New South Wales
I object to the Wollongong Coal's Revised Preferred Project Report (PPR)
to the Russell Vale Underground Expansion Project 09-0013. I object as
a local resident who will be directly impacted by the mine and as a
person deeply concerned about the environment.
Some of the reasons for my objection are listed below.
1. Climate change and Greenhouse Gas (GHG) Emissions
Coal mining, whether for energy or steelmaking, produces the GHG
Emissions that are causing dangerous climate change. This project is
estimated to result in 11,624,000 tonnes of GHG emissions through the
mining and the burning of the coal.
2.A risk to Greater Sydney Water Catchment
The mining will take place in the Special Areas of the Greater Sydney
Water Catchment - areas that forbid public access because of their
sensitivity and strategic importance - and up to the shores of the
Not only will the mining infrastructure, such as access roads and vent
shafts, disturb and damage the catchment, the proposal for Bord and
Pillar mining will result in up to 100 mm in subsidence.
The extraction for the Wonga Central Development Mains extends under
the Cataract Reservoir itself. Cataract is severely affected by
drought and is currently at only 29% of capacity. Mining should not be
permitted anywhere near Great Sydney water supply reservoirs.
3. Triple seam mining
The mining is particularly risky because a third seam of coal is being
mined beneath two previously mined seams. Triple seam mining has
little precedent and impacts are difficult to predict.
The proponent admits that instability in the overlaying old Bulli seam
workings may cause pillar collapse and subsequent subsidence of 1 to 2
metres. It is unacceptable of the NSW government to allow such risky
mining in the water catchment for 5 million people of Greater Sydney
in a time of drought.
4. The proponent is not fit and proper to hold a mining licence
Wollongong Coal and its parent company Jindal Steel and Power Ltd, are
currently the subject of an investigation by the NSW government's
Resources Regulator into whether or not they are a `fit and proper'
entity to hold a mining license. The company has a history of failing
to comply with conditions of approval. Even its auditors have
questioned its capacity to continue as a going concern; its current
liabilities exceed its current assets by nearly A$1 billion.
Wollongong Coal is not a `fit and proper' entity to operate a coal
mine in the water catchment of Australia's largest city.
5. Impacts on local community
The colliery site at Russell Vale is closer to dense residential areas
than any mine in Australia. Residential communities have suffered the
impacts from this mine over many years, including noise and
particulate pollution. In this day and age, Russell Vale is not a
suitable location for a colliery. Wollongong Coal plans to build a
coal processing plant at the Russell Vale Colliery and process coal on
site. The Russell Vale mine is the closest mine to any built up
residential area in Australia and is not a suitable area for coal
processing. Moreover, the proponent has been unable or unwilling to
comply with many conditions of past approvals and the NSW government
has proven to be unable or unwilling to enforce compliance. Residents
have no confidence in "conditions" or "commitments" to operate the
processing plant according to suitable standards.
6. The proponent has a history of non-compliance with approval
Previous applications and approvals promised numerous items to protect
the community and environment that have never been met by the
proponent. These include but are not limited to: truck loading
facilities, sound walls, covered conveyors, limited stockpiles, sealed
roadways and realignment of Bellambi Creek. Now in this new revised
project, Wollongong Coal is promising the same or similar things.
Wollongong Coal is currently operating right at this moment under
three non-compliances: the realignment of Bellambi Creek to protect it
from pollution and flooding (due Oct 2012); the removal of 200,000
tonnes of oversize coal that was illegally stockpiled on the adjoining
slag heap (due July 2019); and, the dedication of land to Council in a
1989 approval from Wollongong City Council (due 1990). All of these
obligations still have not been met.
A proponent with such a poor record of compliance should not be
considered for, let alone granted, approval to mine. The NSW
Department of Planning's inability or unwillingness to enforce
compliance (with the conditions that it itself has stipulated)
undermines confidence in the planning system.
We ask that you reject this application from Wollongong Coal and
commence a process to close the mine at Russell Vale permanently.
Thank you for considering this submission.