Tahmoor South Coal Project

I completely support the proposed submission

As a Wollongong University student and member of the youth community, I
support Tahmoor South as it will provide jobs to the future generation

The importance of this mine extension to the Wollondilly region and wider
community is immense. The positive contribution this operation is
significant to the large workforce to whom are provided reliable
income and family security, and also the stakeholders outside of the
business that perform work or supply materials to this operation.

Abiding by the strict environmental conditions, this extension should
go ahead for Tahmoor Coking Coal to continue supporting the
Wollondilly and wider region for years to come.

The Tahmoor South Project will:
* Extend the life of mine for Tahmoor Coal until approximately 2035;
* Secure the ongoing employment of the current workforce;
* During the construction phase of the project, employment of
approximately 50 to 175 additional people will be required;
* The project will result in a net benefit to NSW of $699.5 million;
and
* a net benefit of up to $139.5 million to the local Wollondilly
region

I believe this project will support the local businesses in the
Wollondilly and create and maintain local jobs for 20 to 30 years.

I would like to support Tahmoor South Coal Project. As a resident of the
Wollondilly Shire, a local resident and an employee of Tahmoor Coking
Coal operations.
This extension to the mine will not only extend the life of the mine
until approximately 2035, but it will secure ongoing employment for
the current workforce, new workforce and myself. Having worked at the
mine for the past 29 years and living in the Wollondilly Shire for
over 20 years I have seen the growth of the Township of Tahmoor and
surrounding areas and the benefits the mine has had on the community,
residents and shop owners. Without the ongoing support of the mine,
sporting organizations, businesses and the community would truly
suffer.

The general community feel is in support, the mine has been operating for
many years, it provides support to local business and the community
It will also provide more jobs to the area, which will in turn sustain
the economic development of this area

I was born in this area, my many friends and family have worked at the
mine, it provides the community with a good income and support.
Our whole family depend on this mine, they do their best for the
community and the environment.
Extending the life of this mine is important to our area

I am writing a submission in support of this project.

I am currently an employee of SIMEC Mining - Tahmoor Coking Coal
Operations. I believe there are numerous benefits to this project.
These include:
- Tahmoor continuity in mining. Mining has a strong history within the
Wollondilly area. This mine is one of the major employers within the
area and it supports many local businesses and organisations.
- Community Donations - Tahmoor Coal has a longstanding history of
supporting many schools and not for profits within the local area.
This will continue to occur if mining is to continue
- State Revenue - this project will result in a net benefit to NSW of
$699.5 million

Extend the life of mine for Tahmoor Coal until approximately 2035

The Tahmoor South EIS is a comprehensive and excellent look into the
potential issues for the project.

The project has address the community concerns for the area and should
be approved.

The Tahmoor South Project will:
* Extend the life of mine for Tahmoor Coal until approximately 2035;
* Secure the ongoing employment of the current workforce;
* During the construction phase of the project, employment of
approximately 50 to 175 additional people will be required;
* The project will result in a net benefit to NSW of $699.5 million;
and
* a net benefit of up to $139.5 million to the local Wollondilly
region

The Tahmoor South EIS valuable and well thought out document. It shows
attention to detail and address issues and concerns as raised by the
community.

The Tahmoor South Project will:
* Extend the life of mine for Tahmoor Coal until approximately 2035;
* Secure the ongoing employment of the current workforce;
* During the construction phase of the project, employment of
approximately 50 to 175 additional people will be required;
* The project will result in a net benefit to NSW of $699.5 million;
and
* a net benefit of up to $139.5 million to the local Wollondilly
region

Based on the above reasons the project should be approved.

secure the ongoing employment of the current workforce

A net benefit of up to $139.5 million to local Wollondilly region

THE PROJECT WILL RESULT IN A NET BENEFIT TO NSW OF $699.5 MILLION;AND UP
TO $139.5 MILLION TO THE LOCAL REGION

This project will extend the life of this operation for another 13 or
more years beyond the operations current mining approval

The project secures the future of the current workforce, will provide
additional employment during the construction phase, continues to
support the local Wollondilly community and continues to engage local
suppliers and businesses through operational requirements

Tahmoor Coal remains an important employer located between Sydney's
South West and the Southern Highland areas

Tahmoor has been supporting jobs in the region and has been a good
employer for many families in the region.
Its is an extension of existing operation thus with minimal impact on
environment.

Tahmoor Coal mine over its life has provided generational benefit to the
personnel involved in the operation of the mine, the local community
and the state of NSW.
Tahmoor Coal operating Tahmoor Colliery is a responsible and
sustainable state and local community stakeholder. An opportunity
exists to extend the life of the mine and to continue to provide
ongoing support and benefit to the mines employees and the local
community.
The contents of the EIS display that Tahmoor Coal can deliver the mine
extension safely and sustainably.

22 February, 2019

Ms Carolyn McNally
Secretary
NSW Department of Environment and Planning
GPO Box 39,
Sydney NSW 2001

Dear Ms McNally,

RE: Tahmoor South Coal Project - SSD 17_8445

The National Trust of Australia (NSW) lodges a strong objection to the
State Significant Development Application for the Tahmoor South Coal
Project - Extension of Underground Mining. The National Trust of
Australia (NSW) is a neighbour to the project, being the owner of the
property at 3105 Remembrance Driveway, Bargo where the Wirrimbirra
Sanctuary operates, an area of approximately 95 hectares of bushland
directly south of the Tahmoor Coal Mine surface facilities site.

This property is listed on the NSW State Heritage Register for its
flora and fauna values and for its historical role in the development
and promotion of the understanding and appreciation of Australian
native flora and fauna. We note that, as this is a State Significant
Development, the NSW Heritage Council is reduced to an advisory role
in the Development Approval process.

On 26 October, 1973, an area of 44.19 hectares at Bargo, vested in The
National Trust of Australia (NSW), being portions 18, 19 and 33 in the
Parish of Bargo, were dedicated for the public purpose of "promotion
of the study and conservation of native flora and fauna" under the
Crown Lands Consolidation Act, 1913.

The National Trust of Australia (NSW) was notified by letter dated 19
February, 2015 that the registration of a Conservation Agreement
between the Minister administering the New South Wales National Parks
and Wildlife Act (1974) and The National Trust of Australia (NSW) was
complete in respect of Lot 132 DP 130897 and Lot 1 DP 789005 at Bargo.
The Conservation Agreement provides that "The Owner and the Minister
agree to take steps to protect and manage the conservation values of
the Conservation Area as set out in Annexures B and C. Annexure C sets
out the management scheme for the Conservation Area and one of the
activities not permitted in the Conservation Area is "any works which
will adversely affect the natural flows and bodies of water."

The Trust has reviewed the Environmental Impact Statement (EIS) and
its supporting documents, including:
* Environmental Impact Statement (EIS); by AECOM;
* Biodiversity Assessment Report; by Niche Environment and Heritage;
* Historical Heritage Report; by Niche Environment and Heritage;
* Subsidence Predictions And Impact Assessments Report; by Mine
Subsidence Engineering Consultants Pty Ltd (MSEC); and
* Conceptual Mine Closure Plan; by SLR Consulting Australia Pty Ltd.

All of these are substantial documents, the presentation and
arrangement of which are not conducive to their being easily
appreciated and understood. While all of these documents, as expected,
provide a basis for proceeding with the project, there are a number of
points contained in them about which the Trust takes issue. These
include:

* The Subsidence report clearly identifies that there will be
subsidence impacts to the land within Wirrimbirra Sanctuary. Amongst
other impacts, it predicts that a ground cracking and movement may
drain the existing natural watercourse through the property. As an
intermittent watercourse, it is suggested that any loss of flow (or
mineralised ground water contamination, the other `likely' adverse
impact) will not have a substantive impact, as the surrounding flora
and fauna is adapted to intermittent water supplies. The Trust
suggests that this is naive and wrong-headed, as clearly, the local
ecology is more highly dependent upon the intermittent flows and any
loss of flow is likely to have an increased impact, not a lesser one.
* The Biodiversity Assessment Report clearly identifies that there
will be negative impacts upon:
o An identified Critically Endangered Ecological Community, the Shale
Sandstone Transition Forest.
o Threatened Flora Species: the Persoonia bargoensis and Grevillea
parviflora
Close reading of the report also identifies that there is a lack of
information regarding fauna species inhabiting the area and that, in
the light of this lack of information, no negative impacts can be
identified. This is a very unsatisfactory outcome. For example, no
koalas were seen during the fauna survey, consequently, no impacts
could be suggested. The National Trust's long involvement with this
property suggests that koalas, possums, gliders, wallaroos and wombats
are all present in the area and that the further shrinking of
available habitat can only be considered to be a negative impact. The
Biodiversity Assessment Report is focussed on the assessment of
species listed as endangered or threatened - it makes no real attempt
to assess the impact upon the general biodiversity of the region.
* There is no attempt to assess impacts upon soil biology, upon insect
and microfauna, upon eco-systems overall and no consideration of
cumulative impacts.
The proposed strategy to mitigate the admitted adverse impacts is to
establish Biodiversity Stewardship Agreements over five other areas of
land in the vicinity (none of which are contiguous) owned by Tahmoor
Coal - ie the mining company will commit not to destroy other areas of
land that it owns. This would be supplemented by purchase of
Biodiversity Credits from the Public Register and a one-off payment
into the NSW Biodiversity Offsets Fund.
Without commencing a detailed critique of the concept of bio-banking
(a separate issue of concern), the Trust notes that several of these
parcels of land are associated with airshafts for underground mining
or are left-over areas sandwiched between existing mine operation
areas and are themselves likely to be affected by subsidence, whilst
another is mostly cleared farmland (which will be `encouraged' to
regenerate). It is the Trust's contention that this is grossly
inadequate and that monetary contributions to Offset Funds amount to
no more than a payment-to-destroy, which the Company can clearly
afford from the expected profits from the mining activity.
In relation to Wirrimbirra specifically, the Trust notes that the
consultant's report states on page 50:
7.3 Other Items
The historical ruins within the Wirrimbirra Sanctuary have been noted
to be in poor condition and their contribution to the significance of
the Sanctuary is not well understood. It was not possible to assess
their condition or historical associations as part of this Project due
to time and access restrictions. The heritage structures including a
course or two of sandstone foundations stones and a shallow well are
unlikely to be affected.
The natural features of the Sanctuary including the `Bargo Bush' are
of heritage significance. There will be detrimental effects on the
stream until it is remediated. Teatree Hollow is expected to
experience fracturing of bedrock and draining of pools at times of low
flow. The wider proportion of the bushland will largely be unaffected
by the proposed works.
As discussed in Section 8.2, a detailed management plan for
Wirrimbirra Sanctuary will be prepared for the required subsequent
Extraction Plan approval. Anderson's Inn has not been included in
Table 7 as the item has been demolished and no longer exists.
The Trust can state that it was never approached by the consultants
for access to Wirrimbirra Sanctuary. A staff member for the
consultants did acquire basic information about the property from the
Trust's archives in 2013 and we presume that the information presented
in the report is based upon this single occasion. The impacts upon the
bushland are admitted but dismissed as they will be "remediated". No
arrangement for access, much less `remediation' activity, within the
National Trust's property has been negotiated - in fact, no-one has
approached the Trust in this regard.
The Trust notes the third point that a detailed "management plan" will
be prepared after approval has been given for the project. This is a
completely unacceptable approach for a State-significant area, when
potentially significant ecological impacts are proposed.

Overall, the Trust objects to the proposed development as having
potentially serious ecological effects. It objects on the grounds that
the process on which the assessments and proposed mitigations have
been carried out is flawed and on the grounds that, as a stakeholder
and neighbouring property owner specifically affected by the proposed
development, the Trust has been ignored and treated as irrelevant to
the development.

Yours sincerely,

Graham Quint
Director, Conservation

Please see attachment for my submission.