Wakefield
,
New South Wales
Message
I object to the Newstan Mine Extension Project on the fundamental principle of the precautionary principle.
Just because this coal mine has been present in the area for over 130 years DOES NOT mean it continues to be a good fit with the expanding urban and residential landuses. Times change and surrounding landuses change. An expansion to mining operations in this location is not a co-existing landuse (as the report suggests). It is fundamentally against the precautionary principle (7.6.1).
Yes, it could be argued that people who moved into the surrounding areas knew the mine was located there, but this does not mean that an expansion to the current mining operation is, or should be, a forgone conclusion.
The report covers many of the key economic, social and environmental factors. Of course it does. And it justifies the continuation and expansion of the mining operations, as a report written for mining is no doubt bound to conclude. BUT some things have been glossed over.
"the potential impacts of the project have been minimised by maximising the use ... developing low impact ... minimising surface disturbance ... complementary suite of mitigation measures and management strategies to be implemented ..." WOW
ECONOMIC
Tick. Big bucks for the government. Jobs for the people.
ENVIRONMENTAL
* This project is a CONTROLLED ACTION under the Environment Protection and Biodiversity Conservation Act 1999 due to the extent of the potential impact to the threatened and endangered species listed under the EPBC Act. This has concluded that there will be an impact on these species (particularly birds such at the glossy black cockatoo, powerful owl and the ten or more micro-bat species). The report says that an offset strategy will be provided for these impacts, but I did not see any detail of this.
* Furthermore, it appears that some of the land to be cleared is within an existing offset area established by Lake Macquarie City Council. This is illogical. How can you offset an impact on threatened and endangered species, by having an impact on an already, offset area? What the? The existing offset area established by Lake Macquarie Council is for a completely different project and should be avoided by this current proposal.
ENVIRONMENTAL AND SOCIAL
* Dust and noise are obvious issues with any expansion of coal operations. But these have been mitigated out of significance.
* The traffic studies and recommendations have pulled out the standard approaches and, of course, have concluded that no road upgrades or intersection improvements are required. Well what about the idea of utilising the existing haul road as a direct route to the site for vehicles (ie employees, deliveries etc). That is, to upgrade the intersection of the existing mine haul road with Cessnock Road. Direct access to site mine sites and direct access to the M1 motorway.
* The increase in vehicle movements on the surrounding road networks seems vastly understated or overlooked. A workforce of 350-400 FTE employees will generate significant traffic movements, day and night. This will affect the amenity of the surrounding areas in regard to increased noise (air and dust pollution). It also seems illogical that intersection upgrades are not seriously being considered (s.6.10.1 states potential impacts could occur, Table 6-56 operation generated traffic volumes) .
* Management of the coal stockpiles does not appear to have been addressed in the report (granted it is over 372 pages long, so it may have been hard to find). There are lots of noise dB and air PM etc, but they conclude that the increase in levels will not exceed current levels, except for when there was a really big dust storm. Really? Of course there will be an increase in noise and air pollution. Just think about the ventilation fans and the increased traffic to and from the sites. These have not been mitigated adequately other than saying, yeah a bit more noise and air pollution is going to happen, but not significant. Not significant perhaps if you dont live nearby.
SOCIAL/AMENITY IMPACTED
* This brings me back to my point about the precautionary principle: that an existing coal mine (of over 130 years etc) in this area is one thing, but the EXPANSION of this coal mine is a completely incompatible landuse as the surrounding landuses have changed and evolved over time.
* Groundwater, surface water and discharge into Lake Macquarie
How can it be 2021 and we think it's okay to discharge mine water into the largest estuary in the southern hemisphere?
Yes, yes the water will be treated to an "acceptable level" before being discharged. But seriously? Is this the best we can do? Is this the legacy we want to leave for our children? What about genuine commitment to intergenerational equity (7.6.2)?
Thank you for considering my submission.
I trust that the points I have raised are given their due consideration and not glossed over.
Yours sincerely