Russell Vale Underground Expansion

Dear Sir,

I strongly object to the proposed Russell Vale Underground Expansion.
It's complete madness to contemplate it.

At a time when Sydney's water supply is under pressure, and is
unlikely to improve (even if it rains) given the population explosion
in the city and surrounds, you are proposing to approve mining under
the 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
Cataract Reservoir.

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. 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.
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.

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.
The proponent has a history of non-compliance with approval conditions

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.
I 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.

Yours sincerely,

Ian Page

The expansion of this coal project worries me greatly. While I am not a
resident of Wollongong, I have deep concerns about water and the
climate.

Coal projects pose several risks to local water sources, in the
production and processing of coal, and the disruption to local ground
water sources that the mine itself produces. We're in a state wide
drought, and a risk as large as this doesn't seem reasonable in
considering the circumstances.

I'n also troubled deeply by the continued expansion of fossil fuel
projects that continue to elevate our nations increasing CO2
emissions. With the United Nations Intergovernmental Panel on Climate
Change, and a myriad of scientific consensus, telling all nations it's
time to immediately transition away from fossil fuels, this strikes me
irresponsible to our domestic and international responsibilities.

I care deeply about the wellbeing of my future children, my family and
those that'll be affected by climate change. To whoever is considering
these submissions, I hope you might understand the existential risk
posed by climate change, by extension, expansions of fossil fuel
projects.

Destabilising overlying mines

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 contrary to public interest for the NSW government to
allow such risky mining in the water catchment for 5 million people of
Greater Sydney in a time of drought.(1)

The land around the proposed mining is unstable. The proposal states,
"It is noted that large areas of the surface within the UEP
Application Area are currently on the verge of moving as a result of
previous mining." [2] It is described as being in "limiting
equilibrium" - still moving, having not stabilised since WCL mined
longwalls 4, 5 and 6 several years ago. If the Special Areas of
Sydney's Water catchment are so special that ordinary people can't
even set foot on them without risking a $44,000 fine, they are special
enough that they should be protected from earth moving, destructive
mining.

Impact on ground and surface water

The project will further the loss of ground and surface water from
Cataract Reservoir and its catchment, adding 131 ML/year of ground
water and 10 ML/year of surface water to losses from previous mining
damage. This is estimated to bring the total ground and surface water
loss from the project to 298 ML/year. [3] This is the equivalent
annual water usage of 25,492 people. [4]

An additional 146 ML of "upgradient inflow" from surrounding mines -
the now "inactive" Cordeaux mine and Corrimal mine (not mined by
Wollongong Coal) - are draining water into WCL workings, bringing the
total to 444 ML/year.[5] This is the approximate water usage of 37,981
Greater Sydney residents.[6]

Following mining the void left will fill up with water. The water will
keep rising until it reaches the adit (mine portal) in the Illawarra
Escarpment in about 2057. The water will overflow through the adit and
the outflow will slowly increase, reaching 0.3ML (300,000 litres) per
day in 2179. WCL's modelling shows that the volume of water outflow at
the adit above Russell Vale will continue to flow, even beyond 2179.
[7] In other words, the project will result in escalating water
discharge from the adit for at least 160 years and probably longer.
The outflow will need to be managed and treated. Wollongong Coal is
proposing a commitment to manage and treat the water for 10 years.[8]

Greenhouse Gas Emissions

Although only a small project, the Expansion has a large carbon
footprint. WCL's consultants divide emissions into Scope 1, 2 and 3,
with 1 and 2 being the emissions produced in the mining and processing
of the coal and Scope 3 being emissions are "indirect emissions that
are a consequence of the activities of the reporting
entity but occur at sources owned or controlled by another reporting
entity"[9]. Scope 3 emissions are the largest volume of emissions, as
they involve use of the coal. The total CO2e emissions for the
project, from mining up to and including usage are approx. 11,147,000.
[10]

To put this in context, this is the equivalent to the annual emissions
of more than half a million Australians.
[11]

Economic case

The mine is currently in Care and Maintenance mode and only about 60
staff are employed. Therefore the impact on the employment outlook for
the Illawarra if this approval was not granted would be minimal.
Moreover, as neither of Wollongong Coal's mines are currently
operating the flow-on effects to the local economy if this proposal
was not approved would be negligible.

A coal processing plant on site at Russell Vale Colliery

Wollongong Coal plans to build a coal processing plant at the Russell
Vale Colliery and process coal on site.[12] 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.

Trucking

· The coal is trucked along Bellambi Lane, past people's homes onto
the Northern Distributor to Port Kembla Coal Terminal. WCL's new
expansion proposal means more coal trucks on the busy Memorial Drive.
There will be an average of 16 laden trucks per hour, Monday to
Saturday, travelling to the port.[13] In other words, counting the
return trip, there will be 32 truck movements per hour, or one truck
every 112 seconds. In addition to this there will be more coal trucks
transporting coal mining waste.[14]

A history of non-compliance with approval conditions

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.

In fact right now, Wollongong Coal is operating under three major
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.

It is of real concern that the proponent is proposing to put in place
pit top infrastructure after they have started mining. History shows
that operators of this mine are unwilling or unable to meet the
conditions of mining approval and the Department of Planning is
unwilling or unable to enforce compliance. In every case the local
community suffers from the failure to implement required pit top
infrastructure.

The suitability of the proponent

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.

In India, corruption charges are being framed against Naveen Jindal,
Chairman of Jindal Steel and Power Ltd (JSPL). JSPL, via a holding
company, JSPL Mauritius, is majority shareholder in Wollongong Coal
Ltd. [14]

Moreover, here in Australia, 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. Operating a coal mine
in the water catchment of Australia's largest city is risky business.
The NSW Resources Regulator started investigating whether Wollongong
Coal was a "fit and proper" entity to hold a mining license in
2016...... and it's still investigating...... Isn't it about time the
Resources Regulator reached a conclusion? And shouldn't any
consideration of an expansion of operations be postponed until after a
conclusion has been reached.





REFERENCES

[1] Russell Vale Revised Underground Expansion Project 3687_R05 RtPAC
Second Review FINAL Revised Preferred Project Environmental
Assessment, p. 62
Accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[2] ibid, p 63
[3] Russell Vale Colliery Underground Expansion Project, Russell Vale
East first workings, Groundwater assessment, Geo terra, NRE16 - R1D,
11 July, 2019, p. 96 accessed at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[4] Based on water consumption of 306 litres per person per day, cited
in Sydney Water Conservation Report 2017/2018, accessed at
https://www.sydneywater.com.au/web/groups/publicwebcontent/documents/document/zgrf/mdq3/~edisp/dd_047419.pdf
[5] Geo terra 2019, op cit, p. 63
[6] Sydney Water Conservation Report 2017/2018, op cit 8[7] Geo terra,
2019, op cit, pp. 96-97
[7] Russell Vale Revised Underground Expansion Project, op cit, p. 172
[8] ibid, p. 158
[9] ibid, p. 133
[10] Greenhouse Gas and Energy Assessment 3687_R08_GHG Report_Final
Impact Assessment Results p. 7
accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[11] Australians annually are responsible for about 21.528 tonnes of
CO2 per person (based on 538.2 mt CO2 emissions year to Dec 18 as
cited at
http://www.environment.gov.au/climate-change/climate-science-data/greenhouse-gas-measurement/publications/quarterly-update-australias-nggi-dec-2018)
and population of 25 million)
[12] Russell Vale Revised Underground Expansion Project, op cit, p. 9
[13] TRAFFIC AND TRANSPORT IMPACT ASSESSMENT FOR RUSSELL VALE COLLIERY
REVISED UNDERGROUND EXPANSION PROJECT AT RUSSELL VALE RESPONSE TO PAC
SECOND REVIEW REPORT, p 5 accessed at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[14]
http://www.newindianexpress.com/nation/2019/jul/01/delhi-court-orders-framing-of-charges-against-naveen-jindal-and-four-others-in-coal-scam-case-1997865.html

I have two young children and am extremely worried about the effects of
the coal mining expansion plans on their future.

Wollongong Coal's Revised Preferred Project Report to the Russell Vale
Underground Expansion Project:

I object to the Wollongong Coal's Revised Preferred Project Report
(PPR) to the Russell Vale Underground Expansion Project 09-0013.

Some of the reasons for my objection are listed below.

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.
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
Cataract Reservoir.
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.
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.
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.
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.
The proponent has a history of non-compliance with approval conditions

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.

Yours sincerely,

Sarah Copeland

I object to the proposed extension on four separate grounds. (1) Mining
that risks loss of water from the catchment area for Sydney and
Wollongong should not be allowed; there's considerable evidence
already that mining is causing loss of water flow into dams that
provide water for Sydney and Wollongong. At this stage dams are below
50% full and falling rapidly, and ongoing population increases are
only going to create greater demand for water - NSW should not support
actions that will likely further reduce supply, particularly in face
of evidence that coal mining proposals in the catchment area routinely
understate likely impacts on water resources compared with outcomes in
practice. (2) Coal mining should be reduced across the board wherever
possible to avoid dangerous climate change; the IPCC has stated that
keeping warming to no more than 1.5 degrees above historic levels
requires immediate action to reduce emissions to zero. This mine
should not be approved for that reason. (3) This particular coal mine
is in a suburban location, and the impacts of coal extraction,
processing and transportation on local residents and transport systems
are unacceptable. (4) The company in question has a very poor track
record on compliance, and has repeatedly failed to comply with
conditions of its license. It should not be indulged any longer.
Enough is enough.

I view with alarm the plan to extend the Russell Vale colliery . This
mine tunnels under long established and vital water catchment not just
Wollongong but most significantly Sydney . Already massive amounts of
water are being lost in the catchment due to cracking caused by
underground mining . This is proven and the threat of further damage
is diabolical. How can this even be considered? It's crazy!!!
Furthermore access to the mine is through heavily populated city
street which already we have too many trucks on our roads in the
Illawarra. Please do not add to our overdevelopment and water
shortages in this region,
Sincerely Kate Broadfoot , Bulli

I am a student at the University of Technology Sydney studying
Environmental Sciences, as well as a member of the UTS Environment
Collective. I believe this proposal should be rejected on the basis of
the hydrological, ecological, social, and broader environmental
impacts that will likely come as a result of these planned
developments in NSW. Not only this, but 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.

I 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.

Yours sincerely,
Miles Carter.

This mining proposals is a major threat to the Sydney Water catchment
that provides drinking water to my young family. Mining in the
catchment area has been shown to result in subsidence and cracking
that diverts surface water and drains upland swamps. In a time of
increasingly variable rainfall due to climate change, it is essential
that this further impact to our water supply is avoided. I understand
that the proponent's long-wall mine proposal was rejected, and now
they have come back with a board and pillar mining proposal. I am
concerned that even this type of mine will degrade and collapse over
time. It's not just the time of mine operations that should be
considered, but the much longer time that our community will rely upon
it for drinking water. We need a secure drinking water catchment to
supply drinking water in perpetuity for many generations to come.

The proposed mine workings will be particularly prone to collapse
because of the cumulative impact of multi-seamed mining. There are
already pre-existing mined seams above the proposed new mine. It's
treating our escarpment like a house of cards.

The Illawarra's upland swamps are unique and threatened eco-systems.
They also act as natural sponges, holding water throughout the year,
buffering the fluctuations in surface water against the highs and lows
in rainfall These peat-rich phenomenons can hold so much water that
milk has more solids. In places that have upland swamps that have
existing mine damage, they dry out and become serious fire risks,
incredibly prone to burning and impossible to restore to a functioning
eco-system.

If damage is done to the catchment area then there is no proven way to
remedy it. Our water supply is too precious to sacrifice or short-term
mining interests.

The economic gain from this proposed mine is insufficient to offset
the economic damage it will inflict on Sydney's drinking water supply.

I am concerned that this proposal is being considered before the
Independent Expert Panel on Mining in the Catchment has made their
findings to government.

I am concerned that this company has failed to take responsibility for
the amelioration of the mine's slag heap that is currently on Council
land adjoining the public golf course. There are concerns that it
results in dust spreading over the adjacent recreational area,
residential area and childcare centre. It also poses a water pollution
risk.In 2017 this company was fined by the EPA for a serious water
pollution incident. At the time the mine failed to notify the
appropriate authority regarding this pollution event, and it was left
to a neighbouring resident to report the incident. This company is not
a fit and proper entity. They should not be granted to privilege of
mining NSW's resources.

I am further concerned that this proposed mine expansion will result
in more truck movements along Memorial Drive to Port Kembla. The
bottom of Mount Ousley is a dangerous pinch point where vehicle flows
split and merge in quick succession. In June 2 people where killed
when a merging car with a trailer caused an accident, that resulted in
two trucks squashing another car between them. We already have too
many heavy vehicles on this stretch of road. It is dangerous to add 30
or more truck movements per hour his congested and difficult stretch
of road.

I am also concerned about the greenhouse gas emissions from this
project. The Paris Accord shows that every nation must reduce its
carbon emissions. The proposed mine has a mix of thermal and
metallurgical coal. Renewable electricity generation as it is now
cheaper to build than thermal coal. Research into coal-free steel
production is being led in Australia by the Australian National
University. ANU's 'Grand Challenge' initiative named "Zero-Carbon
Energy for the Asia-Pacific" is exploring how to develop pathways for
the fully carbon-neutral production of iron and steel. I would like to
see this project, at worst, put on hold while alternatives are
explored and developed.

I object to the Wollongong Coal's Revised Preferred Project Report (PPR)
to the Russell Vale Underground Expansion Project 09-0013.

We cannot afford any new or expanding coal projects- our futures are
at high risk! Australia needs to be a leader in tackling effective
climate action and that won't happen as long as we continue to use
dirty energy to power our country.

We are in a drought and the risk that this project runs with water
waste and contamination is unacceptable. We must project the Greater
Sydney Water Catchment!

Please reconsider putting our community, our health, and our resources
at risk. Thank you.

This mine will have a devastating impact on the environment above it.
Longwall mining causes subsidence and major loss or contamination of
water, and no effective methods exist of stopping this damage. For the
sake of the environment, the global climate, and the people who rely
on the water collected in the catchment above the mine, please
reconsider this expansion.

I object to the expansion. The objection is based on the fact non
Renewable Resources and the pollution associated with their use is an
unacceptable contribution to the acceleration of climate change. We
are in a climate emergency. Our council has declared a climate
emergency. For my children for my region for my country and for this
planet I object.

Wollongong Coal's Revised Preferred Project Report to the Russell Vale
Underground Expansion Project:
I object to the Wollongong Coal's Revised Preferred Project Report
(PPR) to the Russell Vale Underground Expansion Project 09-0013. There
presents an endless maze of difficulties surrounding re-opening the
Russell Vale mine. This mine is in the Wrong Place at the Wrong Time.
The proposed expansions should not be approved for the following
reasons.

THE MINE IS IN THE WRONG PLACE

▪ 1. A risk to Greater Sydney Water Catchment

The Russell Vale expansion is located in the Water NSW Schedule 1
Special Areas, the primary purpose of which is to protect the water
quality and quantity of the drinking water. The State Enviro Planning
Policy for the Sydney Drinking Water Catchment 2011 states that "A
project have neutral or beneficial effect on water quality". How can
any mining project satisfy these requirements? There should be no
mining in water catchments ever, at all! Water is life.

Russell Vale Colliery is situated at the very foot of the escarpment
and mines under the escarpment and catchment. The sandstone cliffs of
the escarpment are well known to be unstable and already there have
been two major landslides at Mt Kiera. The intention to mine Triple
seam mining has little precedent and impacts are difficult to predict.
I imagine the interior of our escarpment to resemble a bee hive.
"In the Southern Coalfields, WaterNSW considers the greatest current
and historic risks to the Sydney water supply are posed by mining
operations beneath the Metropolitan and Woronora Special Areas."
(Water NSW submission to the Independent Expert Panel on Mining in
Sydney Catchment - Task 1 Matters May 2018)
Longwall mining has already resulted in shocking subsidence-induced
fracturing and consequent loss of valuable water in our water
catchments. The cumulative effects of previous mining in this area
cannot be quantified as it will continue indefinitely into the future
and even escalate after the mine closes down. Mining companies are
only required to provide modelling that predict possible effects into
the next ten years. Current modelling cannot accurately predict into
the far future, into the lives of our children and grandchildren.
We need to learn from past experience.
▪ 2. Inadequate modelling.
Even though companies and the government have been attempting for
decades to assess and predict the risks posed by undermining in the
catchment, any proposed predictive modelling has been deemed
inadequate.
"WaterNSW understands and accepts that uncertainty in predicting
impacts and consequences from mining on overlying catchments is
inevitable. It is misleading to report predicted impacts and
consequences as a single value with any degree of confidence, where
steep topographical features are undermined.
"4.4. Predictive Groundwater Modelling 
Groundwater in the
superficial and regional aquifers forms an important component of the
overall water balance for surface catchments across the Special Areas.
Groundwater sustains baseflows to streams, and on a local scale
supports (or partially supports) a variety of ecosystems, including
some upland swamps. WaterNSW's priority currently remains on
harvesting and protecting surface water resources.
4.4.3. Uncertainties in groundwater modelling
A primary source of uncertainty in groundwater impact predictions is
the nature and heterogeneity of the rock formations overlying the coal
seams. Although the sub-horizontally bedded strata of the Sydney Basin
have been extensively investigated by government authorities and
mining companies within their exploration and mining tenements, rock
formations are formed through complex natural processes and are
inherently heterogeneous at various scales.
In intact formations, the heterogeneity of hydrogeological flow fields
is largely controlled by the amount and orientation of fine-grained
materials within bedding planes which greatly affect horizontal
permeability rates, and fractures/faults and other discontinuities in
the rock, which largely control vertical permeability. The most
fundamental change and ensuing uncertainty regarding the
hydrogeological regime in the Special Areas is how much it is modified
by subsidence-induced fracturing following undermining. As discussed
in Section 2.2, the distribution and orientation of subsidence-induced
fracturing is not currently well understood and can't be accurately
predicted." (WaterNSW submission to the IEP- Task 1 Matters May 2018 -
p.26-28)

"some knowledge remains elusive, some things remain unknown and in
these circumstances precaution and damage avoidance is the best
strategy." (Water NSW Submission to the IEP -1. Initial task, May
2018, p.18.)

Wollongong Coal describes their method of rehabilitation as "adaptive
management". I interpret this to mean "see what goes wrong and then
we'll try to fix it." We are talking about loss of water and damage to
an ecological system that cannot be fixed. The only way to show
genuine precaution and damage avoidance is to stop mining in our
precious water catchments.

▪ 3. This mine is the closest mine to a residential area in
Australia.

This project will have significant and unacceptable social and
cultural impacts on nearby residents.

I live in Bellambi, a suburb a few minutes away from the entrance to
the Russell Vale Colliery. The suburbs here are quiet
communities......communities like Russell Vale, Tarrawanna and
Bellambi and our residents like it that way. I chose to live here to
get away from the hustle and bustle of inner city Wollongong life and
traffic. There are no high rises and only a few local businesses. Our
communities pride ourselves on our slower, quieter community lifestyle
and there are many cafes and neighbourhood centres that provide for
community engagement and activities. Russell Vale has a village
atmosphere. We thought the noise and coal dust was a thing of the
past. But now it is threatening to begin again.

Industry always devalues property and it is understandable why. When
Russell Vale mine was active, I watched as Bellambi Creek ran black
and fanned out into the sea. I remember the thin film of sludge on my
windscreen every day. My friend was always complaining about the coal
dust ..... on the washing and in the air...the smell of it on windy
days. Even now there is a thin film over everything that has to be
wiped down every day. The background noise of the coal trucks braking
was constant.

Bellambi Lane and Memorial Drive are the two major highways through
the area. From my house I can hear the noise of trucks and traffic. It
never stops. Apparently the mine proposal includes 32 coal trucks per
hour on local streets going down Bellambi Lane and Memorial Drive past
people's homes from 7am to 10pm. Traffic and the intrusive noise of
mining activity is not compatible with the way of life of these
communities and will impact on the health and well-being of residents.

I simply do not trust Wollongong Coal.The company has a woeful
history, both here and in India. When I googled the cities where the
coal will be transported I read about the charges of corruption and
environmental vandalism against Jindal Steel and Power Ltd (JSPL).
JSPL, via a holding company, JSPL Mauritius, is majority shareholder
in Wollongong Coal Ltd.

I was not confident with their community consultation process. As a
member of the Illawarra Knitting Nannas Against Greed I attended one
of their sessions. To my knowledge there were only two.....group
consultations. One with us and the other with Protect Our Water
Alliance. They held a meeting and an open day but not in the suburbs
that would be most affected or with the people who would be most
affected. In fact they said they letter boxed the local area but no
one in my street received a flyer or any kind of information. Friends
in Russell Vale have not received any recent notification either.

IT IS THE WRONG TIME TO RE-OPEN THIS COAL MINE

▪ Climate change and Green House Gas (GHG) Emissions
1. Any water loss to mining is a serious issue.
Water is already our most valuable asset. We are presently in drought.
The upland swamps, streams and dams of the Illawarra are already
struggling from faster evaporation due to global warming. As at 28
August 2019 the Cataract Dam was at 28.8 % capacity (Sydney Water). As
global warming continues to destabilise our weather, water will become
more and more precious. We cannot predict accurately how global
warming will effect our catchments into the future. To be taking risks
with our water supply is criminal. Why isn't mining in water
catchments illegal? There is a $44.000 fine for trespassing if people
go in there and yet mining companies are allowed in there knowing they
will cause damage to the catchment and compromising our water supply.
What fines do they have to pay?
2. GHG Emissions

It is not the time to be re-opening and expanding an existing coal
mine. Coal mining, whether for energy or steelmaking, produces the GHG
Emissions that are causing dangerous climate change.We have been told
by the IPCC that, to keep the global rise in temperate below 1.5
degrees, no new coal can be mined, processed and burnt. All the coal
from the Russell Vale Colliery will be shipped directly
overseas......to the East Coast of India, for processing and use. The
emissions produced, both upstream and downstream (especially scope 3
emissions ) must be considered. This project is estimated to result in
11.624,000 tonnes of GHG emissions.

3. Employment

As other countries are moving quickly to reducing emissions in
response to the climate change emergency, the demand and price for
coal overseas is falling rapidly. Therefore even if the mine were
re-opened for production the future longevity of demand and employment
would be insecure. Since the mine closed for maintenance, the previous
employees would have been absorbed into other areas and at present
there are only 29 people working there. With a future focus it would
be more ethical to be honest with the community and not deceive them
with hopes of permanent jobs.

Conclusion
As a resident of Bellambi, living 5 minutes from the entrance to the
mine, I 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.
Yours sincerely,

Ann Gadd

I am highly concerned about the expansion of this project. The mine is
too close to the dam and its risks to our water catchment area is too
great. as the recent dry conditions have demonstrated, fresh water is
a precious resource.

The proposed expansion appears to be undermining existing long the
wall. 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. from previous monitoring, subsidence has been demonstrated to
reduce water collection

It is contrary to public interest for the NSW government to allow such
risky mining in the water catchment for 5 million people of Greater
Sydney in a time of drought.

Wollongong coal has been through financial difficulties, I do not
trust their ability to cope with the liabilities of this operation.
furthermore, drinking water is priceless, and the potential damage is
irreversible.

As a resident of Greater Sydney, I object to the mine's expansion

Dear Sir/Madam

I object to to the Underground Expansion Project proposed by
Wollongong Coal beneath the Special Areas of Sydney's Water Catchment

In these difficult times of changing weather patterns which include
low rainfall where we live, and the clear evidence of climate change I
urge you to reject this application by Wollongong Coal to mine beneath
the Special Areas of Sydney's Water Catchment.

Whilst I am aware that after strong opposition to their original
proposals, Wollongong Coal Ltd. has for now abandoned its plan for
long-wall mining I am concerned about some of the features in their
new plan.

The mining is very risky because a 3rd seam of coal is being mined
beneath two previously mined seams.

Impacts of triple seam mining are difficult to predict and there are
no precedents or ways of knowing what might happen.

Wollongong Coal admits that instability in the overlayng old Bulli
seam workings may cause pillar collapse and subsequent subsidence of
1-2 meters.

Surely it must be contrary to public interest for the NSW Govt to
allow such risky mining in the water catchment which provides water
for 5 million people.

There is instability in the land around the proposal. It is described
as being in 'limiting equilibrium' or still moving having not
stabilised since Wollongong Coal mined long-walls 4, 5 and six several
years ago.

This project will further the loss of ground and surface water from
Cataract Reservoir and its catchment.

This expansion, if allowed to proceed, will have a large carbon
footprint.

The mine itself is currently in 'care and management' mode with 60
staff employed. In rejecting this application the impact on the
employment outlook for the Illawarra would be minimal.

Likewise since neither of Wollongong Coal's mines are operating
currently the flow on effect to the local economy, if the proposal was
rejected, would be negligible.

In terms of Wollongong Coal's proposal to build a processing plant at
the Russell Vale colliery - and process coal on site - this mine is so
close to a built up residential area and is not at all a suitable area
for coal processing.

There is the trucking of the coal too - Wollongong Coal have not
adhered to previous requests to protect the community and environment
- I note that they are promising similar things in the revised project
- they have NOT adhered to these requests before and are unlikely to
adhere to them under the revised project.

The local community, in every case, suffers from the failure of
companies, such as Wollongong Coal, to implement required standards.

In addition we the community are constantly having to put submissions
to the Department - companies, such as this one, have many consultants
to whom they can hand over the work - the rest of us go to work every
day, have families, live our lives as best we can, and on top of this
have to constantly put submissions to NSW Government over something
which should be totally rejected at the outset - indeed Wollongong
Coal parent company, Jindal Steel, 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.

Given these facts I urge your department to totally reject this
application for once and for all.

Yours faithfully
Theresa Huxtable

There are many reasons why the current proposal (like all the previous
ones from this proponent) should be refused.

1) The proponent has demonstrably and repeatedly failed to meet the
conditions of previous approvals. Notably the failures are ones which
would cost money to implement and predominantly have adverse impact on
neighbouring residents. The proponent should not be considered for any
future mining approvals until the conditions of all previous approvals
are completed.
2) The proposal involves yet another proposal for third tier mining
below two previous levels of extraction. Where such elements have
occurred via the piecemeal implementation of such mining by improper
approvals of modifications of preliminary works demonstrates that in
this geological formation, it has resulted in destabilising of the
overlying mined layers and surface features have not yet stabilised -
they are subject to movement. Any assertion that future third tier
mining will not result in similar movement is fanciful.
3) The proposal now encompasses the establishment of a coal processing
facility at the Russell Vale Colliery. Such activity by a repeatedly
non-compliant proponent in what is largely a residential area is
unacceptable.
4) Wollongong Coal is in serious breach of previous approvals among
the 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. No approval should be forthcoming
until all outstanding commitments have been fulfilled.
5) The economic worth of the proposal is massively overstated
6) the unacceptable level of trucking proposed is intolerable
7) The potential to impact the Sydney Water special areas is
unacceptable.

I believe that this proposal is without merit and should be refused.

Wollongong Coal's Revised Preferred Project Report to the Russell Vale
Underground Expansion Project:
Sutherland Shire Environment Centre objects to the Wollongong Coal's
Revised Preferred Project Report (PPR) to the Russell Vale Underground
Expansion Project 09-0013.

* Wollongong Coal and its parent company Jindal Steel and Power Ltd is
not a fit and proper entity to hold a mining licence.
The company has not been able to operate the mine for some five years.
It has a record of financial disputes with contractors and the NSW
Government. It has a qualified audit statement. Its financial reports
suggest it does not have the ability to recommence operations.
* History of Non-Compliance
Wollongong Coal has a history of non-compliance with conditions of
approval for mining. These include issues related to: truck loading
facilities, covered conveyors, stockpiles, sealed roadways and impacts
on Bellambi Creek.
* Risk to Sydney Water Supply.
Wollongong coal operates within the Special Areas of the Greater
Sydney Water Catchment.
WaterNSW has objected to the continuation of mining in this catchment
area. The impact on the water availability for dams is well
documented. Sydney is currently under water restrictions as the State
struggles with its worse recorded drought. The mining system proposed
is risky and the threat of excessive subsidence and loss of water from
reservoirs is difficult to predict.
To further risk the already stretched water supply is highly
irresponsible and should not be allowed
* Impacts on the local community
The mine site is very close to large residential communities. The
impact of noise, cola transport and particulate pollution will be
excessive and not acceptable. The proposal acknowledges there is risk
of serious flooding across residential areas from tailings dam and the
potential for reservoir water to access the mine workings.
* The risk factors outweigh any claimed economic benefits from this
mine.
As the mine is not currently in operation, any current economic
benefits are minimal. Claims for future economic benefits are wildly
exaggerated.
Rehabilitation of existing damage is a risk given the past history of
the company and the limited financial guarantees provided.

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.

I do not support the proposed Russell Vale Underground Expansion Project.

I am very concerned about the environmental impacts of the expansion,
particularly within the catchment area to surface waters, creeks and
to Cateract Reservoir.

Outlined below are some key issues or concern that need to be
addressed:

Destabilising overlying mines

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 contrary to public interest for the NSW government to
allow such risky mining in the water catchment for 5 million people of
Greater Sydney in a time of drought.(1)

The land around the proposed mining is unstable. The proposal states,
"It is noted that large areas of the surface within the UEP
Application Area are currently on the verge of moving as a result of
previous mining." [2] It is described as being in "limiting
equilibrium" - still moving, having not stabilised since WCL mined
longwalls 4, 5 and 6 several years ago. If the Special Areas of
Sydney's Water catchment are so special that ordinary people can't
even set foot on them without risking a $44,000 fine, they are special
enough that they should be protected from earth moving, destructive
mining.

Impact on ground and surface water

The project will further the loss of ground and surface water from
Cataract Reservoir and its catchment, adding 131 ML/year of ground
water and 10 ML/year of surface water to losses from previous mining
damage. This is estimated to bring the total ground and surface water
loss from the project to 298 ML/year. [3] This is the equivalent
annual water usage of 25,492 people. [4]

An additional 146 ML of "upgradient inflow" from surrounding mines -
the now "inactive" Cordeaux mine and Corrimal mine (not mined by
Wollongong Coal) - are draining water into WCL workings, bringing the
total to 444 ML/year.[5] This is the approximate water usage of 37,981
Greater Sydney residents.[6]

Following mining the void left will fill up with water. The water will
keep rising until it reaches the adit (mine portal) in the Illawarra
Escarpment in about 2057. The water will overflow through the adit and
the outflow will slowly increase, reaching 0.3ML (300,000 litres) per
day in 2179. WCL's modelling shows that the volume of water outflow at
the adit above Russell Vale will continue to flow, even beyond 2179.
[7] In other words, the project will result in escalating water
discharge from the adit for at least 160 years and probably longer.
The outflow will need to be managed and treated. Wollongong Coal is
proposing a commitment to manage and treat the water for 10 years.[8]

Greenhouse Gas Emissions

Although only a small project, the Expansion has a large carbon
footprint. WCL's consultants divide emissions into Scope 1, 2 and 3,
with 1 and 2 being the emissions produced in the mining and processing
of the coal and Scope 3 being emissions are "indirect emissions that
are a consequence of the activities of the reporting
entity but occur at sources owned or controlled by another reporting
entity"[9]. Scope 3 emissions are the largest volume of emissions, as
they involve use of the coal. The total CO2e emissions for the
project, from mining up to and including usage are approx. 11,147,000.
[10]

To put this in context, this is the equivalent to the annual emissions
of more than half a million Australians.
[11]

Economic case

The mine is currently in Care and Maintenance mode and only about 60
staff are employed. Therefore the impact on the employment outlook for
the Illawarra if this approval was not granted would be minimal.
Moreover, as neither of Wollongong Coal's mines are currently
operating the flow-on effects to the local economy if this proposal
was not approved would be negligible.

A coal processing plant on site at Russell Vale Colliery

Wollongong Coal plans to build a coal processing plant at the Russell
Vale Colliery and process coal on site.[12] 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.

Trucking

The coal is trucked along Bellambi Lane, past people's homes onto the
Northern Distributor to Port Kembla Coal Terminal. WCL's new expansion
proposal means more coal trucks on the busy Memorial Drive. There will
be an average of 16 laden trucks per hour, Monday to Saturday,
travelling to the port.[13] In other words, counting the return trip,
there will be 32 truck movements per hour, or one truck every 112
seconds. In addition to this there will be more coal trucks
transporting coal mining waste.[14]

A history of non-compliance with approval conditions

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.

In fact right now, Wollongong Coal is operating under three major
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.

It is of real concern that the proponent is proposing to put in place
pit top infrastructure after they have started mining. History shows
that operators of this mine are unwilling or unable to meet the
conditions of mining approval and the Department of Planning is
unwilling or unable to enforce compliance. In every case the local
community suffers from the failure to implement required pit top
infrastructure.

The suitability of the proponent

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.

In India, corruption charges are being framed against Naveen Jindal,
Chairman of Jindal Steel and Power Ltd (JSPL). JSPL, via a holding
company, JSPL Mauritius, is majority shareholder in Wollongong Coal
Ltd. [14]

Moreover, here in Australia, 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. Operating a coal mine
in the water catchment of Australia's largest city is risky business.
The NSW Resources Regulator started investigating whether Wollongong
Coal was a "fit and proper" entity to hold a mining license in
2016...... and it's still investigating...... Isn't it about time the
Resources Regulator reached a conclusion? And shouldn't any
consideration of an expansion of operations be postponed until after a
conclusion has been reached.





REFERENCES

[1] Russell Vale Revised Underground Expansion Project 3687_R05 RtPAC
Second Review FINAL Revised Preferred Project Environmental
Assessment, p. 62
Accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[2] ibid, p 63
[3] Russell Vale Colliery Underground Expansion Project, Russell Vale
East first workings, Groundwater assessment, Geo terra, NRE16 - R1D,
11 July, 2019, p. 96 accessed at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[4] Based on water consumption of 306 litres per person per day, cited
in Sydney Water Conservation Report 2017/2018, accessed at
https://www.sydneywater.com.au/web/groups/publicwebcontent/documents/document/zgrf/mdq3/~edisp/dd_047419.pdf
[5] Geo terra 2019, op cit, p. 63
[6] Sydney Water Conservation Report 2017/2018, op cit 8[7] Geo terra,
2019, op cit, pp. 96-97
[7] Russell Vale Revised Underground Expansion Project, op cit, p. 172
[8] ibid, p. 158
[9] ibid, p. 133
[10] Greenhouse Gas and Energy Assessment 3687_R08_GHG Report_Final
Impact Assessment Results p. 7
accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[11] Australians annually are responsible for about 21.528 tonnes of
CO2 per person (based on 538.2 mt CO2 emissions year to Dec 18 as
cited at
http://www.environment.gov.au/climate-change/climate-science-data/greenhouse-gas-measurement/publications/quarterly-update-australias-nggi-dec-2018)
and population of 25 million)
[12] Russell Vale Revised Underground Expansion Project, op cit, p. 9
[13] TRAFFIC AND TRANSPORT IMPACT ASSESSMENT FOR RUSSELL VALE COLLIERY
REVISED UNDERGROUND EXPANSION PROJECT AT RUSSELL VALE RESPONSE TO PAC
SECOND REVIEW REPORT, p 5 accessed at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf
[14]
http://www.newindianexpress.com/nation/2019/jul/01/delhi-court-orders-framing-of-charges-against-naveen-jindal-and-four-others-in-coal-scam-case-1997865.html

I object to further coal mining at this time, over 30 years since we knew
we must reduce our carbon emissions.

I object on the grounds the risk of the proposed mining under Sydney's
drinking water supply is reckless and should not be permitted.

James Dagher
Civil Engineer

Special Areas are intended to be a pristine environment that protect
the quantity and quality of the drinking water of residents in the
Greater Sydney region.

The proposed mine extension at Russell Vale is located in an area that
has the potential to have a critical impact on the Sydney Drinking
Water Catchment - with risks of water losses to the catchment - and
risks to our water quality (1).

Of note with this proposal is that a third seam of coal is planned to
be mined underneath two previously mined seams - the area is already
unstable.

The potential for further subsidence and damage from subsidence caused
by this mining is likely - even Wollongong Coal admit the mine may
cause pillar collapse and subsidence of 1-2 metres (2). This will
result in significant environmental consequences in a highly sensitive
area. The proposal represents a particular threat to the `Special
Area' around Cataract Reservoir and will result in further the loss of
ground and surface water from the Reservoir and its catchment.

Currently the total ground and surface water loss from the project is
estimated at 298 ML/year (3). The annual equivalent water usage of
25,492 people (4).

The void left by these new mines will also fill up with water,
including "inflow" from surrounding mines - the now "inactive"
Cordeaux mine and Corrimal (5). This water will reach the mine portal,
and flow out. This outflow will need to be managed and treated for at
least 160 years (6). Wollongong Coal has said they will manage and
treat the water for 10 years only (7).

Wollongong Coal have a record of non-compliance. Both 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 as whether they are a `fit and proper' entity to hold a
mining license. In India, corruption charges are being framed against
Naveen Jindal, Chairman of Jindal Steel and Power Ltd (JSPL). JSPL,
via a holding company, JSPL Mauritius, is majority shareholder in
Wollongong Coal Ltd (8).

Sydney's drinking water should not be jeopardised in this way. This
mining company has not shown it is able to comply with the
environmental conditions required to protect the Sydney catchment
area.



1. Russell Vale Colliery Underground Expansion Project Second Review
Report March 2016
https://www.smh.com.au/cqstatic/gnw5hv/russellvale2.pdf

2. Russell Vale Revised Underground Expansion Project 3687_R05 RtPAC
Second Review FINAL Revised Preferred Project Environmental
Assessment, p. 62
Accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf

3. Russell Vale Colliery Underground Expansion Project, Russell Vale
East first workings, Groundwater assessment, Geo terra, NRE16 - R1D,
11 July, 2019, p. 96 accessed at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf

4. Based on water consumption of 306 litres per person per day, cited
in Sydney Water Conservation Report 2017/2018, accessed at
https://www.sydneywater.com.au/web/groups/publicwebcontent/documents/document/zgrf/mdq3/~edisp/dd_047419.pdf

5. Russell Vale Colliery Underground Expansion Project, Russell Vale
East first workings, Groundwater assessment, Geo terra, NRE16 - R1D,
11 July, 2019, p. 63 accessed at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf

6. Russell Vale Revised Underground Expansion Project, 3687_R05 RtPAC
Second Review FINAL Revised Preferred Project Environmental
Assessment, p. 172 Accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf

7. Russell Vale Revised Underground Expansion Project, 3687_R05 RtPAC
Second Review FINAL Revised Preferred Project Environmental
Assessment, p. 158 Accessed 18.8.19 at:
https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf

8.
http://www.newindianexpress.com/nation/2019/jul/01/delhi-court-orders-framing-of-charges-against-naveen-jindal-and-four-others-in-coal-scam-case-1997865.html