MOD 8 - Water Transfer to Western Coal Services

Dear Sir, Madam or other identifier.

Re: Centennial Coal Angus Place and Western Coal Services Modifications

I have worked extensively in the mining, including hydro-carbons and power generation sectors. I know the Gardens of Stone area well.
I have seen the damaged caused by mining operations. We need minerals but extraction can be done with minimal impact. We do not need more coal. We do not need more damage to this precious region simply to provide more profit to Centennial Coal.
These proposals are effectively for the same economic entity. I shall keep my submission brief. We all have the details.

I object to the modification proposals on the following grounds.

1. Commencing the exhibition over long weekend denies the public the regulated minimum time to comment. This is cheap. You are supposed to be working for everyone in NSW, not just Centennial coal.

2. Water
a. The proposal will diminish significant wetlands. Groundwater pressure/levels are already lower in the region as a result of coal measure extraction. This has had an observable and material detrimental impact. The proposals will make matters worse. They are avoidable.
b. Discharge into the Cox's River catchment of water with high loadings of heavy metal contaminant should be avoided. It is simply an externalisation the company’s real cost of extraction.

3. I note that Angus Place was placed on care and maintenance in 2015. It is not a natural progression of Springvale. The world has changed since the original mining consents were made. Let this lapse in 2024 as originally intended.

4. First Workings: The plan to mine via First Workings purports to minimise surface subsidence. This is not guaranteed. Moreover there is no guarantee that a subsequent amendment request for Second Workings does not follow.

5. Piecemeal Approval Requests.
a. The proposal appears to be an attempt to circumvent the correct approval process for the bigger picture expansion/recovery of Angus Place coal measures by attempting to have material changes assessed as modification requests. The proposals should be properly assessed under the Environmental Planning and Assessment Act.
b. The project triggers the requirement for referral under EPBCA and should be assessed under this legislation.

6. Centennial Coal’s track record of environmental damage
a. Centennial has a record of damaging environmental incidents, consent and licence non-compliance. b. It has historically provided inaccurate predictions of environmental impacts from its operations. This suggests that the impact predictions in the environmental assessment for these modifications cannot be relied upon.
c. I have known personally senior members of the company, and whilst good people in other respects I observe and conclude that they prioritise company profit above environmental impact and seek simply to box tick these matters.

Thank you for consideration of these matters. Please do not approve these requests.

Yours faithfully
Richard Horton

I have lived in Katoomba for 37 years and prior to that in Bathurst for 10 years, during which time I have spent much time in the bushland appreciating the rock pagodas and swamps.
I object to the proposed Modifications which will allow pumping out of groundwater from areas 800 & 900. Pumping out at this rate of 10ML/day has already lowered the groundwater more than 20 m. A further loss of groundwater will inevitably cause damage to more swamps.

These swamps are listed under the EPBC Act, therefore this action should be referred for assessment under the EPBC Act as a controlled action.


Centennial’s track record in non compliance with its licences and resulting environmental damage should be considered as a reason to refuse this expansion.

The proposed modification 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 proposal is temporary and the most effective and responsible means of providing for a minimal or negligible impact to the environment. The water delivered by the proposal is a highly valuable resource.

To whom it may concern,
This submission relates to the Angus Place mine’s proposed modifications to allow resumption of discharge of mine water via transfer to western Coal services (Modification 8).
I am familiar with this area from many excursions into the Gardens of Stone area, including the Newnes Plateau, as a bushwalker, and hold it dear. The environment there is a natural wonderland of great beauty. Its numerous rare and endangered species of plants, its ecosystems that are adapted to a local rain shadow effect and its unique geological pagoda formations make its proper care precious and emotionally important to me, personally; however its unrecognized value to the nation is of far greater importance. I believe it has significance for ecological sustainability, probably including within the surrounding area, for cultural value, for its beauty and for the quality of drinking water, all the way to Sydney. For reasons briefly stated below and doubtless for many others as well, I believe all these values could be adversely affected by the discharge of large volumes of water from this mine.
I therefore respectfully wish to submit that the threats to these values, especially those posed to biodiversity preservation and security of good quality water for both human consumption and for support of the environment and its biome justify a call for greater scrutiny of the proposals. I request that the proposal be reviewed by the Federal Government, under the EPBC Act, the Independent Expert Scientific Committee on Coal Seam Gas and Large Coal Mining Development, the NSW Independent Planning Commission and the Independent Expert Advisory Panel on underground mining so that these modification proposals receive thorough review and as much community involvement in decision making as possible. I further submit that the proposal number 8 for Angus Place and modification 5 for Western Coal Services should be considered together, as a significant development proposal. In particular, I suggest that expert advice on likely and possible hydrological effects on the ecology should be given high priority in such a review. Below are some of the reasons why. What may be needed instead is an additional high quality water treatment plant, if the Springdale one is not able to adequately treat the additional water that it is proposed to pump out.
Centennial Coal should withdraw proposed modification 8 Angus Place and proposed modification 5 Western Coal Services. Centennial Coal should at least be required to install a reverse osmosis treatment plant, as it did under Angus Place modification 5, and then pump the brine effluent to Springvale Water Treatment Plant site for processing and appropriate disposal.

I also object to the short time period allowed for public submission and especially the timing of the period to start with the long weekend, which looks designed to distract attention and reduce time for people to study and consider the proposal. This proposal requires careful consideration by all.
I believe that the proposed drainage of water is likely to have dangerous effects on both the catchment of the Sydney water supply, via the Cox’s River, into which I understand Wangcol Creek flows, and on the ecological sustainability of the local biodiversity. These issues should be considered in their greater context.
The context in which the ecological sustainability of the biodiversity should be considered is complex and must include both the effects of changing climate, including the relevance of our position early in a period of El Nino Effect, and the history of degradation of the environment from earlier activity, which this modification would presumably compound.
Climate scientists have predictied a gradually drying of south-eastern Australia. In that context, every plant, animal, fungus and microbe that has adapted to low and irregular rainfall is a resource for resilience of the ecosystem as a whole, for example by colonisation of drying areas. At the same time, every possible reservoir of ground water is vital, both for the near future and for evermore. That makes the Newnes Plateau and all surrounding areas of the Gardens of Stone a vital national resource that commercial interest in cost-saving must not be allowed to undermine. My understanding is that the plateau is a rain shadow area amid what is already a relatively dry area, west of the Great Dividing Range. As such, it supports a number of rare plants with limited distribution. I have been told its swamps are sources of water that is retained during dry spells and slowly trickled into the waterways to support the wilderness downstream. They are also of special significance in their own right. They should be given maximum protection from any possible indirect drainage.

The effects of the proposed modifications should also be considered in the context of the 2018 Angus Place Mine Modification 5 and effects of drainage of surface water traced to depressurisation of the ground water in a coal seam of the Springvale mine, noted by the Lithgow Environment Centre in 2018. I refer you to that centre for more detailed information.
In short, the whole area, including all its mines and all its history of environmental impact must be considered together. Not to do so would not be logically consistent with principles of science or with government responsibility.

The proposed modifications are extremely alarming to me, in view of a history of similar discharge of water from the identified areas having caused very significant falls in ground water ( 21-30 metres in 2018, according to the Centennial Coal, Coxs River Swamp Review, of July 2018, P. 44). This drop in groundwater was observed to quickly dry out Kangaroo and Lambs Creeks and associated swamps, as well as the Coxs River and swamps, according to local environmentalists. Other mining activities in this area have already cost Australia dearly in the loss, in 2011 of three very rare temperate highland peat swamps, Narrow Swamp, East Wolgan Swamp and Junction Swamp. These swamps are believed to be permanently lost and were vitally important ecologically.

I tseems to me that the effect on Sydney’s water catchment would likely be to introduce more toxins, including possibly heavy metals into already polluted water that would then flow into the Wangcol Creek and Cox’s River. Adding mine water to a highly polluted element of the Wangcol Creek catchment is also likely to flush out more heavy metals from that contaminated site. These contaminated discharges would then enter the Coxs River, a key part of Sydney's water catchment that flows through the Greater Blue Mountains World Heritage Area. This is a serious matter and should be carefully assessed.
As a bushwalker and lover of nature, I have spent many of my most wonderful days in the Gardens of Stone area, enjoying the beauty and drama of the bush, the scenery and the fantastic geological formations. I have also been heartbroken to see, first hand, the fissures in the celebrated pagoda formations, which seem to be unique in the world, clearly caused by the undermining (literally) by the coal mines. Worse still is the drying of the wetlands that provide the water catchment for the rivers that flow in opposite directions from the Newnes Plateau, and worst of all is to learn of the decline of and threat to the survival of several species of plant that are precious because of their adaption to a dry climate area – something that is predicted to increase. Drying lands need a resource of plants and animals that are adapted to the new conditions.
Accordingly, I beg those concerned with the decision on the proposed modification to consider these and all other issues of environmental concern that relate to the decision, and thank them/you in advance for your consideration of this submission.

Yours faithfully, David Freeland

I am writing re modification 5 (MP06_0021) and modification 8 (SSD-5579), and make the requests below.

I am appalled that citizens are required to repeatedly foil greedy attempts to foist underhand erosions of reliable preservation of endangered swamps and streams in the Gardens of Stone State Conservation Area.

I note that the 2018 approval for pumping from mine workings dropped the groundwater table by 20 - 30 metres, drying out Kangaroo Ck, Lambs Ck, nearby swamps, and causing damage to swamps that feed into Sydney’s water supply.

My understanding is that Centennial Coal’s actions have repeatedly failed to ensure preservation ecosystems of national environmental significance.
I request compliance with all relevant Federal environmental laws.
My understanding is that our democracy has already decided that the Gardens of Stone State Conservation Area is worthy of being implemented, to PRESERVE its ecology, not fracture its drainage system so that it turns into a dustbowl.
My understanding is that not only do the miner’s proposed changes grossly threaten such preservation, but that similar actions by miners have already resulted in significant damage to ecosystems!
Please make a finding as to whether or not my above understandings are correct.

I request that the NSW government assesses whether Centennial Coal’s actions essentially constitute an underhand attack on democratically made decisions.

I request that private citizens should not be burdened with what feels like a never-ending game of whack-a-mole to respond to such underhand attacks on our democracy - it is ludicrous to think that it is democratic or fair to allow procedures such that one technical mistake or omission made by concerned conservationists could result in the Gardens of Stone State Conservation Area being irrevocably turned into a dustbowl.

I request the reviewers of this proposal to seek ministerial review as to whether the current processes provide a fair implementation of democracy, or whether existing processes allow an unacceptable risk that miners’ repeated attempts to erode democratic and Supreme Court decisions will result in irrevocable destruction of a natural heritage that has been democratically deemed worthy of protection for all future generations.

Although I appreciate that any corporation is duty-bound to maximise shareholder profits, as we face another summer of catastrophes caused by greenhouse gases, it is clear that it is morally bankrupt to make coal extraction cheaper by damaging the local environment. Hence:
I request that the reviewers of this proposal determine whether the sought modifications should also be considered according to local, state, and/or federal procedures re Australia’s responsibilities re greenhouse gases.

For such reviews of process to be at all meaningful, they must consider the actual effective disparities of power between a legal team funded by profit-motivated corporations, and citizens funded by colouring-in competitions by primary school students who hope to grow up in a planet not denuded of hanging swamps and coral reefs, and not riven by water-wars and displaced climate refugees.

To whom it may concern,

Many years ago I visited the Gardens of Stone and was overwhelmed by its natural beauty. It is indeed unique and very special and must be protected. It is my understanding that it is a very fragile area and needs protection from any development, especially destructive mining practices.

Photos I have seen of the damage caused by previous mining operations are very distressing for me. There have been huge cracks in the beautiful rock formations. Swamps are drying out, destroying the fragile ecological habit.

By the way, opening this for discussion before the start of a long weekend has effectively shortened the exhibition period and reduced the time for making a submission. Bad planning in my opinion, or maybe it was unscrupulous planning.

I am very concerned for this national heritage site. Centennial Coal’s mining proposals are a threat to the Gardens of Stone. Their proposals include plans to recommence discharges of mine water to the Coxs River catchment, part of Sydney’s water catchment. That is insane!!

Any modifications should be part of the Angus Place West proposal.

Modification 8 for Angus Place and modification 5 for Western Coal Services appear to be part of  Centennial’s plans to expand mining under Angus Place West – which has to go through a state significant development application.

It would seem that Centennial Coal is trying to get around the purposes of the Environmental Planning and Assessment Act, 1979.

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.

The unique wetlands are being decimated by Centennial Coal already and any increase in the approved pumping will be disastrous, lowering the water table again.

What madness is it to put Sydney’s water supply at risk of contamination?

This whole proposal must be scrutinised closely, as Centennial Coal have not been acting responsibly as far as the environment is concerned.

Short-term profit is abhorrent.

Thank you for the opportunity to share my concerns.
Regards,
Narelle Jarvis

I am a nature lover with a particular fondness for the Gardens of Stone area. I am also particularly concerned with fossil fuel developments which have a deleterious impact on the natural environment, and potentially on wetlands and the water table. My objections are driven by the following key factors.
• The 14 day public exhibition period started just before the long weekend, and I have not had adequate time to fully consider the negative impacts
• The modification proposals should be part of the Angus Place West major project, not treated like separate projects.
• Absolutely critical wetlands, creeks and swamps could be damaged and it appears the water table could be lowered by as much as 30 metres.
• Sydney's drinking water supplies might be contaminated – the water the proponent is proposing to dump is too polluted to be be treated at the specially built 40ML/day mine water treatment plant. That polluted water must surely be treated before release into the environment
• The modification proposals are of such significance that they should be reviewed under the Federal EPBC Act, and by the Independent Expert Scientific Committee on Coal Seam Gas and Large Coal Mining Development, the NSW Independent Planning Commission and the Independent Expert Advisory Panel on underground mining.
To protect my privacy please withhold my name from the list of submitters that is published on the NSW planning portal.
Thank you.

See attachment

I'll keep it very simple.
I object to this project. Close down the damn mine. No to further mining. We don't want it and we don't need it.
All water to be correctly treated. No to dumping it into the waterways.

Please note this is a submission on behalf of Lithgow Environment Group Inc.

Please see attached my personal submission for this project.

Thank you for providing the opportunity to make a submission. Yours truly
Yours truly
Julie Favell

I object to the proposal. The short-term benefits are significantly outweighed by the permanent impacts of the proposal, including impacts to the Greater Blue Mountains World Heritage Area. The proposal and assessment are critically flawed and far too brief to merit approval, for the following reasons.

- The assessment of impacts is far too brief and requires further detail and assessment.

- The length of time for consultation and submissions is too short.

- The assessment has not considered any potential impacts from groundwater drawdown due to removal of mine / groundwater, including assessing potential impacts to swamps or wetlands.

- The assessment of impacts to surface water states there will be an increase in some metals discharged into the Coxs River catchment, which flows into the Greater Blue Mountains World Heritage Area.

- The assessment of impacts to surface water justifies discharges to the Coxs River catchment by saying discharges will dilute existing approved more contaminated discharges. This justification should in no way be acceptable. Any water discharged into the Greater Blue Mountains World Heritage Area catchment should be treated to a high standard.

- The proposal does not provide intergenerational equity - "that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations". Continued extraction of coal leading to greenhouse gas emissions, drawdown of groundwater and discharge of untreated water into the Coxs River catchment in no way maintains or enhances the environment for future generations.

- Centennial Coal has a track record of repeated and serious environmental breaches causing permanent damage to the Greater Blue Mountains World Heritage Area which should be taken into account, including discharge of coal fines into the Wollangambe River, fracturing of pagodas, and permanent loss of peat swamps.

see attached

I am a resident of NSW and I am deeply concerned about the damage that we are doing to our environment, locally in NSW, nationally across Australia, and globally. Like many people I value greatly the natural environment and spend a lot of time in it, mostly walking and birdwatching, and I was delighted when the significance of the Gardens of Stone area recently received formal recognition.

As a public health doctor, I am extremely aware of the damage that is being done to human health by the degradation of the environment. It is obvious that human health and welfare is completely dependent on having a healthy natural environment and that civilisations have developed over the last 12,000 years only because we have enjoyed an historically unique period of environmental and meteorological stability. This is threatened, in fact already being undermined, by the damage we are doing to the environment. The consequence is completely unnecessary illness and premature death.

I am greatly concerned by the proposal by Centennial Coal to pump toxic waste from the Angus Place coal mine and dump it into Sydney’s water catchment area. This is completely irresponsible.

I also think it is ridiculous that Centennial Coal can take as long as it likes to prepare and submit its proposal and yet the public is given only two weeks to make submissions about it. I would have hoped that the NSW government, anxious to make the best decision possible, and take all factors into consideration, would be keen to give the public ample opportunity to respond to the proposal. Two weeks is unfair, inefficient and an insult to the citizens of NSW. I fail to see what possible reasonable reason there can be for this extremely short time frame. It would be appropriate in my view for the government to extend the submission period for at least four weeks beyond the current deadline.

Returning to the proposal itself:
• The modifications being proposed should be considered with the proposed Angus Place West mine expansion, not on their own. This fragmentation of proposals is nothing but a ruse to prevent all the impacts being considered together.
• The modifications are likely to pollute surface water and have a severe harmful effect on the ecology of several local creeks and swamps.
• The contaminated waste will contaminate Sydney’s drinking water and will contribute to ill health among the population.
• The modifications should be referred to the Commonwealth government for assessment under the EPBC Act.
• It is now well recognised that if global warming is to be kept under the internationally agreed 1.5oC, no new fossil fuel projects, including expansions of existing ones, should be approved.
• The dreadful consequences for human health of global warming are also now well recognised. These are already occurring and will get worse as greenhouse gas emissions continue.

In my view, it is completely irresponsible in terms of the local environment, Sydney’s drinking water, climate change and human health for this proposal to be approved.

Summary of objections:
• There has been a lack of time to comment on these damaging proposals
• The modification proposals should be part of the Angus Place West major project, not treated like a separate project
• Nationally endangered wetlands and swamps could be damaged
• Sydney's drinking water supplies might be contaminated – the water they are proposing to dump can't be treated at the specially built 40ML/day mine water treatment plant
• The modification proposals should be subjected to scrutiny under Federal environmental law
• Centennial's track record means its environmental report on these proposals should not be relied upon
• Another reverse osmosis treatment plant is needed right now to treat this additional mine water.
Please see attachment for further comments.

Please confirm receipt of submission

As a keen bushwalker and a person concerned about out natural environment I would like to object to Centennial Coal’s plan to pump toxic effluent from the Angus Place Coal Mine into Sydney’s drinking water catchment area in order to lay the groundwork for a new coal mine. I am deeply concerned both by the development of new coal mines and the possible results of the pump out in damaging nationally endangered wetlands and swamps in the area. I am also concerned that Sydney’s water supplies may be contaminated by the pump out

Please see attached submission. Please consider the climate change implications of the project as well as the environmental concerns that I have outlined.

I have two concerns about Centennial Coal's latest plans for its Angus Place Mine:
1. As a resident of Sydney, I find it entirely unacceptable that a coal mine should be permitted to act in a way that risks contaminating Sydney's precious water supplies with toxic metals. My understanding is that the level of treatment of proposed mine effluent may not be sufficient to prevent toxic chemicals like arsenic and selenium from entering the Wangcol Creek catchment, with the likelihood that they will flow into Cox's River and from there into Sydney's water catchment. Even a slight elevation in the levels of these chemicals puts at risk the health of millions.
2. As a regular visitor to the Gardens of Stone region, I am very conscious that this is an important ecosystem with high environmental values, as well as a place of great natural beauty. It needs to be protected, not put at further risk by coal mining. Centennial Coal has a poor track record in terms of environmental damage from its coal mining operations, and this indicates that the NSW public cannot trust its assurances. As recently as 2022, Centennial breached its development consent for Airly mine resulting in significant fractures to million-year-old sandstone pagoda. Its operations have also drained water from creeks and swamp areas. As the impact of climate change on our weather increases, with increased temperatures, we cannot afford to put our remaining natural water systems under further pressure. That's leaving aside the general impact of mining and burning more coal generating more carbon emissions and generating more climate change, caused by Centennial's operations.

I have been a resident of the Blue Mountains for over 40 years. My son has grown up here in the Blue Mountains World Heritage National Park where he and his friends use the area for bush-walking, rock climbing, bird watching and photography. My family and friends are also keen bush-walkers and observe the amazing array of fauna and flora. The enormous value of this area for recreational enjoyment and environmental conservation cannot be over-stated.
I am objecting to this proposal for the following reasons:
If approved, these modifications could obscure the extent of impacts from the future Angus Place West mine expansion proposal on national heritage in the new Gardens of Stone reserve. Modifications are supposed to allow for minor changes to approved major projects. These modifications could damage nationally endangered swamps and plants and drain water from streams in the new Gardens of Stone State Conservation Area. These proposals seek to by-pass the $120 million reverse osmosis mine water treatment plant and permit the discharge of mine water into the Coxs River catchment.
It appears that Centennial Coal is trying to get around the purposes of the Environmental Planning and Assessment Act, 1979

In 2018, Angus Place Mine Modification 5 was approved allowing pumping at a rate of 10 ML/day from mine workings (areas 800 and 900). Following this approval, the groundwater table dropped between 21 and 30 metres (Centennial Coal, Coxs River Swamp Review, July 2018, pg 44). This drop in groundwater was observed to quickly dry out Kangaroo and Lambs Creeks and associated swamps, as well as the Coxs River and swamps (Lithgow Environment Group, pers. comm. 4 Oct, 2023). Since 2018, far-field loss of surface waters in Newnes Plateau streams and swamps have been observed over a kilometre away following depressurisation of groundwater in a coal seam due to coal mining at Springvale.
Such far-field impacts may explain the observations made by Lithgow Environment Centre in 2018 and why future surface water losses from dewatering areas 800 and 900 may be expected. The proposed modification 8 which would allow pumping at 10ML/day from areas 800 and 900 is likely to again lower the groundwater table, and probably also impact on surface water resources in the area of operations for the Angus Place West proposal.
Other consequences of this proposal could mean that nationally endangered plants may also be harmed
The mine effluent will have elevated levels of heavy metals if salinity is treated to the proposed 350?S/cm standard. This level of treatment may not adequately protect aquatic ecosystems
Wangcol Creek flows to the Coxs River and is part of Sydney�s Drinking Water Catchment. 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.
This would risk contamination of Sydney’s water supply.
I am concerned that the modifications have not been referred for Commonwealth assessment under the EPBC Act. We think that this project is likely to have significant impacts on water and that the modifications should be referred to Environment Minister Plibersek to determine if the water trigger applies. Commonwealth assessment and the application of the water trigger is important to ensure that there is rigorous assessment of the surface and groundwater impacts of the modifications.

The mine water that is to be discharged into the Coxs River flows downstream into the Greater Blue Mountains World Heritage Area. Any downstream impacts of mine water arising from the proposed modifications on World Heritage values of the World Heritage property must be considered. They are likely to impact on water resources of a drinking water catchment, a World Heritage Area and nationally endangered plants and communities. Nationally endangered wetlands and swamps could be damaged
Modification 8 Angus Place and Modification 5 Western Coal Services should be controlled actions under the EPBC Act.

Centennial has failed to demonstrate that it can operate responsibly in the Gardens of Stone region without causing irreversible damage to the environment. Records of environmental incidents and harm, consent and licence non-compliances, and inaccurate predictions of environmental impacts from its operations suggest that current impact predictions in the environmental assessment for these modifications should not be relied upon. An audit of Centennial�s mining licences for the past five years has found at least 134 licence non-compliances across its sites in the Gardens of Stone region.
It is for these reasons that I strongly oppose this modification proposal.
I would also like to raise my concern over proposal process;
The lack of time for comment on these damaging proposals
The modification proposals should be part of the Angus Place West major project, not treated like a separate project
The modification proposals should be subjected to scrutiny under Federal environmental law