Mt Arthur Coal MOD 2 (Pathway to 2030)

See attached

Please find our submission (attached) which explains in detail why Lock the Gate objects to this Project.

Please see attached document for Aurizon's submission supporting Mt Arthur Coal Mod 2 (Pathway to 2030).

I support the project on the basis of the pathway to 2030 closure, enabling timely evaluation of the significant Pumped Hydro opportunity: with potential to develop a fit for purpose final void(s) and to overlap construction with mining prior to closure (maximising value, minimising costs, maintaining employment and bringing forward commissioning time to better match the state's transition to renewables).

Please see attached submission.

The Hunter Thoroughbred Breeders' Association provides comments and recommendations on the Mt Arthur Coal Mine Modification 2 - Pathway 2030 in the attached submission

Our comments here relate to closure planning and the potential to deliver rock climbing facilities for the Hunter community as outlined in attachment 2 of the Alternate Mine Planned Reuse Prospectus.

There are very few areas of good rock in the upper Hunter that support outdoor rock climbing either using bolts for safety ( sport climbing) or climbing on featured boulders (bouldering).

It is probable that sandstone horizons and/or dolerite or basalt intrusions would be of suitable rock quality to allow the development of vertical cliff faces of optimal height for sports climbing. An ideal height is between 10 to 30 metres. In addition large boulders of good quality rock up to 4m in height could be placed to create a bouldering park.

Development of such a recreational opportunity would require planning before closure to preserve sites of suitable orientation and stability for climbing. Planning for drainage, access and hazard minimisation is also required in the closure phase to ensure safe access to cliff faces and boulders. There are well qualified climbers with backgrounds in geology, environmental science, mining engineering and geotechnical engineering who could provide advice as to the considerations to create a unique and valued climbing opportunity and ACANSW is always happy to provide further input.

Thank you for the opportunity to make a submission on the proposed Modification 2 of the Mt Arthur Coal project.

The Sydney Knitting Nannas are opposed to any new coal or gas projects, in line with the global declarations by the IPCC and IEA that we cannot afford to have new coal or gas mined if we are to have a hope of achieving the 1.5C goal. Neither can Australia reach its legislated target of net zero emissions by 2050 without ceasing new coal and gas mining approvals.

In relation to the Mt Arthur Coal MOD 2 proposal, the Nannas have some major concerns at both the broad and specific levels.

At the broad level, it’s important to recognize that Mt Arthur is not only the largest coal mine in the Hunter Valley, it will also be the first to close. As such, what happens here will set the standard for the closure of the remaining coal mines. Closing the coal industry in the Hunter represents a major change to the region, and to be done properly it must have thoroughly-planned – and rigorously overseen – procedures for:

- staging down operations over the remainder of its lifetime, so as to avoid abrupt changes that will have a major impact on the social and environmental fabric of the region.
- rehabilitating the mined landscape so that the area is best able to provide for the people of the region after operations cease.

With the closure of this mine, the NSW government has an opportunity – and responsibility - to set the bar for coal mine closures. The people of NSW need assurance that the heavily mined areas of the Hunter Valley will be restored in such a way that the post-mining landscape is ripe for their social, economic and environmental needs.

In light of our broad concerns, the following specifics of the proposed modification are of major concern to us.

• extending the approved mining operations by 4 years (from 2026 to 2030)
Extending the mining operations flies in the face of what the science and international policy tell us about what we need to do to avoid climate catastrophe. We are opposed to any extension of fossil fuel mining.

• reducing the approved open cut ROM coal extraction rate by 7 Mtpa (from 32 Mtpa to 25 Mtpa)
This reduction would allow mining at Mt Arthur to continue at a very high operational rate (almost 80% of the current rate) right up until the proposed cessation in 2030. There is no staged decrease, which adds an unjustifiable level of risk to any just transition for the community and mine workers when the industry shuts down. A just transition requires genuine cooperation with stakeholders – workers, First Nations groups and other community members.

• extending the north-west disturbance footprint
The mine extension is NOT a modification to the existing development consent. This extension project should be made part of the “Transition and Mine Closure Project” for Mt Arthur, and as such should NOT be either assessed or approved as a modification. Instead, the mine operators should submit a new application that covers the entire development, including full planning for staged closure of the mine. Again, it’s the standard that’s set by the NSW government on this mine’s closure that will determine where the bar sits for future mine closures.

• revising the final landform configuration (including final voids) to allow for mine closure
Again, revision of the final landform configuration includes the mine extension project which is NOT part of a modification, but rather part of the overall closure process.

If the Modification is in fact approved, conditions of approval should include strict criteria for the preparation and implementation of Mt Arthur’s Transition and Mine Closure Project, including:
- the Closure plan should be developed through genuine cooperation with stakeholders - workers, First Nations groups and other community members.
- Surety for the future of the Hunter region post closure. This project should be considered in the context of a Hunter transition plan AWAY from coal. Developments in the region post-mining should maximize social and environmental benefits to the region – not simple economic benefits. To this end, any new developments should be assessed for viability of community–ownership and profit-sharing schemes.

The Sydney Knitting Nannas are concerned that the Modification process offers a pathway for coal companies to avoid a full and rigorous planning process. With the urgent need to close coal and gas operations, we need our government to step up and set the standard that will give our current mining regions the best opportunity for a healthy and prosperous future through a just transition away from fossil fuels.

We urge you to take this opportunity.



Bernie Hobbs
On behalf of The Sydney Knitting Nannas
https://knittingnannas.org/

Subject: Submission of Objection to Mt Arthur Coal MOD 2 (Pathway to 2030)

10/11/2023

Joe Fittell
NSW Department of Planning and Environment
4 Parramatta Square
12 Darcy Street
Parramatta NSW 2150
Phone: 4908 6896

Dear Mr. Fittell,

I am writing to express my strong objection to the proposed modification (MOD 2) for the Mt Arthur coal mine, outlining a pathway to extend its operations to 2030. As a concerned member of the community, I believe that this modification poses significant environmental risks, particularly in relation to climate change, air quality, and the potential exacerbation of extreme weather events such as the devastating 2019-2020 bushfires that impacted the local community of Muswellbrook, NSW.
Climate Change Concerns:
1. Carbon Emissions
The NSW EPA 2021 Statement of the Environment report underscores the pressing need to address carbon emissions and their impact on climate change (NSW EPA, 2021). The continued operation of the Mt Arthur coal mine contributes to carbon emissions, exacerbating climate change.
a. Scope 1 Emissions Calculation
Considering the proposed modification, it is imperative to conduct a thorough evaluation of Scope 1 emissions, encompassing direct greenhouse gas emissions from sources owned or controlled by the Mt Arthur coal mine. According to available data, the calculated Scope 1 total stands at 2.52 Mt CO2-e.
b. Scope 2 Emissions Calculation
Additionally, the assessment of Scope 2 emissions, which includes indirect emissions associated with the generation of purchased electricity consumed by the mine, reveals a total of 0.36 Mt CO2-e.
c. Scope 3 Emissions Calculation
The evaluation of Scope 3 emissions, covering indirect emissions from activities across the value chain, indicates a total of 190.26 Mt CO2-e.
2. Extreme Weather Events, Drought, and Royal Commission Recommendations:
It is crucial to acknowledge the local impact of climate change, particularly evidenced by the devastating 2019-2020 bushfires that ravaged the community of Muswellbrook, where the Mt Arthur coal mine is situated. The Royal Commission into the 2019-2020 Bushfires emphasized the urgent need to address carbon emissions and combat climate change. The recommendations of the Royal Commission underscore the imperative of mitigating climate change impacts, including reconsidering projects that contribute to carbon emissions and the intensification of extreme weather events. The drought that preceded the fires further highlights the vulnerability of the region to changing climate conditions.
3. Human Toll of the 2019-2020 Bushfires
It is with great sorrow that we acknowledge the profound impact of the 2019-2020 bushfires, which claimed 483 Australian lives (Royal Commission, 2021). This tragic loss emphasizes the urgent need to address the factors contributing to such extreme events, including the potential exacerbation by projects like the Mt Arthur coal mine extension.
Air Quality Impacts:
1. **Particulate Matter and Respiratory Health:** The NSW EPA 2021 report emphasizes the importance of assessing and mitigating air quality impacts on community health (NSW EPA, 2021). Prolonged mining activities, as proposed in the modification, may lead to increased levels of particulate matter in the air, adversely affecting respiratory health in nearby communities.

2. IPCC's Stance on Air Quality:
The IPCC Summary for Policy Makers further emphasizes the need to address air quality concerns associated with fossil fuel projects (IPCC, 2021). The potential health risks posed by poor air quality resulting from coal mining operations align with global recommendations against new or extended fossil fuel projects.
Conclusions
In light of these climate change and air quality concerns, I urge you to conduct a thorough evaluation of the environmental impacts associated with the proposed modification of the Mt Arthur coal mine. It is essential to prioritize the health and well-being of the community and to align the decision-making process with global initiatives, as outlined by the NSW EPA, the IPCC, and the recommendations of the Royal Commission into the 2019-2020 Bushfires.

I appreciate your attention to these specific environmental considerations, including the local impact of the 2019-2020 bushfires and the preceding drought, and trust that you will carefully weigh the climate change and air quality impacts, including the provided emissions calculations, before making any decisions regarding the modification of the Mt Arthur coal mine.

Thank you for your time and consideration.

Sincerely, Jayden Pan
Bachelor of Environmental Science and Management

References:

NSW EPA. (2021). *Statement of the Environment 2021*. Retrieved from https://www.soe.epa.nsw.gov.au/

IPCC. (2021). *Summary for Policy Makers*. Retrieved from https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_SPM.pdf

Royal Commission into National Natural Disaster Arrangements. (2021). *Final Report*. Retrieved from https://www.royalcommission.gov.au/system/files/2020-12/Royal%20Commission%20into%20National%20Natural%20Disaster%20Arrangements%20-%20Report%20%20%5Baccessible%5D.pdf

I have no issues with this project being moved forward to continue to support the local economy.

We all can’t sell $6 coffees, we need to generate work for people, we can’t solely rely on the service industries

though I support the wind down project , I would prefer the state continue the operations and use of the facilities to continue resource recovery from the deposit.