is an important application. While transitioning to renewable energy solutions is important for our future, and providing intergenerational equity through a sustainable environment is an important aim for our communities, this is a critical modification for a business that has been a key contributor to our local and national economy over many generations.

The proposed Mods will allow for the safe working conditions for the mine workers and also ensure that the coal resource remain viable. The ongoing mining contributes to energy security for the state of NSW and employment for the local community. The water discharged will have minimal or negligible environmental impact.

To whom it may concern,
Please find attached 55 unique submissions all of who made submissions through the Gardens of Stone website. These submitters were encouraged to use the Major Project Planning portal but preferred to use the alternative approach offered by the Gardens of Stone Alliance.
Citizens who had reportable political donations were advised to use the Planning portal.
Submitters were asked if they wanted their name withheld and whether they objected to the proposed modifications.
I trust these submissions are in a suitable form to be accepted as unique submissions. Please carefully note those submissions where a person has selected to keep their name withheld and ensure this translates to the Major Projects Portal when they are made public.
Sincerely,
Keith Muir
for the Gardens of Stone Alliance

This submission is on behalf of the Blue Mountains Conservation Society so that is he name that should be recorded as submitting it, not my name

The Society opposes these two modification as set out in attached submission.

I support this project for the following reasons,
At a local level ongoing stable employment opportunities for the local community are of paramount importance.
At a state (and National level) ongoing stability of power generation is of extremely high importance.

please see attached submission

My concern is that if Angus Place does not proceed, then Mt. Piper Power Station will have to close sooner than planned with the result we will not have power and we will go back to the 1960s and 1970s when we had power cuts almost on a daily basis. If we must reduce coal power then lets do it in a sensible way. Power prices are now getting unaffordable and we are going to be forced to get rid of gas applicances. I have solar panels on my house but the power it generates is only in the day when we least use it.

Please see attached submission submitted by Environmental Justice Australia on behalf of our client Lithgow Environment Group.

As a born and bred local I support the modification as per the proposal submitted to the Department of Planning, Centennial has been a long term employer of hundreds of locals and active supporter of the Community providing funding and support for numerous charities and organisations.

To whom it may concern,

I am a concerned citizen of Sydney and a parent who wants my child to grow up drinking from an uncontaminated water supply. I am also someone keenly aware of the ongoing crisis of species loss and land degradation in this continent and who wants to conserve the last remaining pockets of biodiversity and natural beauty that have survived the ravages of colonial exploitation.
The proposal to establish a toxic tailings dam, after a pitifully – perhaps illegally – short period of public consultation which began over the October long weekend is s clearly meant to railroad the community interest and to serve the profit motive of polluters.
Modification 8 for Angus Place and modification 5 for Western Coal Services are not minor adjustments to an approved project. They would seem to be part of a larger plan to evade the Environmental Planning and Assessment Act and clear the legal path for Centennial to expand its mining operation, by obscuring the extent of impacts from the future Angus Place West Proposal on national heritage in the Gardens of Stone State Conservation Area. They will allow Centennial to by-pass the $120 million reverse osmosis mine water treatment plant and permit the discharge of mine water into the Coxs River catchment. The impacts of these modifications should be assessed in totality with the proposed Angus Place West mine expansion proposal, rather than piecemeal through these modifications. The modifications should be withdrawn and the changes they seek should be included in Centennial’s state significant development application for the Angus Place West mining area so that they can be appropriately assessed.

If Modification 8 is approved, the lowering of the water table and loss of groundwater in the area is likely to transform the local ecology, endangering arboreal and bird species in the area. Mine effluent with high salinity and heavy metal content will likewise damage the fragile wetland ecosystems by poisoning invertebrates at the base of the food web.

Further, the modifications will see more contaminated mine water going into the Wangcol Creek from the Western Coal Services site. This water is likely to be contaminated with toxic chemicals such as arsenic and selenium that have been recorded as present in the mine water of the Springvale-Angus Place mine water system.

To whom it may concern,
Please see the attached submission as an objection
Sincerely
Keith Muir

Please refer to the attached letter from Sue Elliott, Executive, Operations and Projects.

I object to Centennial Coal’s requested Modification 5 to Angus Place Mine’s consent (MP06_0021) and Modification 8 to Western Coal Services consent (SSD-5579)

Angus Place Colliery & Western Coal Services Modifications to 06_0211 9MOD 8) & SSD-5579 (Mod 5)
The Bathurst Community Climate Action Network (BCCAN) is comprised of individuals and organisations from the Bathurst region who want to promote action in response to the Climate Emergency by collaborating with local government and environmental groups across the State to reduce the carbon emissions. Our members have been impressed by the NSW government’s emphasis on transitioning NSW from an electricity system based on fossil fuels to one based on de-centralised renewable energy generation and storage. We note that this policy is attracting large investment in a number of exciting solar, wind and battery projects including in the Bathurst-Lithgow region. We were heartened by the government’s commitment to achieving Net Zero Emissions by 2050 and the early plan to achieve this as outlined in Climate Change Net Zero Plan Stage 1: 2020-2030.
The International Energy Association (IEA) is clear on this point. If the world is to achieve net-zero emissions by 2050, there should be no new investment in oil or gas production or coal mines as from 2021. Our children’s future in the face of the climate emergency is already seriously jeopardised.
In a recent study, Emeritus Professor Ian Lowe calculated the likely carbon emissions from eight NSW gas and coal projects already approved by the IPC since March 2018. We include the link to his study below. In his summary, Prof Ian Lowe report_FINAL_210728 (d3n8a8pro7vhmx.cloudfront.net) he stated
Significant greenhouse gas emissions will result from the projects approved by the New South Wales IPC since March 2018. The impacts are dominated by Scope 3 emissions, which have been consistently ignored by local regulators. The Scope 1 and 2 emissions from these projects, for which local regulators do in principle accept responsibility, add up to some 89 million tonnes of CO2-equivalent over the project lifetimes. In seven of the eight projects approved, there are no measurable emission abatement targets at all, simply bland encouragements to take reasonable steps. (p10)
The proposed modifications before the DPI are designed primarily to ensure the protection of critical underground infrastructure in the Angus Place Mine from flooding which could compromise the future of coal mining opportunities at Angus Place. However, the end of mining here would be a good thing. BCCAN supports the overwhelming consensus of the world’s climate scientists that, if the planet is to avoid catastrophe, thermal coal mining should have no future. The proposed modification is unjustified.
Currently the water from Angus Place is piped to Mt Piper power plant where it is treated before being discharged. The modification proposal would instead send the untreated water directly into the Wangcol Creek, (already highly polluted) & thence into the Cox’s River. While this might be cheaper for the proponent, Lithgow’s economic future, which will rely on clean energy and environmental tourism, will be threatened.
The public interest is best served by giving a clear sign that NSW and Australia are serious about a rapid transition away from coal and into clean energy. These proposed modifications should be subject to a full enquiry through the IPC and, because the proposal has implications for the proposed Angus Place West project, should be referred to the Commonwealth Department of Climate Change, Energy, the Environment and Water and its impact on riverine water quality assessed under the Environmental Protection and Biodiversity Conservation Act.
Margaret Sewell (Secretary) for
Jack Fry, President.

• The proposed Mods will allow for the safe working conditions for the mine workers and also ensure that the coal resource remain viable
• Ongoing mining means energy security and employment for the local community.
• The need to undertake these Mods is temporary
• Water discharged will have minimal or negligible environmental impact

To whom it may concern,

I have lived in the Blue Mountains for 30 years and see the Gardens of Stone to be one of the last vestiges of unspoiled wilderness remaining in the state of NSW and in Australia. It is a place of immense natural beauty, biodiversity, and hydrological importance for Sydney. Both specifically and generally, mining operations have a longstanding history of destroying natural areas, exhibiting carelessness for ecosystems and natural life, disregard and flagrant violation of contractual obligations to protect and restore the land they use. The legal sanctioning of wildlife, nature, and habitat destruction does not absolve us of ethical and moral culpability. Let history know that I strongly object to these proposals.

With respect to my key concerns around the Angus Place Mine Proposal [specifically Angus Place Mine’s consent modification 8 (MP06_0021) and modification 5 to Western Coal Services consent (SSD-5579).]
I am concerned about the risk of further damage to nationally endangered swamp ecosystems which drain water from the streams of the Gardens of Stone State Conservation Area.
I am concerned that the discharge of mine water which can readily contain chemical contaminants and heavy metals risks serious and irreversible damage to native ecosystems as well as pollution into the nearby Cox’s River Catchment area.
I am concerned that the hydrological impacts will further degrade the unique Gardens of Stone area wetlands, as has been seen following the 2018 Angus Place Mine Approval which allowed pumping of water for mine operations, resulting in a drop in groundwater levels and drying out of nearby creeks, Kangaroo Creek, Lambs Creek, as well as Cox’s River.
I am also concerned that there would not even be any substantive or legally binding measures in place to monitor and identify the possible environmental impacts of this proposal – for water contamination, biodiversity loss, groundwater depletion and loss of native plant and animal species. It would truly be a case of ‘what you don’t measure – you don’t know’ – constituting a case of obviously deliberate and wilful ignorance.

I am extremely concerned about the risk of mine runoff and effluent, with heavy metals and chemical contaminants risking Sydney’s drinking water. Mine water will flow into Wangcol creek. Wangcol creek flows into Cox’s river. Cox’s river flows into the Sydney water catchment. The impacts on local watercourses would be terrible, and would not be reversible in any temporally meaningful way. Have we all forgotten or simply chosen to ignore situations like the Queen River in Tasmania? Mining operations are diametrically opposed to the health of river systems, swamps, ecosystems, and world heritage natural areas.
I am concerned the modifications have not been referred for the required Commonwealth assessment under the Environmental Protection and Biodiversity Conservation Act. I am concerned the project will have significant impacts and recommend these modifications be referred to Environment Minister for Commonwealth level assessment and review of the risk to water quality alone through what is referred to as the ‘water trigger’.
Centennial Coal has failed to demonstrate that Modification 8 Angus Place and Modification 5 Western Coal Services do not impact of matters of national environmental significance and the modifications should be controlled actions under the Federal Environmental Protection and Biodiversity Act (EPBC Act).
Centennial Coal has quite literally been found to repeatedly breach relevant legislation in their operations. (2022 breaching development consent for Airly Mine and causing irreversible damage to the Mugii Murum-ban State Conservation Area <https://www.abc.net.au/news/2022-06-21/coal-mine-damages-rock-formations-in-nsw-greater-blue-mountains/101161118>;)(in 2017 being prosecuted for spilling more than two hundred tonnes of coal material into the Wollangambe River. <https://www.abc.net.au/news/2017-07-14/clarence-colliery-fined-one-million-for-blue-mountains-spill/8709834>)
I am doubly concerned that the pertinent environmental protection legislation and reviews are not being applied in this instance around the current mining proposal; and secondly that if approved, the relevant environmental protection legislation wouldn't even be adhered to – as we have quite literally already seen.

In summary, due to the multitude of concerns raised around the tangible, material, and immanent risks posed by mining in the Gardens of Stone, and specifically by these proposals (modification 5 of Angus Place Mine’s consent (MP06_0021) and modification 8 of Western Coal Service’s consent (SSD-5579)) I wish to voice my strong opposition.
Please give serious consideration to this, and other objections to the proposal and know that no money can buy back the Queen River (Tasmania), no money can undo the Lago Agrio Oil Field (Ecuador), and no money can create another Gardens of Stone when we lead this one into ruin.

Sincerely,
Dr Thanjon Michniewicz (B.MED, MPH, FRACGP)

The proposed water transfer to Western Coal Services is a positive project that will help to secure NSW energy supply and support Mount Piper power station and Angus Place mine into the future.
The success of this project also brings significant economic and social benefit to the local community in the form of ongoing employment opportunities.
In addition the proposed project will improve water quality outcomes.
Centennial have continuously demonstrated a commitment to minimising harm to the environment.
Based on this I fully support approval of the project.