Modification 6 - underground mining extension

1. This proposal will continue to increase global emissions.
2. An additional area of 993.2 ha will be impacted by mine subsidence including cumulative impact on significant sandstone cliff lines.
3. An additional 48 sites with First Nations cultural values will be impacted. The cumulative loss of cultural heritage across the Ulan Mine is highly significant.
4. Loss of 24.7 ha of woodland vegetation including 9.5 ha of critically endangered White Box – Yellow Box – Blakely’s Red Gum Woodland ecological community providing habitat for numerous threatened fauna and flora species
5. Removal and disturbance of habitat for critically endangered Regent Honeyeater, Swift Parrot; endangered Koala and Long-eared Pied Bat and numerous other threatened fauna species.
6. The iconic groundwater dependent ecosystem on the Goulburn River known as ‘The Drip’ is incorrectly described with no recognition of the connection to the regional groundwater system.
7. Cumulative groundwater drawdown will cause loss of additional base flows to both the Goulburn River to the east and the Talbragar River to the west for up to 3,000 years.
8. The proposed new workings will provide continuation access to a large area of coal to the north of current operations.
9. It is imperative that coal mining cease at the Ulan operation no later than 2033 to allow for the necessary global decarbonisation for the management of climate extremes.

Background
Moolarben Coalmine is a very large operation near Mudgee on the headwaters of the Goulburn River, a major tributary in the Hunter River catchment. The mine is owned and operated by Yancoal, a Chinese owned multinational. It has current approval to produce 22 million tonnes of thermal coal per annum until 2038 from four open cut mines and three underground mines. The mining complex covers over 80 sq. kms of sensitive environments with significant cultural heritage values. The cumulative impact of current approvals has caused a major loss of threatened species habitat and First Nations culture, sandstone cliff removal and collapse, and permanent loss of irreplaceable water sources.
The proposed expansion on exhibition intrudes further into the upper Moolarben valley, an area rich in biodiversity, ringed by natural springs and bounded on three sides by the outstanding Munghorn Gap Nature Reserve that straddles the Great Dividing Range.

Key points for a submission of objection:

1. Climate Change impacts:
The proposal is to produce an additional 40 million tonnes of coal and increase greenhouse gas emissions by 86.59 Mt CO2-e
The consequences of scope 3 emissions ( i.e the emissions arising form the use of this coal overseas should be considered in the assessment of this project
2. First Nations heritage impacts:
A total of 130 first nations cultural heritage sites were identified within or overlapping the subject area including shelters with artefacts (one with possible burial), and axe grinding groove site
3. Water impacts:
• The permanent loss of potable, good quality (low salinity) groundwater from springs that provide fresh flows to creeks and the Goulburn River
• A predicted loss of baseflows to the Goulburn River between 180 – 225 million litres /year and 600 million litres in wet years. This will impact on river health and downstream water users, including Goulburn River National Park.
• A 200m buffer zone to Moolarben and Murdering Creeks (aimed at protecting them from mining) includes mine haul roads and other infrastructure impacting crucial riparian vegetation.
4. Biodiversity impacts:
• The extended mining operations will come within 100m of the Munghorn Gap Nature Reserve threatening important conservation values especially native bird and Koala habitat.
• Noise, dust and lights from the 24 hour operations will disrupt the many identified threatened and endangered birds, mammals and bat species that live in and around the valley.
• The project would result in the clearing of 624.18 ha native vegetation including
477.75 ha of Box-Gum Woodland Critically Endangered Ecological Communities. This is irreplaceable and cannot be adequately offset.
• Ecosystem habitat loss for 22 threatened fauna species including: Regent Honeyeater (Anthochaera phrygia), Koala (Phascolarctos cinereus), Squirrel Glider (Petaurus norfolcensis), Large-eared Pied Bat (Chalinolobus dwyeri)
5. Agricultural impacts:
Loss of food production potential on large areas of prime agricultural land that previously supported many farming families. This land should be assessed as Biophysical Strategic Agricultural Land (BSAL) and assessed through the Gateway process.

I wish to express my concerns about the Ulan Coal Mine extension.
The current mine is part of a complex of coal mines positioned in an area of appreciable aesthetic, cultural and ecological value. Expansions to the current mine will have significant biodiversity impacts. The clearing of a significant area of native vegetation that is planned will result in a significant habitat loss for vulnerable species of fauna. This loss of native vegetation cannot be replaced, repaired or effectively offset.
Many first nations cultural sites are also contained within the area for planned extension and the loss of such sites needs to be considered seriously.
The proposed extension reflects a planned increase in the life span of the Ulan Coal mine by two years and a further 25 million tonnes of coal production. The greenhouse gas emissions resulting from the burning of such coal are profound. It is clearly evident that we need to be moving away from the use of coal for energy generation. Global temperature increases are already nearing 1.5C and without significant changes to how we obtain energy will rise beyond 2 degrees, with resultant catastrophic changes to the climate and the livelihood of people around the world. Planning for extensions to current coal mines in the current climate crisis could reasonably be described as absurd.
As a Mudgee resident I readily acknowledge the contribution that coal mining makes to the economy of our region and the many jobs provided by coal mining and related services. However, the cost of expanding our mining of coal far outweighs the financial benefits brought to the region (and to the coal mine operators.) In considering the planned extension please be mindful of the impact that expanding the mining of coal will have both for our generation and the generations to come.

Ibrahim Farag
1072 Blue Springs Road Cope
Lot 72 DP 750742

Objection to Ulan Coalmine Mod 6 Application

Ulan Coalmine is a very large coal extractor operating within the Mid-Western Regional Council LGA, in close proximity to the Goulburn River, it is one of three large coalmining operations operating in the immediate area.

UCMPL currently has consent to extract in excess of 22 million tones of thermal coal per annually until 2033. With three large longwall underground operations mines and previously an open cut mine, it covers an area of almost 150 km2, much of which is environmentally sensitive pristine wooded forest with many indigenous cultural heritage areas. As landholders we have no idea of the total volume of coal been extracted by the three companies, the cumulative impacts on surface and Ground water or impacts of subsidence on the region. I believe it is incumbent on the department to make those facts known to the property owners.

The original Mod 6 application proposed an extension of the MOD 3 approval over my property Lot 72 DP 750742. In the absence of the mandatory environmental assessments prior to the MOD 3 application I strenuously objected till those studies were performed and completed. UCMPL elected to amend the MOD 6 application by deleting the proposed extensions over my property.

It is my contention and strong submission that it is totally remiss and negligent of the Department to continue to consider applications by UCMPL until the mandatory environmental studies associated with MOD 3 are performed.

Those studies were not performed due to the submission of FALSE & MISLEADING Information in the EA's prepared by UMWELT on behalf of UCMPL, the Department is very conversant with the entire matter and has to date failed to ensure those studies are performed.

SURFACE AND GROUND WATER:

It is disturbing that comprehensive studies have not been performed on the cumulative impacts of all the current approvals on our surface and ground water, {our water resources are the life line of the entire area}.

As a consequence the immeasurable loss of our priceless Surface & groundwater "an essential NATURAL resource", has never been quantified, I am in doubt this is because to do so would be detrimental to the future operations of UCMPL and the other two mine companies in our district.

SUBSIDENCE:

In addition, it is of great concern that the subsidence modeling submitted and accepted by the Department has proven to be totally inaccurate and flawed.

The sad reality that the subsidence and surface cracking resultant from extraction beneath the property known as "Woodbury" has proven that the modeling is totally erroneous and flawed. That property has suffered from at least one SINK HOLE and the subsidence cracking to the surface has by far exceeded the modeling. While the predicted surface cracking was less than 20omm wide, it has in fact exceeded 1.4m in width.
Any reasonable person would anticipate that the consent authority would halt all operations and have the subsidence and water modeling peer reviewed by a SUITABLY qualified experts in addition to an internal review / investigation.

The disparity between the predicated surface cracking and the resultant surface cracking is not what could be regarded or viewed as "within the margin of error". The disparity in the surface cracking can only be described as dire if not catastrophic, and reinforces the dangers of relying on modeling.

It would be beyond alarming if the Department has been made aware of the disparity and not commissioned independent consultants to conduct site visits so and to prepare an impartial report on the failures of the modeling.

As landholders we are at the mercy of the Department in the hope they will always do the right thing and as the consent authority will act to protect of the interests of the landowners impacted by mining activities.

Finally the flawed modeling will undoubtedly have an impact on the veracity of the other EA studies. In simple words, had the modeling predicted there could be surface cracks well in excess of a meter in width:
1. Would the Department have approved the applications?
2. What impact would this have had on the reports by other consultants preparing studies on threatened species, natural habitats, creeks, indigenous cultural artifacts and heritage?
3. Sandstone outcrops, caves and cliffs?
4. The draw down levels ground water, aquifers and spring fed dams?
5. Water bores?
6. The loss of natural surface water into the catchments
7. Creeks, dams, billabongs, natural springs and swamps?

IMPACTS OF SUBSIDENCE ON SURFACE AND GROUND WATER:

Given the matters raised above, there is no doubt that the flawed subsidence modeling will directly impacted the water modeling which included impacts on aquifers and surface runoff. Given that "Woodbury" is the first privately owned property that UCMPL is extracting coal from beneath, the Department must revisit all the modeling prior to permitting extraction from beneath other privately owned land holdings.

To that end it I ask the Department and assessing officers the following questions:

1. Are they able to inform the land owners with any degree of certainty if the surface cracking and subsidence will be consistent with the modeling they relied upon prior to granting the UCMPL consents for underground wall mining?
2. That their properties will not suffer surface cracking mirroring that of Woodbury?
3. If the Surface cracking and subsidence will exceed the modeling what impact will that have on their surface water, runoff to catchment, aquifers and bores?
4. What are the current daily / weekly / monthly water pump outs rates from all the longwalls currently been mined?
5. Will the Department revisit and have the subsidence and water modeling they relied upon peer reviewed by totally independent experts in the respective fields?
6. What will the impacts on the ground be as a direct consequence of the loss of surface and ground water?
7. Does the Department accept that loss of surface and ground waters will have a permanent, irreversible and dire impact on threatened species, their natural habitat, and indigenous cultural artifacts and sandstone and cliff collapses.
OTHER MATTERS OF SERIOUS CONCERN:

1. Why has the Department accepted a Modification application that is silent on the cumulative impacts of subsidence, Ground and surface water as they do not acknowledge that the subsidence modeling has proven fundamentally flawed and erroneous?

2. It is my very strong submission that the Department can not approve any further extension to the Ulan operation beyond what has been approved no 2033.

3. The Department has a duty to acknowledge and ensure that their consideration of any coal application includes global decarbonisation targets for the management of climate extremes are met.

Annexures:

In support of the matters I raise I have attached a number of scientific papers and other relevant material:
1. A plan of the areas ALREADY declared within a Mine Subsidence District for Mudgee.

2. Scientific paper on "IMPACT OF LONGWALL MINING ON SURFACE WATER-GROUND WATER INTERACTION AND CHANGES IN CHEMICAL COMPOSITION OF CREEK WATER"

3. Scientific paper on " SURFACE WATER–GROUNDWATER INTERACTION IN THE FRACTURED SANDSTONE AQUIFER IMPACTED BY MINING-INDUCED SUBSIDENCE: 1. HYDROLOGY AND HYDROGEOLOGY"

4. Scientific paper on "SURFACE WATER-GROUNDWATER INTERACTIONS IN A CATCHMENT IMPACTED BY LONGWALL MINING "

5. Scientific paper on "THE INVESTIGATION OF GROUNDWATER-SURFACE WATER LINKAGES USING ENVIRONMENTAL AND APPLIED TRACERS: A CASE STUDY FROM A MINING-IMPACTED CATCHMENT"

6. Scientific Paper on "SURFACE WATER-GROUNDWATER CONNECTIVITY IN A LONGWALL MINING IMPACTED CATCHMENT IN THE SOUTHERN COALFIELD, NSW, AUSTRALIA"

7. Scientific Paper on "CHANGES OF WATER QUALITY IN A STREAM IMPACTED BY LONGWALL MINING SUBSIDENCE"

8. UCML Plan showing extent of "Catchment Boundaries and Remnant Ponding Impacts"

9. I have also attached my Social Impact survey response as UCML have NOT attached it in full as originally discussed and agreed. I object profoundly to their attempts to bury my responses.

I strongly oppose to this modification as it will increase the cumulative negative effects of three large coalmines in area.
Ulan mine has caused major loss of habitat for threatened species, loss of groundwater sources, mine subsidence.
Threatened species and critically endangered species cannot tolerate further loss of native vegetation.
Goulburn River will have additional loss of base flows The drip is a very important environmental feature.
The damage that will occur to the environment and First Nations Cultural sites cannot be accepted, This modification should not be approved

The project provides economic value to the community by extending LOM by ~2 years, with little adverse impact to environmental features by utilising existing infrastructure.

JUST DON'T !!!!!!

Ulan coal mines have been one of this areas main employers and community supporters for generations, the longevity of the mine is critical to the areas prosperity, it is of utmost importance that the communities future is also considered when evaluating this proposal.
Having worked in the industry for many years, I have also seen first hand the benefits this industry provides to many associated contractors and small businesses through out the mid west, these rural communities can often be overlooked by decision makers. Rural communities have very limited career opportunities, families are often separated in search of income and often ending up working city jobs in order to provide for the family. We need people and jobs in the bush, please don't overlook us.

I support the Ulan Complex expanding the mining operation into these new areas as the mine support 650 direct employees in the local community. This extension can be competed within the same footprint minimising impact to the environment

I support this project. Myself and my family members are employed in the coal industry, we live locally, spend the majority of our money locally, our children attend school in the local area. The continuation of mining activities is crucial to the viability and longevity of the local community, businesses and families

The flow of job is important for local community. It will increase local jobs, local economy which is most important for current and future generation.

The Mudgee region relies heavily on coal mining, and this allows continued operation of an already established and productive operation.

As a Mudgee local of more than 25 years, and a member of the mining community for more than 15 years, this extension project allows ongoing continued employment in an established location. I fully support the project.

I see no reason for this submission to be rejected.

I am in support of this project for the economic benefits that it will bring to our local economy.