Vickery Mine Extension

I object to an extension of the Vickery mine because of the negative
impact it will have on water resources. River and groundwater systems
are already under pressure from extractive industries. The result is
plain to see in the Murray - Darling basin. We do not need more coal.
We do need water.

+Please find my submission on behalf of myself,my husband, Russell and
sons Phillip and Daniel.
My name is Julie Heiler and my family live and family work and live on
the properties 'Brighton' and 'Roma'. Russell's grandfather selected
'Greentree' in 1900 and were founding members of Boggabri #1 Rural
Fire Brigade and continue this involvement and strong ties with our
community today.
We strongly object to the approval of the Vickery Extension Project
AND STRONGLY URGE that after proper, genuine and realistic
consideration is given this project will be totally rejected.
Our district has lost over 70 farms and families and we are sadly only
one of two on the eastern side of the Iron Bridge
The claims that the establishment of Whitehaven's State Significant
project will give future generations real opportunities to live, work
and prosper together in a viable sustainable local economy and
community is unsubstantiated and unbelievable, not to mention an
insult to our intelligence!
The loss of productive farmland, their families and associated loss of
Community involvement, positive participation,and support is not
condusive to a strong, vibrant,viable community moving forward to a
long, economic and socially sustainable future and this needs to be
recognized and addressed.
Canyon, White haven's original mine, created no community issues and
for the first years of Boggabri Coal and Tarrawonga
led us to believe that agriculture and mines could co-exist but the
ongoing modifications, extensions and the approval of Maules Creek
Mine has created unacceptable cumulative effect of dust, noise,
blasting impact on our infrastructure, the negative impact on our
water, flood patterns and not forgetting our health and mental well
being and can not be expected to be acceptable.
The introduction of another mine including a washery and so called
borefields on our flood plain will just increase the already negative
pressure on an already depleted community resource.
We have been negatively impacted by the continual pumping ofthe
Victoria Park Bore one of Boggabri Coals Borefield supplies which
start pumping in January this year, since mid March our over 80 year
old reliable bore has dropped from six and half feet to two and half
inches and remains at that level up to now, the mine has been carting
water each week to our dam for the cattle since April, but this is a
bandaid not a solution.We also lost water capacity in our production
bore resulting in loss of yield and income from our cotton
crop.Irrigation was our drought proofing strategy and water is
essential to our enterprise and its financial survival.Shame the
Modelling let us down again but then I can't imagine why any one is
stupid enough to trust an assumption but to gamble with our livelihood
is unforgivable.
The risk of this approval to the Namoi River is unacceptable, it is
not just our river but the lifeblood of all those downstream for stock
and domestic use many who don't have any backup access to ground
water. We and many others believe that the State Significance of the
Namoi far outweighs that of a coal mine and the loss of the river
would have far reaching devastating effect on NSW's economy and
environmental survival,
Whitehaven does not deserve or has been given the Social Licence to
operate in our Valley. They do not acknowledge the negative impacts
they have created, take no responsibility and show no interest in
working with the Community or Neighbours to find some sort of mutually
acceptable solution. to the issues.
Our Community is continuing to experiences unresolved social impacts
As a Community we are experiencing many negative social
impacts and it is unrealistic to approve another mine to add to the
already existent problems.
THE APPROVAL OF THIS EXTENSION IS NOT IN THE BEST INTEREST OF OUR
COMMUNITY, IT REPRESENTS A THREAT TO OUR AQUIFERS AND THE NAMOI RIVER.
AND WILL POTENTIALLY REDUCE THE THE AIR QUALITY HEALTH AND WELLBEING
OF OUR RESIDENTS.
The drought is considered a major threat to farming and small
communities but drought is part of Australia and our lives and each
day we are closer to rain but the
biggest threat to our community is the ongoing insidious expansion of
the mines resulting in an uncertain future with which we have no
experience or proven strategies to protect us and a Government that
has forgotten their DUTY OF CARE to all Australians.This is you
opportunity to make a difference please don't waste it.
Please accept this submission is incomplete due to time constraints
and the drought, extra time would have been appreciated
Yours Faithfully
Julie Heiler
to our future.

I Object to the mine.

OBJECT to the very short timeframe you've had to prepare your
submission, 42 days is not long enough.

COAL RAILWAY AND RAIL LOOP: No modelling has been provided as to the
movement of surface water once the railway is constructed, and there
are inadequate details of the construction of the 14 km rail spur.
There are inadequate indications of what sections will be elevated,
and which will be embankments.

"The final vertical alignment of the rail and the sizing of the
openings (bridges and culverts) will be determined during the detailed
design stage."- Appendix C Flood Assessment, page 38.

This has very serious ramifications for flood risks and makes it
impossible for anyone to make an informed submission.

Further, according to the Dept of Planning, "this is a flood modelling
much different than other developments... without explicitly stating
where each structure is.... It's certainly a key issue." [Source:
Stephen O'Donoghue, Team Leader, Resources Assessments, Golf Club
meeting 26th Sept 2018]

I do not have confidence in modelling which is based on such vague
assumptions, with no details about where each structure is.

The rail loop itself is too close to the Namoi River and the riparian
vegetation and koala habitat will be lost.

The community has been living under the assumption that there would be
no Namoi River crossing associated with this project, since Whitehaven
Coal was advised the Commonwealth of the Environment that a river
crossing would not be acceptable under the Environmental Protection
and Biodiversity Conservation Act.

The coal railway is one of the most serious concerns about this
Vickery project.

Biodiversity - koalas: The entire locality where the Vickery mine is
intended to be built is prime koala habitat, including the area where
the rail loop is to be built.

Koalas are listed as an endangered species under NSW and Commonwealth
legislation. I do not believe that any mitigation measures, such as
relocation of the local koala population can be viable because
alternative habitat is being destroyed throughout NSW and in any case
relocating koalas is known to have a high failure rate.

Impacts on the Koala have also been understated because of
insufficient consideration of impacts upon the full extent of suitable
habitat within the Approved Mine area. Like other cumulative impacts,
the effects on koala habitat have been dealt with poorly in the EIS.
There does not seem to be any limit of the extent of impact being
considered and matters in relation to landscape impacts have not been
considered adequately.

Right now, some of the most important and large nearby koala habitat,
being Vickery State Forest and Leard State Forest are either being
actively destroyed by coal mining, or else they are slated for
destruction in the medium-term.

I am a retired teacher who has grandchildren for whom I worry. The
environment they will be left with, if we do not stop this now, will
be unliveable.

Coal is dangerous. To mine, to ship, to process and to burn. It should
be made illegal to start any new coal mines.

As far as the COAL RAILWAY AND RAIL LOOP is concerned no modelling has
been provided as to the movement of surface water once the railway is
constructed, and there are inadequate details of the construction of
the 14 km rail spur. There are inadequate indications of what sections
will be elevated, and which will be embankments.

"The final vertical alignment of the rail and the sizing of the
openings (bridges and culverts) will be determined during the detailed
design stage."- Appendix C Flood Assessment, page 38.

This has very serious ramifications for flood risks and makes it
impossible for anyone to make an informed submission.

Further, according to the Dept of Planning, "this is a flood modelling
much different than other developments... without explicitly stating
where each structure is.... It's certainly a key issue." [Source:
Stephen O'Donoghue, Team Leader, Resources Assessments, Golf Club
meeting 26th Sept 2018]

I do not have confidence in modelling which is based on such vague
assumptions, with no details about where each structure is.

The rail loop itself is too close to the Namoi River and the riparian
vegetation and koala habitat will be lost.

The community has been living under the assumption that there would be
no Namoi River crossing associated with this project, since Whitehaven
Coal was advised the Commonwealth of the Environment that a river
crossing would not be acceptable under the Environmental Protection
and Biodiversity Conservation Act.

The coal railway is one of the most serious concerns about this
Vickery project.

As far as the Koalas are concerned: The entire locality where the
Vickery mine is intended to be built is prime koala habitat, including
the area where the rail loop is to be built.

Koalas are listed as an endangered species under NSW and Commonwealth
legislation. I do not believe that any mitigation measures, such as
relocation of the local koala population can be viable because
alternative habitat is being destroyed throughout NSW and in any case
relocating koalas is known to have a high failure rate.

Impacts on the Koala have also been understated because of
insufficient consideration of impacts upon the full extent of suitable
habitat within the Approved Mine area. Like other cumulative impacts,
the effects on koala habitat have been dealt with poorly in the EIS.
There does not seem to be any limit of the extent of impact being
considered and matters in relation to landscape impacts have not been
considered adequately.

Right now, some of the most important and large nearby koala habitat,
being Vickery State Forest and Leard State Forest are either being
actively destroyed by coal mining, or else they are slated for
destruction in the medium-term.

The Vickery mine extension Environmental Impact Assessment should be
rejected.

I believe that the Vickery mine poses the risk of irreversible harm to
the Namoi River and the surrounding surface water and groundwater
systems.
It will damage the health and well-being of human populations in the
Boggabri region.
It will damage the habitat of the endangered koala and the
Commonwealth-listed Murray Cod.

1.
I believe that the relatively short Public Exhibition period has
compromised the right of the public to comment on this important State
Significant Development and is an incorrect decision by the Minister
for Planning who refused to extend the Public Exhibition to 90 days to
allow more expert consideration and community comment.

2.

The Gunnedah Basin in the vicinity of Boggabri is also the location
for 22 Million Tonnes per Annum of Approved coal mining. The 10 MTPA
proposed Vickery mine is surrounded by other Exploration Licences
which will, in the course of time, be sought to be developed,
including a licence which covers the Vickery State Forest itself.

Vickery Coal Mine Extension is another megamine the scale of Maules
Creek, and in close distance from the Leard Forest Coal Mining
precinct. Yet the EIA does not make any attempt to apply the
Precautionary Principle to its assessment of the cumulative impacts.
There are many examples where the EIA has ignored or misstated the
cumulative impacts. Eg locals are already badly affected by blasting
vibrations and dust from Whitehaven's Rocglen and Tarrawonga mines.
This is not alluded to in the EIA. The EIA also is misleading about
the distance between Vickery and Tarrawonga, stating they are 11km
apart when in fact there is just 4km distance between Tarrawonga and
the proposed Vickery borefield.

In view of pre-existing concerns about dust from the Leard Forest coal
mines, I am of the view that cumulative impacts of dust pollution and
the risk to the health of communities in the Gunnedah Basin are not
adequately assessed.


3.

The detrimental social impacts of the mine includes health and
well-being, including physical and mental health. According to the
Social Impact Assessment, existing local mining operations form part
of the basis of assessment. Many impacts are not quantified, such as
for example the effect of mine noise on sleep disturbance and quality
of life is completely ignored in the Social Impact Assessment, yet
widely known since a very large number of Boggabri and Maules Creek
residents lodged moving objections to the Maules Creek noise
modification last year.

Health

The Social Impact Assessment does not refer to the growing evidence
about rising bronchial ill-health in Boggabri and Narrabri towns,
reported anecdotally by GPs, and is consistent with health problems in
the Upper Hunter Valley. The reported increase in bronchial
medications has occurred since the time of the Maules Creek mine, and
Boggabri extension. Furthermore I am exceptionally disappointed that
the recently established Namoi Air Quality Monitoring System does not
incorporate dust monitoring in or near the town of Boggabri.

Mental health

The SIA makes much of the fact that "anxiety" is a national problem.
However, I believe that anxiety in coal-affected communities is based
on real triggers that emanate directly from the coal mining industry.
Examples include:

* The threat of loss of livelihood and property rights
* Dividing neighbor against neighbour is a common tactic of Project
Delivery personnel to break down a bloc of landowners who deny access
to their land
* Night-time noise and sleep disturbance is bound to result in some
anxiety

Therefore, to blame the anxiety in coal-afflicted communities on a
general national mental health problem fails to properly assess mental
health impacts of the Vickery coal mine itself on the local community.

Loss of farming families from the region

Over 70 farms have been sold to coal mines in the area around the
Boggabri and Maules Creek region. This has caused leakage of long-term
resident population and replaced them with tenants in the most part,
many of whom do not bring their families with them. Many more tenants
are employees of the mines, and do not farm. Farming land is either
grazed by arrangement with other parties, or left unfarmed, often
because the property has been deemed a biodiversity offset.

Community groups such as the NSW Rural Fire Service, the Country
Women's Association, Meals on Wheels, etc suffer due to the decline in
permanent residents.

This has led to a downward economic spiral in Boggabri.

Employment forecasts unreliable due to the prevalence of drive-in,
drive-out workers

It is a well-observed fact that even mine staff who have an address in
Boggabri are Drive-in, Drive-out workers. They tend to leave their
families in places such as the Hunter Valley towns, and commute weekly
to their work. This has not been addressed in the SIA. Boggabri has
not received an influx of population, and Whitehaven are understood to
encourage workers to live in Gunnedah instead, adding to road traffic.


4. Threats to the town of Boggabri

Boggabri is a town in slow decline, despite the assurances that were
made by the coal industry when the Maules Creek mine was being
proposed that prosperity would come.

Despite strong support in the community for a dust monitor in the town
of Boggabri, which is supported by Boggabri Coal (Idemitsu Resources),
Whitehaven has opposed this plan. Although a Dept of Planning
representative recently blamed this on the NSW EPA, there is written
evidence that Whitehaven refused to support the Boggabri dust monitor
unless it were paid for by the NSW Government.

Loss of population has an impact on housing occupation levels.

The CIVEO worker camp benefits to Boggabri are overstated - CIVEO
never patronized the Boggabri butcher, for example, and bought their
meat from elsewhere.

Businesses in Boggabri have not seen the benefit from decade of coal
mines, if anything the reverse has happened. Only one pub out of three
remains in operation.

There is no child care centre and furthermore Whitehaven Coal
approached Narrabri Council and advised them not to invest in child
care in Boggabri, which is a disincentive to young families who may
wish to relocate there. Community bitterness surrounding the child
care centre has caused extreme distress to the Boggabri Business and
Community Progress Association, which strives to secure the survival
of the town.


5. Noise

The Noise Impact Assessment has extremely significant ramifications
for the surrounding community, with impacts that will extend to the
town of Boggabri, based on my knowledge of other coal-affected towns
such as Wollar and Bulga, which are being gradually depopulated due to
mine encroachment and noise issues.

The construction of a coal handling and processing plant at the
Vickery coal mine is an additional threat, as it will produce
unacceptable levels of low-frequency noise. This is well-known to
occur, and is well-documented that CHPPs produce highly disturbing
noise in the 16-25Hertz range. Whitehaven's Maules Creek coal mine has
intractible noise problems at the 50 Hz frequency.

In addition, the Noise Impact Assessment is lacking an All Years Worst
Case Scenario, and fails to include key noise producing infrastructure
in its modelling.

I do not find it credible that the 10 MTPA mine will be quieter than
the 4.5MTPA version that was previously approved in 2015.


6. Coal railway and rail loop

No modelling has been provided as to the movement of surface water
once the railway were to be constructed, and inadequate details of the
construction of the 14 km rail spur. There are inadequate indications
of what sections will be elevated, and which will be embankments.

"The final vertical alignment of the rail and the sizing of the
openings (bridges and culverts) will be determined during the detailed
design stage."- Appendix C Flood Assessment, page 38.

This has very serious ramifications for flood risks and makes it
impossible for anyone to make an informed submission.

Further, acccording to the Dept of Planning, "this is a flood
modelling much different than other developments .. without explicitly
stating where each structure is.... It's certainly a key issue."
[Source: Stephen O'Donoghue, Team Leader, Resources Assessments, Golf
Club meeting 26th Sept 2018]

I do not have confidence in modelling which is based on such vague
assumptions, with no details about where each structure is.

The rail loop itself is particularly too close to the Namoi River and
the riparian vegetation and koala habitat will be lost.

The community has been living under the assumption that there would be
no Namoi River crossing associated with this project, since Whitehaven
Coal was advised the Commonwealth of the Environment that a river
crossing would not be acceptable under the Environmental Protection
and Biodiversity Conservation Act.

The coal railway is one of the most serious concerns about this
Vickery project.


7. Biodiversity - koalas

The entire locality where the Vickery mine is intended to be built is
prime koala habitat, including the area where the rail loop is to be
built.

Koalas are listed as an endangered species under NSW and Commonwealth
legislation. I do not believe that any mitigation measures, such as
relocation of the local koala population can be viable because
alternative habitat is being destroyed throughout NSW and in any case
relocating koalas is known to have a high failure rate.

Impacts on the Koala have also been understated because of
insufficient consideration of impacts upon the full extent of suitable
habitat within the Approved Mine area. Like other cumulative impacts,
the effects on koala habitat have been dealt with poorly in the EIS.
There does not seem to be any limit of the extent of impact being
considered and matters in relation to landscape impacts have not been
considered adequately.

Right now, some of the most important and large nearby koala habitat,
being Vickery State Forest and Leard State Forest are either being
actively destroyed by coal mining, or else they are slated for
destruction in the medium-term.


8. Road Transport

The Road Transport Assessment uses survey data collected in 2012 which
is outdated. It predates the establishment of the Maules Creek coal
mine, the extension of the Boggabri and Tarrawonga mines.

There has not been a thorough assessment of road usage or an
up-to-date road traffic audit identifying cumulative impacts.

Road transport since 2012 has grown dramatically, including mine
workers, transportation of heavy plant and equipment, and increased
road haulage of coal from Tarrawonga mine which gained approval
subsequent to 2012. These are not accounted for in the Vickery Road
Transport Assessment.

Since 2010, the Dept of Planning has continued to approve increases in
truck movements on the Highway from 2MTPA to 3MTPA to 4MTPA, rather
than building the Kamillaroi Highway overpass as promised.

I believe there should be no new coal on the Kamillaroi Highway.

10. Water trigger

This Project is a controlled action under the Environmental Protection
and Biodiversity Conservation Act, and is a "large coal mine" under
the terms of the EPBC Act.

This EIA does not provide an adequate amount of detail to enable
decision-makers at the State or Commonwealth level to properly assess
the likely impacts of the mine, and the railway, on the Namoi River,
and the surrounding surface-water and groundwater.

Elsewhere, the EIA provides factually inaccurate or incomplete
information which may a tendency to be misleading.

I do not have confidence that the Namoi River is safe from severe
damage if this mine proceeds, and fear that water quality and
downstream flows will be damaged to the detriment of downstream users.


11. Indigenous culture
From the experience of the Maules Creek mine, Whitehaven continually
ignore their responsibilities in relation to cultural heritage as it
is set out in the Burra Charter and the Policies relating to
Aboriginal Cultural Heritage Valuations set out by the Office of
Environment and Heritage. There has been a lack of any consultation
with the First Nation's People's Knowledge Holders, within the Red
Chief Local Aboriginal Land Council boundaries. Consulting with
Registered Aboriginal Parties is not enough.

I object to the mine extension.
Following reasons:
- Whitehaven with this project want to more than double the volume of
coal it mines every year, to 10 million tonnes. The infrastructure the
company is proposing has larger capacity than the proposed mine, and
therefore would suggest that they are planning to expand once again in
the future. The Liverpool plains is one of the choice if not the
number one food bowl within Australia and to exploit the land and also
the water reserves within it for an unsustainable commodity like coal
would be a national disaster. It shows the focus of our governments at
all levels is extremely short sighted , this can be seen even in our
local council with several members of the council having interests
within coal mining companies in the gunnedah basin.
- The proposed train line over the namoi river and then across the
flood plain . This will effect my property and also house directly ,
due to the back up of water in a wet period . This will occur due to
the water backing up against the existing train line between gunnedah
and boggabri. If the proposed train line goes ahead , the volume of
water trying to flow down the floodway in a flood will be restricted
and therefor directly impact several houses within the area.
- The noise from the proposed mine extension will also effect our
house directly due to the increased amount of trains using the line
for coal .
- Train loading time slots for loading grain are already difficult to
secure due to the amount of coal trains using the line , how is the
train line going to be able to handle the extreme increase in coal
trains using the lines ?
- lastly , the community has been left in the dark with this proposed
mine extension and train line. why hasn't a member from white haven
consulted with each landholder that is going to be directly effected
by this development? are white haven going to be accountable if houses
are flooded, due to the alteration of the natural watercourse ? will
they be accountable when underground water resources are exploited
like they have been in the past ?Their are several questions that have
not been answered from both white haven and also the government. I
feel that there should be at least be a full review on all plans for
both the mine extension and railway across the floodplain by
individuals who have no current ,past or future affiliation with white
haven!. Lets not have the Liverpool plains turn into another hunter
region , where there has been exploitation of premium farming land for
a short term cash grab from a unsustainable commodity.

This submission is opposed to the Whitehaven Vickery Coal Project SSD
7480.

I am based in the Gunnedah Shire Council area, and have a family farm
located immediately alongside the Whitehaven owned Werris Creek coal
mine site.
Having been heavily involved in the local community in my local area,
I advocate strongly for the immediate neighbours to the Vickery Coal
mine site, and fear for their farming futures alongside this proposed
new large coal mine.

The troubles my community have experienced with water bores alongside
the Werris Creek mine don't instill any faith in the proponents abilty
to adequatly address issues, or maintain and build decent
relationships with their neighbours.

My family for some time in 2013-2014 had our property on the market
for sale, a large property with bores and site improvements, and an
affordable entry level cattle property in the district. We had lots of
interest in our property from prospective purschasers, but not in line
with the suggested marketed advertised sale price. The first question
we were always asked was about our water situation, and the situation
with that of our neighbour Whitehavens Werris Creek coal mine.

Since this time, thoughout 2015 and 2016, many of my neighbours futher
to the south east towards Quirindi have had significant water issues
with stock and domestic bores, and irrigation water.

Many have had bores give out entirely and have had to sink new bores,
or deeper bores, affecting their business operations and their
household supplies. Some haven't been able to replace lost or
diminished water supplies, greatly affecting to many their primary
asset, their homes and farms.

During this same time, the company has had an abundance of water in
their mine pit, it appears an unexpected amount, as they have had to
develop further evaporation ponds, and even develop their business
interest into the agricultural sector introducing a pivot irrigator to
disperse their excess pit water onto crops.

Today in October 2018 there are a great number of small farms
neighbouring, and nearby to the Werris Creek coal mine, that are
either on the open market for sale, or it is known that their owners
would like to put their propertys up for sale, as they head into
retirement from the land. Some of these people maintain good
underground water supplies, some who purchased their properties as
irrigation operations, are looking to sell now, as dryland farming.

These farms have been on the market for some time now, and whilst
other properties across the district quickly change hands to new
owners, these farms remain unsold with anecdotally diminished interest
from buyers. There is an undeniable lack of purchaser interest in land
that abuts or is in the vicinity of coal mines. People would rather
look elsewhere for a farm to purchase away from these type of
developments due to the perceived and real risk associated with these
mega mines of today.

These Boggabri farmers and landholders across the state, alongside
these mine sites, are deeply disadvantaged by these new developments
on their door steps, and Government and associated entities, including
these proponents need to do much more to help those affected by land
devaluation. I would propose that land valuations are obtained for
neighbours, with no coal mine project in mind, prior to these
developments being approved, and then these property valuations be
marked along side other sale results in the proceeding years for
valuation purposes. And then if a land holder is wanting to sell later
on they are not disadvantaged by the perceived risks associated of
being neighbours to these coal mine developments, with any loss in
realised value paid for by the proponenet developers.

It is often said that when these developments move into greenfield
development areas, that landholders who sell out required land to
proponents 'win the lotto' whilst its greatly unforutnate that
landholders whose land is not required for development are left with
'the wooden spoon'. These farmers should not, and can not, be left
disadvantaged in these developments, and the proponent advantaged off
the back of neighbours unrealised and potential realised losses.

To The Powers That Be,

In regards to the proposal by Whitehaven Coal to Extend the Vickery
Mine approved mine site from a 4.5 million ton per annum mine to a 10
million ton per annum - I object based on the following information,
or there lack of, supplied in the companies EIS;

Firstly, the river health is the main concern for locals and those
further down stream on the Namoi. With the mine bordering on a
precious piece of natural environment, which is more environmentally
diverse than most parts of the Namoi, it would be a total travesty to
let the mine destroy this important ecosystem. Despite their planned
"modelling" (plenty of which has been considerably inaccurate in their
Maules Creek mine) the region is prone to flooding, and that means
only one thing. That mine will fill with water and the only option
will be to pump the toxic, coal dust water back out and release it
into the river. The effects on the natural environment alone should be
enough to put a stop to this ludicrous proposal, without even taking
into account the effects this polluted water will have on the health
of humans and the cost to communities downstream that rely on the
Namoi River.

The effects to the underground water are also of MAJOR concern to the
immediate and further afield communities. Agricultural has been the
primary industry in the Gunnedah/Boggabri district for decades and now
works along side Mining in a mostly amicable relationship. The
difference between this mine proposal and the others is that this mine
is located on a River, in a Flood plain, by an unreliable operator who
has already proven themselves in the local area as an untrustworthy
custodian of this sensitive environment.

We are fourth generation farmers and we would like to continue to pass
this property down through the generations by looking after it and the
surrounding environment well. This is how we have managed to keep this
land productive for nearly 100 years already, by managing it
sustainably. Our underground water is absolutely vital to hundreds of
families in this region just like ours. If something was to impact on
our underground water source, not only would our farm, and water
licences, be worthless (this alone would send us broke as these are
our prime assets) but we would not have a consistent income (or in a
year like this, no income at all), we would not have an employee, and
we would not have a future here. We would be lining up at Centrelink
asking the Government for some of that welfare money that Whitehaven
have paid them in Mining royalties. Although we are only just one
farm, typical of the size in this area, we turn over close to $2
million dollars annually, spending three quarters of that in local
communities and contributing some $1.7 million dollars worth of
agricultural produce to the Export Industry. And whilst I get that
mining that surface area will produce a lot more bang for their buck
in the short term, the long term affects will reach far beyond the
mine's boundary. Even further than the Gunnedah shire and Bogggabri
community. The impacts to farm lands, water users and secondary
industries in Gunnedah, Boggabri, Baan Baa, Narrabri, Wee Waa and out
to Walgett and beyond will affect tens of thousands of people, their
businesses and their communities. Can the government afford to risk
impacting all these people? Potentially millions of dollars each? And
who is going to compensate us when the underground water is gone, or
the river is contaminated, our farmlands are worthless, unproductive
and potentially hazardous to even be on in this scenario.

The worst part is, none of this, however dramatic it sounds, is
unforeseeable. It is all, very foreseeable and therefore very
concerning for a stakeholder like myself and my family.

There have already been many instances when Whitehaven's Maules Creek
mine have sent blast fumes over neighbouring properties, causing those
inhabitants to need hospitalisation. And there is evidence around the
Werris Creek and Scone districts of bores "drying up" for the first
time in a hundred years, conveniently within several years of mine
commencing in that region.

The community social impacts surrounding any changes to the water
supplies that we all rely on would be unquantifiable in dollars to the
industry and also, population levels too.

Another key selling point Whitehaven are using is boasting "all the
jobs" that they will be bringing to the regions. To be honest, I don't
think Gunnedah really needs anymore jobs. The house prices and rent is
already so high that it is pushing locals who have lived here forever
out of town. Not to mention the farm lands that the mines have already
bought up, as far as I know, 29 farming families have already left the
Wean district. We have had 2 of our own farm hands leave us for
employment in the mines, as we are unable to compete with the
exorbitant wages. It's not always that they are "creating new jobs"
they are really just stealing local jobs. We don't have a worker
anymore because we can't afford one and we can't find anyone. And
should we hire a mechanic from town to work on a tractor, we now pay
$165 per hr, because that is how much they could be earning in the
mines.
The money that the government receives in royalties should be shared
with the communities that have to live with mining! After all, we are
the people that have to live with the increased prices for everything.
Groceries, labour, land, housing, industry supplies and contractors.
It is already difficult enough balancing increased input costs in
agriculture when the output prices never increase.

As a young couple who will be bringing an infant into the world
shortly, I'm also very concerned about air quality. Yes, we live in a
dusty environment, but we can control that effect on us and our
neighbours. We don't plough a paddock when the wind is blowing a cloud
of dust into our neighbours house. And we certainly wouldn't spray
chemicals in windy conditions at all for the effects it would have on
our own paddocks and our neighbours (and we would rightfully be liable
to pay for any costs that we cause, health wise and product value
wise). However, when your dealing with Whitehaven in particular, as
evidenced by previous complaints and law cases surround there existing
mine sites, there is no regard for any ones health and safety, nor
financial impact to their business or homes. Offering to compensate
neighbours by paying for double glazing and air-conditioning in their
homes, only worries me more because even they know their actions will
impact on their surroundings. And frankly, have you ever seen a farmer
grow a crop or feed his stock from inside an air-conditioned, double
glazed home? We work outside, we live outside and our kids play
outside. And if we can't be outside whilst they are operating for the
next 30 years, than we have a real problem. No neighbour, big or
small, should be allowed to impact on someone else that much.
Socially, Medically, Financially and Environmentally. They all matter
and none of these issues are a concern for Whitehaven because they
aren't here for the long haul. They are here for a quick money grab
for the next few decades and then they will leave our region an
irreparable mess that the Government is ultimately responsible for.
Not that that will comfort me at night.

And in regards to the proposed Train Line and out load facility also
put forward in the same submission (and I would question why it is not
put forward under its own submission, being such a major individual
development?), I also object, based on the following concerns and the
questionability of the information they provide on it.

The information detailing the plan for the train line has been left
out of the submission altogether. Perhaps next time I go for a DA to
build a house I will leave out whether I'm going to be building it out
of bricks or toothpicks, and see how I get on. There will be a
significantly different outcome to my submission if I mentioned I was
building it out of toothpicks, don't you think? My point made, how can
anyone interpret and properly assess the impacts of a structural
development, (over a flood plan nonetheless) without being supplied
the correct information? Or any information? If they don't know what
are the best products to use, then they aren't ready to build it yet.
Go back and keep doing your homework Whitehaven, because you are
messing with many peoples lives here. Or better yet, give them 42 days
and see how they like it.

The risks posed by building a train line through a flood plain are
ridiculous. Anyone that has lived here for more than 10 years, and
there are plenty of families that have lived here for more than a 100
years, know the flow of the flood water, the height it gets to and
damage it causes. We know we live in a flood plan, and we plan for it.
Our houses, silos and sheds are safely behind little levy banks no
more than a metre high in most places, and this has kept our property
safe for decades. With Whitehaven's proposed train line that is, um
about yay high, on pillars that are... a good distance apart, on say,
pretty strong and deep foundations, it is hard to believe their
suggestion that flood water levels will not rise. And the consequences
of this? Potential loss of homes, machinery, income (crops and stored
crops in silos/sheds), as well as the health risks that go alongside
flooding in general.

The potential for pollution to enter the river and surrounding
environments is also increased 10 fold when you put a train up in the
air. Not only from a potential derailment over the river or highway,
which it crosses and tracks along for many kilometres, but also from
the wind blowing coal dust out of the back of the train. Whilst it is
accepted in the industry that coal dust does not escape moving
vehicles, I challenge you to openly look at, feel, smell and touch the
guideposts and road surfaces along a track where coal trucks transport
goods all day long. I bet you will wash your hands before you eat your
next sandwich. The dust is evident there, as it will be in our air
over our farmland, homes and rivers and eventually in our lungs and
stomachs from producing food in a coal district. I hope you like your
wheatbix black.

The noise from a train at ground level is clear from my home to the
main Northern line at 5km away. And that is fine, we chose to live
here so we live with it. There are not many trains a day anyway so it
is not much of an inconvenience. However, according to Whitehaven's
representative Brian Cole, the train will be quieter than a library at
our house, located approximately the same distance away but up in the
air. I'm not sure where they are getting the modelling to produce
these figures but I can firmly suggest it is wrong. A direct,
uninhibited passage straight from the train to our ears is always
going to be louder than sound wave that might be reduced by trees,
grass and dirt that lays in its path. I think that's why they use
these as sound barriers on the highways?

For someone that already struggles with insomnia, I can't bear the
thought of having to live with potentially 20 trains a day rattling
away in the distance. That would be worse than Chinese water torture.
We won't even be able to sell out to get away, who would want to buy
here then?

The whole idea of the rail overpass is a complete waste of resources
in my view, which is shared by a large majority of locals. There is
already a railway overpass over the Namoi north of Boggabri and the
belief locally is that although Whitehaven could use this option to
service Vickery Mine, they don't "get along" with the other mine
operators that use this rail over pass. From a business mind set, they
would have more control over a new railway over pass that is set to
benefit them significantly, unfortunately to the detriment of everyone
around them. It would be a lot safer, cheaper and more sustainable if
they co-operated with their counterparts and used the existing
overpass.

Lastly, can someone please ask Whitehaven to change the name of this
project? I query how a project can be considered an "Extension" when
it is clearly more than twice the original size of the first,
approved, 4.5MT/pa model. Another slant of propaganda from Whitehaven
I expect. Let's hope those making the final call can see through the
completely made up 4000 pages of dribble that they have submitted and
only given us 42 days to read. We don't all get paid to sit around
making stuff up Whitehaven, please be considerate, some of us have
lives to make the most of before you destroy what is left of them.

I have run out of time to go on, and I'm sure you're not disappointed,
but we do appreciate your honest consideration of the real,
potentially life-changing impacts this project will have on the
community and individuals. Although I have attempted to lighten the
mood of this submission, purely for my own sanity and I'm sure your
sick of reading them too, it really is a serious concern for everyone
in this region, and even those that aren't in this region or don't
know that they will be impacted by the project. Please, don't approve
this application, not with the way it is and certainly don't allow
Whitehaven to be the custodian of this fragile enviroment. Honestly,
they laugh in the face of the $15,000 fines they get, and so would I
if I grossed $900,000,000 annually from this one mine alone. The rules
and regulations set in place to protect us are not worth the paper
they are written on and the only way to protect us now is to put a
stop to the Extension altogether. Please help us.

Thank you

This submission is opposed to the White haven Coal Vickery Coal Project
SSD 7480.

The members of the New England Greens Armidale-Tamworth (NEGAT)
express in the strongest terms their opposition to the expansion of
the Vickery Coal project and our conviction that the Vickery Mine
extension Environmental Impact Assessment (EIA) should be rejected.
NEGAT particularly is concerned for the on-going viability of our
Regional communities, the incompatibility of the development with
existing land-use and the complete disregard for intergenerational
equity, cumulative impacts and the precautionary principle. NEGAT
notes that Whitehaven has been granted an approval for a mine at this
site yet the company has failed to begin development which raises
questions as to the viability of the project.

NEGAT's submission should not be regarded as complete. The extremely
short exhibition period of just 42 days, of a document of more than
4000 pages, has imposed an impossible burden on the public to
adequately respond. The failure of the Minister for Planning to extend
the Public Exhibition period, despite many requests, shows a lack of
understanding of the current hardships faced by local farmers and
community members.

NEGAT consider the extent and impact of the proposal renders the
project effectively a new, rather than extended, proposal including as
it does a new coal railway; a rail load out facility; a new Coal
Handling and Processing Plant; a second bridge over the Namoi River
and a new bore field with an additional 10 bores. Key changes to the
Vickery project have not been adequately consulted with the community
(or, as is the case with the new borefield, no consultation at all).

NEGAT are concerned that Whitehaven continues to ignore their
responsibilities in relation to cultural heritage as set out in the
Burra Charter and the policies set out by the Office of Environment
and Heritage. There has been a lack of consultation with the
traditional custodians within the Red Chief Local Aboriginal Land
Council boundaries.

NEGAT believes the viability of our Regional community is compromised
by this Development. One of our greatest concerns is the current and
future health, especially mental health, of those who will be
alongside this development, and living nearby in the Boggabri
community. There is already significant concern in existing coal
communities, were community members often have little choice but to
remain. Anecdotal evidence of health concerns is widespread and
compounded with that documented within the Department of Planning and
found in the files of mining companies' complaint records. Health
issues in the Upper Hunter Valley and Maules Creek area, particularly
in bronchial conditions, can be expected to occur as a result of this
development. It is disappointing that the recently established Namoi
Air Quality Monitoring System does not incorporate dust monitoring in
or near the town of Boggabri.

The Development Application is incompatible with existing land-use in
the Gunnedah and Boggabri area, with dryland and irrigated
agricultural farming lands extremely close by, as well as posing a
threat to underground water supplies. NEGAT is concerned that the
Namoi River will be adversely affected by this proposal. Local action
was required to have Whitehaven move pits back from the Namoi River,
but the pits are close to the alluvial aquifer that feeds the river, a
most undesirable situation.

Boggabri has been caught in a downward economic spiral; there is no
evidence to suggest this situation will improve with Drive-in, Drive
out workers being the norm and farms being sold off. The local area
should not be becoming increasingly reliant on industries that are
under global pressure as corporations and entities divest from coal,
banks remain hesitant, or will not commit at all to invest, and whilst
a great majority of countries globally look to transition their energy
sources away from this heavily polluting industry, to clean renewable,
and far cheaper energy sources.

A complete disregard for Intergenerational Equity, a failure to
consider cumulative impacts and to apply the Precautionary Principle
marr the EIA. Vickery Coal Mine Extension is another megamine (on the
scale of the Maules Creek mine) and in close proximity to the Leard
Forest Coal Mining precinct. However, the EIA makes no attempt to
apply the Precautionary Principle to its assessment and potential
impact on water, land and air pollution are understated. The EIA has
failed to address the impact of the blasting vibrations and dust from
already operating mines which will be compounded with those of the
Vickery Mine.

NEGAT observe that matters associated with Biodiversity are
inadequately treated in the EIA. Prime koala habitat is threatened by
the extension of Vickery mine and the impacts (and cumulative impacts)
of habitat loss have been understated in the EIA. Koalas are listed as
an endangered species under NSW and Commonwealth legislation. Offsets
are not apparent for the Mixed Sedgeland community nor the River Red
Gum community which will be lost should the extension project be
approved.

NEGAT consider that it is unconscionable that the Boggabri community,
precious water, land and air resources should be the price paid for
Whitehaven's attempt to effect economies of scale in proposing this
extension. The current economics of new coal development is widely
acknowledged to be under intense pressure, and whilst some of this
development is for coking coal, a significant remaining portion is
thermal coal, that must inhibit the project's viability. Whitehaven
already has an approved DA for a 4.5mT per year coal mine; this is
apparently deemed uneconomical and so Whitehaven is seeking expansion
under this application. The last 10 years, and in particular the last
3 years, have been economically unattractive for the coal industry,
with Whitehaven's own share price being as low as 5% of its current
recovered share price today. These are volatile commodities in the
context of ever-changing and movable global markets, and the ascent of
renewable energies. An application of an ETS (Emissions Trading
Scheme) or a movement in the AUD/USD exchange rate the wrong way will
be enough to put significant pressure on this industry that could be
catastrophic for the reliant local coal communities and workers.
Already Whitehaven Coal has a record of not paying its fair share of
tax to the Australian taxation system, either via Tax shields or off
-shore accounting opportunities, questioning this company's
profitability. Whitehaven's seeking of economies of scale should not
be at the expense of our future.

NEGAT observe that the Road Transport Assessment of the EAS uses
out-dated modelling and fails to take into account changes that have
occurred since 2012 (viz. it predates the establishment of the Maules
Creek coal mine, and the extension of the Boggabri and Tarrawonga
mines); the predictions for road impact in 2019 and beyond are
unreliable and discrepancies in predicted traffic volumes are of great
concern. Since 2010, the Department of Planning has approved increases
in truck movements on the Highway while the promised Kamilaroi Highway
overpass has yet to eventuate. The risks are excessive: the issues of
cumulative impacts from all mine and mine related traffic should be
addressed and a private haul road and highway overpass should be built
prior to any work commencing on the Vickery Coal Mine.

NEGAT urge the Department of Planning to reject the EIA for the White
haven Coal Vickery Coal Project SSD 7480 and, in doing so, acknowledge
the need to be planning for a transition from fossil fuel industries
by assisting coal reliant communities into new industries and jobs
that will be far more secure into the future.


Signed,
Peter Wills,
State Delegate
New England Greens Armidale Tamworth

To whom this may concern,

Approval cannot be granted to extend the Whitehaven Vickery Coal Mine.

Approval for extension of the Vickery coal mine, a project of such
scale and defiance allows Whitehaven to shatter our prime land.
Through acceptance of this project you are agreeing to destroying
Australia's food bowl; allowing for contamination of our water
systems, and natural wildlife and ecosystems within this environment.
You are ultimately causing a region to suffer an immeasurable social
impact through your poor decisions. You are impacting Australia's
farming future.

Not only are my concerns based on the obvious environmental impacts,
but also the approval of this extension will cause significant
personal impact on all of our lives.

The extension proposes a new rail crossing over the Namoi River,
affecting a major floodplain. A new large coal handling facility is
also proposed to increase coal processing for surrounding mines in the
region, causing a vast increase in the number of trains along our rail
line.

I live alongside this railway at Emerald Hill, NSW on a productive
cereal-cropping farm. By extending the railway and increasing the rail
traffic along this line, it raises great concern for the future of our
agricultural farmland. The associated effects are immense making our
home unliveable from associated noise disturbance, and black coal dust
air pollution that will destroy our home environment. Our beautiful
scenic landscapes will be lost. Our unique wildlife will be without a
home. Our local towns and strong farming communities will crumble.
Through Whitehaven's increased infrastructure, a proposal is made for
an indefinite larger capacity jeopardising our region's future.

I'm a Registered Nurse, each day travelling from Emerald Hill to
Tamworth to work and complete postgraduate midwifery studies. As a
shift worker, I travel at all hours of the day, rain hail or shine to
make it to work, and then return home to my loved ones, to a place I
have always called home. This railway will interrupt a floodplain,
acting as a barrier for floodwaters to pass. Water will not be able to
make it to its natural course, to nearby systems. I will not be able
to travel to work. Roads will be severely damaged and access to major
highways and nearby towns will be blocked. Our crops will be swamped.

I do not agree with the proposed expansion of the Vickery Coal Mine.
Think about the lives of everyday people you are destroying. Think
about our countries farming future.

Im writing this as a plea for the people of Northwest NSW, against the
Vickery Mine.
Would the government please accept the will of the People in this
community, because the farming community is more valuable to the
country at large than this coalmine extension.
When is enough ENOUGH ?

The community has been decimated by other coal mines in this region.
This massive coal mine will bring dust, noise, blasting and social
impacts to the community, farmlands, rivers, groundwater, ecosystems
and climate.
Listen to the People - and give it up !

Stop forcing big mines onto people, livelihoods and polluting the
land, air and water around it for many many future generations. It is
appalling that human, plant and animal life is not given the same
consideration as mining moguls.

My great and grandfathers family came from this north west farming
area and generations ago it was acclaimed for its rich farmlands and
`Farmers' were once respected and hailed as the backbone of the
country, working hard and through droughts and floods they kept the
country fed and we exported our produce to the world. This area is
also a significant wildlife area.

This stretch of the Namoi River that runs on the boundary of the
project area is a permanent waterhole even in times of extreme drought
and has already been noted for its biodiversity and natural assets
that must be protected from the impacts of mining. The proponent
proposes to leave a strip of vegetation along the river which will
mitigate any negative impacts on biodiversity but the proposed bridge
crossing will impair the movement and wildlife including the koala.

No offsets areas for biodiversity loss are being proposed and so the
issue of the impact of the mine on biodiversity has not been resolved.
A lack of suitable local remnant vegetation raises questions as to
whether this can be resolved. Whitehaven has a poor record of meeting
offset requirements. They still have not fulfilled their requirements
at Maules Creek five years after approval. The community has little
faith they can fulfil their obligations at Vickery.

Giving permission to this project is wrong and the application is a
sign of defiance and arrogance by a company who believe they are above
the law. Approval cannot be given for a project of this scale in a
region already suffering the water and social impacts of prior poor
planning decisions and lack of compliance oversight.

Think very carefully about the impacts your decision will have and may
you be at peace with it - for it will haunt you and your department
forever, if your decision destroys this country and the environment
for the future generations of Australia and the whole world - forever.

Thankyou for providing this opportunity to submit my objections to
this mine proposal.

Yours Sincerely

I object o the Vickery Mine expansion as it will significantly threaten
the environment,ecology and agricultural sustainability in the region.

Whitehaven already has an approval for a mine at the site, but with
this project the company wants to more than double the volume of coal
it mines every year, to 10 million tonnes. The infrastructure the
company is proposing has larger capacity than the proposed mine, and
farmers know from bitter experience that coal mines tend to grow...
The company proposes a new rail crossing over the Namoi River and
floodplain and a new large coal handling facility that can process
coal from other mines in the region.
Thanks to the efforts of farmers fighting the mine, Whitehaven was
forced to move its pits a little further away from the Namoi River,
but the pits now come close to the edge of the Namoi's alluvial
aquifer, the productive groundwater that underlies the river, and
feeds it. The pits will induce leakage from the alluvial aquifer and
the Namoi River itself.
People in the small community of Boggabri believe the community cannot
handle a fifth mine in close proximity to the town. They're concerned
that the scale is too large for the town to cope with.
The mine will be located close to the historically significant
property and homestead "Kurumbede" which was the inspiration for
several Dorothea Mackellar poems including the famous "My Country."
One outbuilding at Kurumbede will be destroyed by mining and the
homestead could suffer from the vibration of blasting and the loss of
scenic value and quietude.
The area adjacent to the proposed mine is strategic agricultural land
and the impacts of dust and noise will make this land unliveable and
likely impact the quality of crops grown there.
Already, 76 family farms have been purchased by Whitehaven in close
proximity to the town of Boggabri. This has hollowed out the township,
affected local businesses and rent the social fabric of the district.
This proposal will mean more rural properties bought up because of air
and noise pollution, irreversibly changing Boggabri.

The proponent states this is just an extension to the already approved
Vickery mine however this proposal includes new infrastructure to
service much bigger needs than for Vickery itself. For example, a new
rail crossing across the river and the establishment of a new large
coal handling facility that will service other mines in the region.
The scale of infrastructure proposed could service much greater mining
in the region. As such it seems like approval creep where a minor
application actually opens the door for new and other expansions. This
makes tracking the true cumulative impacts of all developments a
challenge. The size and potential impact of the rail line alone should
surely require its own EIS. The EIS contains no management plans for
water, noise, blast, air quality, heritage or traffic management.
There are only vague terms such as mitigation.

The Department has no guidelines for mining companies to follow when
undertaking a 'cumulative assessment' under NSW law. This is
particularly important for Vickery extension which has not considered
the combined impacts of the existing approval in the current EIS or
the cumulative impact of the original approval as well as the other
major mines in close proximity.

The EIS repeatedly places Boggabri west of the project. However,
Boggabri is north west of the project which places it approximately
10km as the crow flies with the prevailing winds from the south east.
This means that the township is directly in the path of the south
easterly winds.

In approval number - 013 of the proponents Maules Creek mine the
McGregor's property "Calendar" which was 12km in a south easterly
direction was placed within the acquisition zone due to the cumulative
effect of dust and noise. Following this logic, the entire township of
Boggabri could theoretically find itself in an acquisition zine due to
the same effects. Despite this there are no community dust monitors in
the Boggabri township. This is despite monitors being placed in
Tamworth, Gunnedah and Narrabri - towns which are all a considerable
distance from any of the mines.
There is no clarity surrounding the makeup, potential health effects
or likely impact to neighbours and the community in general regarding
blast fumes.

This proposal is seen by many as the "tipping point" for the small
community of Boggabri with locals believing the infrastructure of the
community cannot handle the fifth mine near the town. They are
concerned that the scale is too large for the town to cope with.
Another 450 operational staff are proposed for the mine and yet any
local who seeks to work in the industry already does, leading to a
need to import large numbers of workers, further disrupting the town.

The mine will be located close to the historically significant
property and homestead "Kurumbede" which is the inspiration for
several Dorothea Mackellar poems including the famous "My Country".
One outbuilding will be destroyed by mining and the homestead is
likely to suffer the effects of blasting. This important culturally
significant site must be protected for future generations.

The proponent stated they responded to community concern over the
close proximity of the coal pit to the river and moved the pit a
little further away from the Namoi River. However, the mine footprint
is still perilously close to the critical water source of the Namoi.
Whilst more in depth science is yet to be done on the water impacts of
this proposal, it is sufficient to assume that this mine, combined
with the others in the close proximity will have a significant and
dangerous impact on the water resources of the region. The proponent
intends to develop a bore site with a total of ten 1 megalitre bores
within Zone 4. This zone also contains the two bores which provide the
water supply to Boggabri township. Sharing this zone poses a risk of
leaching and contamination of the town drinking water and increases
the potential for an adverse impact on the quality and availability of
the town water supply.

I believe that an independent water panel is needed to investigate
water take from Vickery and cumulative coal mines. This should include
both aquifers as the use of water from Maules creek aquifer will pull
water from alluvial aquifers ie vertical leakage from Namoi alluvium
to the underlying consolidated material of Maules Creek formation.
Further it should examine the impact of surface water take and the
release of contaminated surface water into the Namoi River system.

The Land & Water Commissioner, Jock Lawrie is on the record as having
a conflict of interest due to property ownership therefore it is
difficult to understand how he could be involved in the assessment and
influence on this project.

There is a serious lack of information in the EIS about the rail
crossing across the Namoi River and the floodplain. This crossing will
be the second one in close proximity causing serious concerns about
the risk of debris build up during flooding and the flow on impacts
created. The EIS contains no detail regarding the definitive route of
the rail line nor any design or construction details. In addition,
there has been little to no consultation with local farmers or
organisations such as the State Emergency Service regarding water flow
and the likely impact of the rail line on local farms and towns both
up and down stream.

Approximately 76 family farms have already been purchased near the
town of Boggabri. This has hollowed out the township, caused suffering
to businesses and seriously changed to social setting of the area. The
proponent has been responsible for a raft of environmental breaches,
created significant social impacts in the local township of Boggabri
and left a string of broken promises to neighbours and locals. Much
controversy surrounds the water impacts caused by the proponent's
Werris Creek and Maules Creek mines. Their Maules Creek mine was
recently given the poorest rating possible (1 of only 3 mines in the
state with that rating) in terms of environmental problems. They are
not a fit and proper proponent to be allowed to build another mine.

This proposal will likely cause more of the same, irreversibly
changing the town and the area. The proponents have no social license
within the community. This project is a sign of defiance and arrogance
by a company who believe they are above the law. Approval cannot be
given for a project of this scale in a region already suffering the
water and social impacts of prior poor planning decisions and lack of
compliance oversight. They still have not fulfilled their requirements
at Maules Creek five years after approval. The community has little
faith they can fulfil their obligations at Vickery.

I am completely opposed to this so called expansion for the following
reasons:

1. . The scale of infrastructure proposed could service much greater
mining in the region. It seems like approval creep where a minor
application actually opens the door for new and other expansions. This
makes tracking the true cumulative impacts of all developments a
challenge.

2. The Department has no guidelines for mining companies to follow
when undertaking a 'cumulative assessment' under NSW law. For instance
the Extension identifies a 2m groundwater drawdown caused by the
Extension, it is unclear if that is taking into account the cumulative
impact of the original approval as well as the other major mines in
close proximity.

3. The mine footprint is perilously close to the critical water source
of the Namoi River

4. Whitehaven has been responsible for a raft of environmental
breaches, created significant social impacts in the local township of
Boggabri and left a string of broken promises to neighbours and
locals. Much controversy surrounds the water impacts caused by the
proponent's Werris Creek and Maules Creek mines. Their Maules Creek
mine was recently given the poorest rating possible (1 of only 3 mines
in the state with that rating) in terms of environmental problems.
They are not a fit and proper proponent to be allowed to build another
mine.

5. This proposal is seen by many as the "tipping point" for the small
community of Boggabri with locals believing the infrastructure of the
community cannot handle the fifth mine in close proximity to the town.

6. The mine will be located close to the historically significant
property and homestead "kurumbede" which is the inspiration for a
number of Dorothea Mackellar poems including the famous "My Country".
One outbuilding will be destroyed by mining and the homestead is
likely to suffer the effects of blasting. This important culturally
significant site must be protected for future generations.

7. The area adjacent to the proposed mine is strategic agricultural
land and the impacts of dust and noise will make this land unlivable
and will likely impact the quality of crops grown there. This is the
first project seeking approval so close to strategic agricultural land
and sets a dangerous precedent.

8. 76 family farms have already been purchased in close proximity to
the town if Boggabri. This has hollowed out the township, caused
suffering to businesses and seriously changed to social setting of the
area. This proposal will likely cause more of the same, irreversibly
changing the town and the area.

9. There is virtually no effort to protect bio-diversity nor water for
agriculture in this woefully inadequate EIS.


10. A lack of suitable local remnant vegetation raises questions as to
whether this can be resolved. Whitehaven has a poor record of meeting
offset requirements. They still have not fulfilled their requirements
at Maules Creek five years after approval. The community has little
faith they can fulfill their obligations at Vickery.



11. A report issued 7th October, by the UN Intergovernmental Panel on
Climate Change (IPCC), says the planet will reach the crucial
threshold of 1.5 degrees Celsius (2.7 degrees Fahrenheit) above
pre-industrial levels by as early as 2030, precipitating the risk of
extreme drought, wildfires, floods and food shortages for hundreds of
millions of people. They recommended that Australia and the rest of
the world must virtually eliminate the use of coal for electricity
within 22 years if there is to be a chance to save even some of the
Great Barrier Reef. This project must not add to the calamitous
impacts of climate change and for this reason alone it cannot be
allowed to be developed.

Sincerely
Simon Clough

Another coal mine? Are we completely losing our minds?
I object to this proposal for a number of reasons:
1. The environmental impact of the mining process itself and the
further detrimental impact when the extracted coal is used. We must,
as a community refuse to continue to expand the sources of pollution
which contribute to global warming.
2. The impact this project will have on the near neighbours.
3. The availability of renewable sources of energy which don't have
all the adverse impacts associated with fossil fuels and their
extraction.
4. The significant degradation of the visual amenity of the region.

No new coal!!

I am objecting the proposed new Whitehaven coal-mine on numerous grounds,
both social and environmental. My primary concerns being;
* The horribly damaging impacts of our emissions on the environment -
which have been shown repeatedly to be leading to catastrophic global
climate change. Although I do not live in the region, this is a State
Significant Development, and I am concerned and the loss of
agricultural land
and its implications for food security.

* The disregard for the local community's concerns - not extending the
public exhibition period to 90 days.
Having recently travelled in the region, attended the Boggabri
planning meeting, and spoken at length with locals, I'm unable to see
how this project is in the best interests of the community, or more
broadly the country, given the urgency with which we need to move
towards renewable energy sources. Being relatively young and observing
the unfailingly myopic outlook of our government and mining companies
seriously frightens me. The wellbeing of people and the environment
should be the primary concern when evaluating proposals such as this,
not the speed with which it can be pushed through regardless of
consequences.

The Vickery mine extension Environmental Impact Assessment should be
rejected.

The Vickery mine poses the risk of irreversible or catastrophic harm
to the Namoi River, and its surrounding surface water and groundwater
systems, and the health and well-being of human populations in the
Boggabri region as well as the habitat of the endangered koala and the
Commonwealth-listed Murray Cod.


1. Cumulative impacts have not been considered

The Gunnedah Basin in the vicinity of Boggabri is also the location
for 22 Million Tonnes per Annum of Approved coal mining. The 10 MTPA
proposed Vickery mine is surrounded by other Exploration Licences
which will, in the course of time, be sought to be developed,
including a licence which covers the Vickery State Forest itself.

Vickery Coal Mine Extension is another megamine the scale of Maules
Creek, and in close distance from the Leard Forest Coal Mining
precinct. Yet the EIA does not make any attempt to apply the
Precautionary Principle to its assessment of the cumulative impacts.
There are many examples where the EIA has ignored or misstated the
cumulative impacts. Eg locals are already badly affected by blasting
vibrations and dust from Whitehaven's Rocglen and Tarrawonga mines.
This is not alluded to in the EIA. The EIA also is misleading about
the distance between Vickery and Tarrawonga, stating they are 11km
apart when in fact there is just 4km distance between Tarrawonga and
the proposed Vickery borefield.

In view of pre-existing concerns about dust from the Leard Forest coal
mines, I am of the view that cumulative impacts of dust pollution and
the risk to the health of communities in the Gunnedah Basin are not
adequately assessed.

2. This is not my full submission

I wish it to be known that my Submission is not complete, due to the
onerously short Public Exhibition period. This means I have not been
able to provide as full as Submission as is called for given the size,
complexity and lack of public awareness of the Vickery Coal mine
extension project. I believe that the relatively short Public
Exhibition period has compromised the right of the public to comment
on this important State Significant Development and is an incorrect
decision by the Minister for Planning who refused to extend the Public
Exhibition to 90 days to allow more expert consideration and community
comment.

3. Threats to the town of Boggabri

Boggabri is a town in slow decline, despite the assurances that were
made by the coal industry when the Maules Creek mine was being
proposed that prosperity would come.

Despite strong support in the community for a dust monitor in the town
of Boggabri, which is supported by Boggabri Coal (Idemitsu Resources),
Whitehaven has opposed this plan. Although a Dept of Planning
representative recently blamed this on the NSW EPA, there is written
evidence that Whitehaven refused to support the Boggabri dust monitor
unless it were paid for by the NSW Government.

Loss of population has an impact on housing occupation levels.

The CIVEO worker camp benefits to Boggabri are overstated - CIVEO
never patronized the Boggabri butcher, for example, and bought their
meat from elsewhere.

Businesses in Boggabri have not seen the benefit from decade of coal
mines, if anything the reverse has happened. Only one pub out of three
remains in operation.

There is no child care centre and furthermore Whitehaven Coal
approached Narrabri Council and advised them not to invest in child
care in Boggabri, which is a disincentive to young families who may
wish to relocate there. Community bitterness surrounding the child
care centre has caused extreme distress to the Boggabri Business and
Community Progress Association, which strives to secure the survival
of the town.


4. Social impacts of Vickery must be assessed with existing local
mining operations in mind

Social impacts of the mine includes health and well-being, including
physical and mental health. According to the Social Impact Assessment,
existing local mining operations form part of the basis of assessment.
Many impacts are not quantified, such as for example the effect of
mine noise on sleep disturbance and quality of life is completely
ignored in the Social Impact Assessment, yet widely known since a very
large number of Boggabri and Maules Creek residents lodged moving
objections to the Maules Creek noise modification last year.

Health

The Social Impact Assessment does not refer to the growing evidence
about rising bronchial ill-health in Boggabri and Narrabri towns,
reported anecdotally by GPs, and is consistent with health problems in
the Upper Hunter Valley. The reported increase in bronchial
medications has occurred since the time of the Maules Creek mine, and
Boggabri extension. Furthermore I am exceptionally disappointed that
the recently established Namoi Air Quality Monitoring System does not
incorporate dust monitoring in or near the town of Boggabri.

Mental health

The SIA makes much of the fact that "anxiety" is a national problem.
However, I believe that anxiety in coal-affected communities is based
on real triggers that emanate directly from the coal mining industry.
Examples include:

* The threat of loss of livelihood and property rights
* Dividing neighbor against neighbour is a common tactic of Project
Delivery personnel to break down a bloc of landowners who deny access
to their land
* Night-time noise and sleep disturbance is bound to result in some
anxiety

Therefore, to blame the anxiety in coal-afflicted communities on a
general national mental health problem fails to properly assess mental
health impacts of the Vickery coal mine itself on the local community.

Loss of farming families from the region

Over 70 farms have been sold to coal mines in the area around the
Boggabri and Maules Creek region. This has caused leakage of long-term
resident population and replaced them with tenants in the most part,
many of whom do not bring their families with them. Many more tenants
are employees of the mines, and do not farm. Farming land is either
grazed by arrangement with other parties, or left unfarmed, often
because the property has been deemed a biodiversity offset.

Community groups such as the NSW Rural Fire Service, the Country
Women's Association, Meals on Wheels, etc suffer due to the decline in
permanent residents.

This has led to a downward economic spiral in Boggabri.

Employment forecasts unreliable due to the prevalence of drive-in,
drive-out workers

It is a well-observed fact that even mine staff who have an address in
Boggabri are Drive-in, Drive-out workers. They tend to leave their
families in places such as the Hunter Valley towns, and commute weekly
to their work. This has not been addressed in the SIA. Boggabri has
not received an influx of population, and Whitehaven are understood to
encourage workers to live in Gunnedah instead, adding to road traffic.


5. Noise

The Noise Impact Assessment has extremely significant ramifications
for the surrounding community, with impacts that will extend to the
town of Boggabri, based on my knowledge of other coal-affected towns
such as Wollar and Bulga, which are being gradually depopulated due to
mine encroachment and noise issues.

The construction of a coal handling and processing plant at the
Vickery coal mine is an additional threat, as it will produce
unacceptable levels of low-frequency noise. This is well-known to
occur, and is well-documented that CHPPs produce highly disturbing
noise in the 16-25Hertz range. Whitehaven's Maules Creek coal mine has
intractible noise problems at the 50 Hz frequency.

In addition, the Noise Impact Assessment is lacking an All Years Worst
Case Scenario, and fails to include key noise producing infrastructure
in its modelling.

I do not find it credible that the 10 MTPA mine will be quieter than
the 4.5MTPA version that was previously approved in 2015.


6. Coal railway and rail loop

No modelling has been provided as to the movement of surface water
once the railway were to be constructed, and inadequate details of the
construction of the 14 km rail spur. There are inadequate indications
of what sections will be elevated, and which will be embankments.

"The final vertical alignment of the rail and the sizing of the
openings (bridges and culverts) will be determined during the detailed
design stage."- Appendix C Flood Assessment, page 38.

This has very serious ramifications for flood risks and makes it
impossible for anyone to make an informed submission.

Further, acccording to the Dept of Planning, "this is a flood
modelling much different than other developments .. without explicitly
stating where each structure is.... It's certainly a key issue."
[Source: Stephen O'Donoghue, Team Leader, Resources Assessments, Golf
Club meeting 26th Sept 2018]

I do not have confidence in modelling which is based on such vague
assumptions, with no details about where each structure is.

The rail loop itself is particularly too close to the Namoi River and
the riparian vegetation and koala habitat will be lost.

The community has been living under the assumption that there would be
no Namoi River crossing associated with this project, since Whitehaven
Coal was advised the Commonwealth of the Environment that a river
crossing would not be acceptable under the Environmental Protection
and Biodiversity Conservation Act.

The coal railway is one of the most serious concerns about this
Vickery project.


7. Biodiversity - koalas

The entire locality where the Vickery mine is intended to be built is
prime koala habitat, including the area where the rail loop is to be
built.

Koalas are listed as an endangered species under NSW and Commonwealth
legislation. I do not believe that any mitigation measures, such as
relocation of the local koala population can be viable because
alternative habitat is being destroyed throughout NSW and in any case
relocating koalas is known to have a high failure rate.

Impacts on the Koala have also been understated because of
insufficient consideration of impacts upon the full extent of suitable
habitat within the Approved Mine area. Like other cumulative impacts,
the effects on koala habitat have been dealt with poorly in the EIS.
There does not seem to be any limit of the extent of impact being
considered and matters in relation to landscape impacts have not been
considered adequately.

Right now, some of the most important and large nearby koala habitat,
being Vickery State Forest and Leard State Forest are either being
actively destroyed by coal mining, or else they are slated for
destruction in the medium-term.


8. Road Transport

The Road Transport Assessment uses survey data collected in 2012 which
is outdated. It predates the establishment of the Maules Creek coal
mine, the extension of the Boggabri and Tarrawonga mines.

There has not been a thorough assessment of road usage or an
up-to-date road traffic audit identifying cumulative impacts.

Road transport since 2012 has grown dramatically, including mine
workers, transportation of heavy plant and equipment, and increased
road haulage of coal from Tarrawonga mine which gained approval
subsequent to 2012. These are not accounted for in the Vickery Road
Transport Assessment.

Since 2010, the Dept of Planning has continued to approve increases in
truck movements on the Highway from 2MTPA to 3MTPA to 4MTPA, rather
than building the Kamillaroi Highway overpass as promised.

I believe there should be no new coal on the Kamillaroi Highway.


9. Not a "fit and proper person"

The Chief Executive officer of Whitehaven Coal, Mr Paul Flynn, does
not have the "character, honesty and integrity" to satisfy s 83(g)
"fit and proper person" test of the Protection of the Environment
Operations Act. Here is the relevant legislation:

45 Matters to be taken into consideration in licensing functions
In exercising its functions under this Chapter, the appropriate
regulatory authority is required to take into consideration such of
the following matters as are of relevance:
...
(f) whether the person concerned is a fit and proper person,
Note.
See section 83 for provisions relating to the determination of whether
a person is a fit and proper person for the purposes of this section.

83 Fit and proper persons
...
(g) if the person is a body corporate, whether, in the opinion of the
appropriate regulatory authority, a director or other person concerned
in the management of the body corporate is of good repute, having
regard to character, honesty and integrity,

At the company's 2017 Annual General meeting the CEO responded to
questions about the Maules Creek high-risk rating, telling
shareholders that the Level 3 risk rating was the result of complaints
from just one nearby landowner who wanted more for his land, which was
an untruth. The Level 3 risk rating was due to a history of noise
exceedances and pollution problems. The CEO's statement was false, and
has been denied by the NSW EPA. I believe that this makes the CEO not
a "fit and proper person" within the definition of the Protection of
the Environment Operations Act 1997 to hold an Environmental
Protection Licence as a Director of Whitehaven Coal, of which Maules
Creek Coal Pty Ltd is a subsidiary. As a result, Whitehaven Coal
should not be granted approval for the Vickery Coal Mine Extension.

In addition, the history of non-compliance of the Maules Creek coal
mine, the fact that Whitehaven has had a Mandatory Noise Audit at
Maules Creek Coal mine, and a Pollution Reduction Program at the
Gunnedah Coal Handling and Processing Plant, I believe that NSW cannot
afford to take the risk.

10. Water trigger

This Project is a controlled action under the Environmental Protection
and Biodiversity Conservation Act, and is a "large coal mine" under
the terms of the EPBC Act.

This EIA does not provide an adequate amount of detail to enable
decision-makers at the State or Commonwealth level to properly assess
the likely impacts of the mine, and the railway, on the Namoi River,
and the surrounding surface-water and groundwater.

Elsewhere, the EIA provides factually inaccurate or incomplete
information which may a tendency to be misleading.

I do not have confidence that the Namoi River is safe from severe
damage if this mine proceeds, and fear that water quality and
downstream flows will be damaged to the detriment of downstream users.


11. Indigenous culture

From the experience of the Maules Creek mine, Whitehaven continually
ignore their responsibilities in relation to cultural heritage as it
is set out in the Burra Charter and the Policies relating to
Aboriginal Cultural Heritage Valuations set out by the Office of
Environment and Heritage. There has been a lack of any consultation
with the First Nation's People's Knowledge Holders, within the Red
Chief Local Aboriginal Land Council boundaries. Consulting with
Registered Aboriginal Parties is not enough.

No new coal in NSW please!

I am Johannes Brits and I have been a resident in Australia for almost
22 years. I love the fauna and flora of this magnificent country and
see it as my duty as a lover of nature to do my upmost to protect it.

I would like to start in objecting to the short timeframe given to
prepare a submission. 42 is not enough time to prepare a proper
response.

The following points have been brought to my attention and need to be
addressed:

COAL RAILWAY AND RAIL LOOP: No modelling has been provided as to the
movement of surface water once the railway is constructed, and there
are inadequate details of the construction of the 14 km rail spur.
There are inadequate indications of what sections will be elevated,
and which will be embankments.

"The final vertical alignment of the rail and the sizing of the
openings (bridges and culverts) will be determined during the detailed
design stage."- Appendix C Flood Assessment, page 38.

This has very serious ramifications for flood risks and makes it
impossible for anyone to make an informed submission.

Further, according to the Dept of Planning, "this is a flood modelling
much different than other developments... without explicitly stating
where each structure is.... It's certainly a key issue." [Source:
Stephen O'Donoghue, Team Leader, Resources Assessments, Golf Club
meeting 26th Sept 2018]

I do not have confidence in modelling which is based on such vague
assumptions, with no details about where each structure is.

The rail loop itself is too close to the Namoi River and the riparian
vegetation and koala habitat will be lost.

The community has been living under the assumption that there would be
no Namoi River crossing associated with this project, since Whitehaven
Coal was advised the Commonwealth of the Environment that a river
crossing would not be acceptable under the Environmental Protection
and Biodiversity Conservation Act.

The coal railway is one of the most serious concerns about this
Vickery project.

Biodiversity - koalas: The entire locality where the Vickery mine is
intended to be built is prime koala habitat, including the area where
the rail loop is to be built.

Koalas are listed as an endangered species under NSW and Commonwealth
legislation. I do not believe that any mitigation measures, such as
relocation of the local koala population can be viable because
alternative habitat is being destroyed throughout NSW and in any case
relocating koalas is known to have a high failure rate.

Impacts on the Koala have also been understated because of
insufficient consideration of impacts upon the full extent of suitable
habitat within the Approved Mine area. Like other cumulative impacts,
the effects on koala habitat have been dealt with poorly in the EIS.
There does not seem to be any limit of the extent of impact being
considered and matters in relation to landscape impacts have not been
considered adequately.

Right now, some of the most important and large nearby koala habitat,
being Vickery State Forest and Leard State Forest are either being
actively destroyed by coal mining, or else they are slated for
destruction in the medium-term.

Please leave a legacy that you can be proud. This country has an awful
extinction record and damage that has already been done in the pursuit
of fossil fuels are heinous.

Yours sincerely

Johannes Brits

I object to this proposal on a number of grounds. As a mother of two
young Children I have concerns regarding the risk of contamination of
the Namoi River. I do not believe adequate modelling has been done to
mitigate this risk. I have concerns about the koala habitat that is
being put
in jeopardy. Too many of our precious and unique flora and fauna have
been destroyed due to the short sighted actions of corporations. ,
which then demands public money to rectify ie. Animal conservation,
great barrier reef restoration. And lastly, I object to further
investment in coal. Despite knowing full well that globally that coal
is no longer considered best practice and that it is a significant
contributor to global warming, Australia sees the need to continue to
invest in this toxic method. Clean and renewable energy is the only
option if Australia is to preserve its place as one of the most
liveable and well regarded countries on earth. The only reason that
the government choose to continue to deny global warming is greed and
money and that is not a justifiable excuse that I feel comfortable
giving my children as they grow up and I am left explaining the local
and global damage to the environment and to communities that we had
the opportunity to prevent but didn't. Shame on you.