Vickery Mine Extension

Please see attached files

attached sub

See attached submission.

this mine extension will impact heavily on both us and our neighbours

As per attachment, please find Absolute Services Group's submission in
support of the Vickery Extension Project.

As per attachment, please find ASG Equipment's submission in support of
the Vickery Extension Project.

As a community member in a neighbouring community whose livelihood
depends on clean water and arable agricultural land I wholeheartedly
believe the Vickery mine extension Environmental Impact Assessment
should be rejected.
The mine poses the risk of irreversible damage to the Namoi River, the
surrounding surface water and groundwater, and the health and
well-being of human and animal populations across the region.

* This is not my full submission - our Region is in the midst of a
catastrophic drought - as a farmer I am busy from sun up to sun down
and believe that due to the short public exhibition period I am
severely limited in how much time and effort I can spend on my
response to this huge and complex document. 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. It is extremely inconsiderate
given the Regions current state of drought and the pressures families
are under on a daily basis, without having to digest and respond to
documents such as these in such a short amount of time.

* The EIA does not make any attempt to apply the Precautionary
Principle to its assessment of the cumulative impacts of this mine.
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.


* 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.
The Social Impact Assessment does not refer to the growing evidence
about rising bronchial ill-health in Boggabri and Narrabri towns, and
is consistent with health problems in the Upper Hunter Valley. 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. WHY??
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.
This MUST be addressed immediately.

* 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.
Small communities simply cannot afford to lose families to FIFO or
DIDO workers - it does not sustain local business nor improve living
standards for locals.

* 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.


* 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.
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.

* 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.
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.

* 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.

* 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.

* From the experience of issues over 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.

With little time to respond I would again like to reiterate that I
WHOLEHEARTEDLY object to the approval of this EIA and urge the
Department to allow the community, region and wider community a chance
to respond in a proper manner. Elections are won and lost on the way
in which Governments listen to their constituents - this issue may
very well be another nail in the coffin of a government refusing to
embrace climate change and listen to the people living in these
communities. As a Coonamble local I know only too well how devastating
the threat of mining on our communities can be - our water is too
precious to risk FOR ANY REASON. Prime Agricultural land also needs to
be protected - we cannot afford to continue losing Prime Ag land -
there will be a food crisis as well as a water crisis - HOW DO WE LIVE
WITHOUT FOOD AND WATER?
I

Please Refer to attached PDF

I object to this. Please see attached document.

my submission is in a pdf document in the file attachment 1

Please find attached the MCCC objection to this project.

Regards

MCCC

See attached.

Refer attached letter of support for the Vickery Extension Project.

The NSW Farmers' Association (NSW Farmers) appreciates the opportunity to
comment on the Environmental Impact Statement (EIS) for the proposed
expansion to the Vickery Coal Mine located near Gunnedah, NSW. We have
a number of concerns with the development, particularly around the
impacts to neighbouring landholders and the close proximity to the
Namoi River.

NSW Farmers is Australia's largest state farming organisation,
representing the majority of commercial farm businesses in NSW,
ranging from broad acre, meat, dairy, wool and grain producers, to
more specialised producers in the horticulture, egg, pork, oyster and
goat industries.

The proximity of the Vickery Extension Project to the Namoi River and
the associated floodplain presents a range of worrying potential
impacts. The EIS lacks sufficient detail relating to the potential
risks associated with the expansion of the mine on floodplain areas
and the impacts on the associated water resources of the Namoi River,
tributaries and aquifers. It is critical that the proposed Vickery
expansion does not cause or contribute to adverse impacts to the water
resource in particular, but not limited to, altering flood risk,
up-catchment flows, aquifer storages and water quality.

Additionally, the EIS provides limited engineering details in relation
to the construction of the rail spur over the Namoi River and
floodplain areas. The construction of the rail spur has the potential
to affect water movements (including surface water and river flows),
therefore detailed analysis of these impacts and associated risks must
be taken into consideration. The accumulation of flood debris against
the construction also has the potential to increase flood levels,
which may contribute to the flood risk in Gunnedah, especially in
areas already prone to flooding. Changing variability in climate may
also see increasing intensity and frequency of rainfall events. This
needs to be considered in flood risk assessments over the life of the
project.

A number of nearby landholders have raised concerns about the likely
creation of dust and noise disturbance during the construction and
production phases of the proposed expansion. NSW Farmers acknowledges
the efforts taken to model and develop strategies to minimise the
potential impacts on nearby landholders, although there are perhaps
still questions as to their accuracy and applicability in a real word
setting. With the mine expansion more than doubling the size of
production and the proposed expansion area being in closer proximity
to landholders, these landholders and the wider community must be
assured that the creation of dust and noise pollution will be minimal.

In respect to the EIS of the Vickery Expansion Project, we seek
additional information about the details of the expansion project, in
particular the construction of the rail spur and the close proximity
of the expansion to the Namoi River and associated floodplain and the
risks this imposes on the water resource. We also seek an extension to
the exhibition period from 42 to 90 days to allow for landholders and
stakeholders to analyse the extensive documentation, seek expert
advice and consider the proposal.

Overall, we appreciate the opportunity to comment on the EIS for the
Vickery Expansion Project and strongly believe that the best outcomes
will be achieved if the concerns of landholders are genuinely
considered alongside other stakeholders.

People for the Plains Submission to Vickery Extension EIS
As the community was informed by the Department's Mike Young, that we
are not required to fully read and assess the EIS, we are highly
concerned that this belittles the Government's own "approvals" process
and the role that the community plays in it. Given the impractically
short time frame given to assess the 4,000 page document at a time of
great stress and time constriction for rural people, this submission
seeks to make high level comment only at this stage. We seek to have
multiple and more in-depth comment on the project at other stages in
the process.
We object to the Vickery Expansion on the following grounds:
1. Whitehaven Coal has poor environmental record
The proponent is not a fit and proper person to be eligible to
undertake another mining operation. Maules Creek mine, run by
Whitehaven have been branded "Rogue Operator" and had something like
63 breaches of their approval conditions when the Independent
Environmental Audit was undertaken in 2015.
A review of approval conditions by Namoi Water also found a range of
inconsistencies and lack of data in regards to monitoring of water
impacts at Maules Creek (Attachment One). The Independent
Environmental Audit of 2015 also noted this as a breach.
Of greatest concern is the complete lack of baseline monitoring data
for groundwater levels due to the destruction of the monitoring bores
from the progress of mining. Also concerning is the lack of updates to
the Water Management Plan and water model for the full first five
years of operation, despite the clear conditions in both the Project
Approval and the Environmental Protection Licence.
Throughout the social impacts assessment of the EIS it made it very
clear there is already a very high level of distrust of the proponent,
concerns for the likely impacts and scepticism of the models.
The proponent spends considerable time explaining that the project was
approved five years ago. Surely this would indicate ample time in
which to consult with key people, build trust with them and explain in
detail, the project. And yet, the result of all that time is actually
less trust and open and more hostility.
Furthermore, local community members have first hand experience from
those impacted by the Maules Creek mine to learn from. This should be
a clear warning for the Department that this proponent has no interest
and/or ability to build respectful relationships with the community.
It is unconscionable to be considering the approval of another mine
for a company which clearly is not adhering to its conditions of
approval for the mines it already operates. Until the proponent can
prove that it can wholly and fully satisfy its conditions of approval
on its current mines, it should not be considered fit and proper to be
approved another mining production licence.
2. Vickery Extension is More Appropriately Characterised as a New
Approval
We believe it is disingenuous to consider this application as an
extension only. The "extension" EIS seeks to more than double the
production used in the original Vickery EIS (from a maximum 4.5Mtpa to
a maximum of 12Mtpa). This "extension" EIS also includes a raft of new
and highly significant infrastructure not included in the original EIS
including:
* A new borefield with ten new bores
* A new coal rail line, including rail load out facility, conveyor
belts and a rail line crossing the floodplain
* A new coal handling and processing facility
Each of these new pieces of infrastructure are very significant and
should be considered as a full EIS of the project in its entirety.
We seek that a full EIS be submitted to the Department for full and
proper assessment.
Furthermore, we note that the proponent for the Vickery Extension is
Vickery Coal (see more below) - surely this is a new proponent to the
one that received the original approval? Surely this new proponent
should reapply for the approval of the whole project.
3. Change of Proponent Name to Meet SEARS Requirements
The Secretary's Environmental Assessment Requirements (SEARS) have
been modified a number of times during the long duration since the
original approval was given. We note one particular change that
corresponds with an interesting chain of events.
In all SEARS modifications up until the most recent one (19th July
2018), the proponent's name is Whitehaven Coal Limited.
The Supplementary SEARS - Commonwealth Requirements were issued
sometime between March and July 2018 (no date is given). It includes a
requirement by the Commonwealth Government to declare the
Environmental Record of the person taking the action - section as
pictured here:

Interestingly, in the Revised SEARS provided by Whitehaven to the
Department dated 19th July 2018 it lists the proponent as Vickery Coal
Pty Ltd.
An ASIC search (Attachment Two) shows that this entity, Vickery Coal
Pty Ltd was formed on 17th May 2018.
This allows Whitehaven to deceive the Commonwealth Government and the
community by stating in the EIS in section 6.1.2 that the proponent
has no environmental breaches or proceedings against them.

4. No Cumulative Assessment Guideline is Available
The Vickery coal mine will be a huge scale operation. It will join the
huge scale operations at Maules Creek (12 Mtpa), Narrabri Underground
(6Mtpa) and Tarrawonga (2Mtpa), along with the Boggabri mine all in
very close proximity. There is simply no doubt that the addition of
Vickery will have a cumulative impact on the water resources,
agricultural resources, social resources, community infrastructure and
biodiversity resources of the area. This is a classic example of the
singular approval process that is no longer acceptable.
The Department has said that they are currently developing a tool for
assessing cumulative impacts of multiple large scale, state
significant projects. This project approval process must be halted
until this tool can be used to fully assess the cumulative impacts of
the massive Vickery project.
5. Complete Lack of Planning for the Rail Overpass
There is no way this project can be approved when it does not include
a proper plan for the rail line. To cross directly across the
floodplain of the Namoi River as is proposed, is ridiculous and highly
risky. To identify this as being the "most feasible" way is a joke.
The proponent should justify clearly and in detail why they cannot use
the existing rail line that crosses the floodplain further to the
north. They should be requested to exhaust all other options before a
second rail crossing is even vaguely entertained. Then and only then,
it should be properly designed and the risks properly assessed. No
assessment can be done on the information currently provided, the
proponent is wasting the Department's and the community's time.
6. Errors in Water Estimations
We are concerned that the impacts to water resources from the current
mining operations in the region have been underestimated due to
modelling errors.
Table 3-4 in Appendix J outlines the change in water requirements
between the original application and the extension. The EIS states
that the original approval is for 4.5Mtpa maximum output, and the
extension seeks approval for 12Mtpa maximum. Comparing these directly
means the Extension is actually a 160% increase in production. With
that level of increase in production it could be assumed the water
needs would increase at a similar level and yet the following changes
are noted in Table 3-4:
* Namoi River usage will change from 1,155ML to 1,751ML (51% increase)
* There will continue to be 2m drawdown of Groundwater for
neighbouring bores
* Porous Rock will increase from 430ML to 600ML (39% increase)
* Namoi Groundwater increase from 180 ML to 396ML (120% increase)
* TOTAL water requirements increased from 1,765ML to 2,747 ML (an
increase of 56%)
Are these reasonable assumptions?
Also the coal processing facility is being moved to this site which is
also a water user.
Furthermore, the proponent has stated that they do not need to secure
any new water licences. The Maules Creek mine during this extended dry
period of late has struggled to maintain enough water for its daily
operations.
How is it possible to build another new mine the same size as Maules
Creek mine and not need any new water licences?
However the Water Balance in Appendix B - Surface Water Assessment pg
117 section 10.7 states the total water use as:
* life of Project average licensed extraction from the Namoi River
ranges from 470 to 655 ML/year, with annual extraction ranging from 0
to 1,465 ML/year, depending on mine year; and
* life of Project average licensed extraction from groundwater bores
ranges from 57 to 107 ML/year, with annual extraction ranging from 0
to 390 ML/year.
How can we have faith that the proponent has properly modelled the
water impacts when their EIS contains conflicting information?
7. Illegal Surface Water Take Could Again Be Facilitated
A report by Lock The Gate and EDO NSW (Attachment Three) shows water
taken from overland flow above the harvestable right of 10% of
rainfall, by Maules Creek mine in 2016. This is currently being
investigated by the Natural Resources Regulator. We have strong
suspicions that the same will occur at Vickery, where the proponent
captures more overland flow than it is legally entitled to which it
uses to run the mine, freeing up its water licences. This allows the
proponent to trade their water licences and make a profit for the
company.
With this track record, the proponent (Whitehaven Coal, not Vickery
Coal) should not be give the rights to build another mega mine a
similar size to Maules Creek.
Appendix R pg 97 discusses the idea of a "make good" for water impacts
to surrounding properties and communities. However the community is
hugely sceptical about this as a solution.
Already many bores have been lost in the Maules Creek area and yet no
"make good" has been seen. Experience has shown us that it is a time
consuming and often expensive process to prove "make good". All the
requirement is on the person who has lost their water to prove the
mine caused it.
If this mitigation strategy is to be used, the proponent should prove
that they will follow through in the Maules Creek situations first,
before more approvals should be considered. Their actual approach
usually is to malign, humiliate and bully anyone who may mention the
loss of water - this has been seen also at Werris Creek mine.
8. The Open Cut is Too Close to the Namoi Alluvium
The open cut is located too close to the Namoi alluvium. It will
create seepage from the alluvium and the Namoi River into the coal
seams and the mine pit. The proponent's statement that the mine will
have "No direct contribution of groundwater from the Upper Namoi
Alluvium" is untrue. The EIS clearly identifies loss of water from the
alluvium for generations to come.
The proponent has made no effort to help the community understand the
true water impacts from this project. At public meetings held recently
direct neighbours of the project have openly stated that they have not
had communication with the proponent in terms of water.
The EIS is presented in a way that makes it difficult to ascertain the
water impacts. We seek a clear diagram outlining the groundwater
drawdown of the Namoi alluvium.
As mentioned above the proponent states they have enough licences
currently for this increased take of 2,747ML per year.
We are highly concerned about the lack of clear estimations of
expected surface water capture, given this is one of the main ways of
meeting the mine's water needs.
Whilst the water modelling predicts an increase in rainfall recharge
of 0.6ML per day "due to infiltration through the waste rock
emplacement" (Appendix A pg 42) we are concerned that this recharge
will bring with it the spoil pile elements of Arsenic, Boron, Antimony
and Selenium. Eventhough these metals are identified in the EIS it
dosn't go on to give analysis of the concentrations of these metals in
the alluvium once it has moved through the western emplacement area.
It is summarised with "the Project would not increase concentration of
these metals in comparison to the in-situ material." But no evidence
is presented to support it.
We do not believe there is an adequate plan to manage the runoff from
the mine site. In a big rainfall event runoff is likely from the mine
site and it is likely to go into the River contaminating the riparian
zone. We are also concerned about locating such a massive overburden
pile right next to the river and the implications during a flood
event. We do not believe this has been adequately dealt with in the
EIS.
We note that the groundwater assessment doesn't include much actual
data. However we understand that at least four monitoring bores were
installed by Coalworx and much data is likely to have been collected
over this time. We seek for the release of this data and it to be
incorporated into the EIS to allow for a fully informed model.
9. New Mine Opportunity To Improve Air Quality Monitoring for
Community
The new Air Quality Monitoring Network proposed for the Namoi region
does not include a monitoring station for Boggabri. This township is
ringed by mines and by far gets the greatest air quality impacts of
any town in the region. The town includes two schools, a preschool, a
medical centre and hospital and a aged care home. These places house
the most vulnerable of our community members and should have an air
quality monitoring system available to them.
10. Greenhouse Gas Emissions from This Project Are Too Great To Risk
In the absence of federal legislation around carbon emissions, even
greater emphasis is placed on the NSW Climate Policy. The NSW Climate
Policy is committed to the Paris Agreement. Also under the mining
State Environmental Planning Policy Scope 3 emissions from mining
projects are relevant. It is critical that the NSW Government takes
the NSW Climate Policy into consideration when reviewing this project.
Appendix E outlines the Greenhouse Gas Emissions (GHG) expected for
the Vickery project. They outline an average of 15 million tonnes per
year, every year for the 25 year lifespan of the project. I total 375
Million Tonnes of carbon will be emitted by Vickery.
Whilst Appendix J seeks to cost the economic impacts and benefits of
the project, it drastically undercuts the cost of carbon. Firstly, as
indicated in Table 3-9 it completely ignores the Scope 3 emissions
created by the project. This assumes that the community more broadly
must bear the cost of these emissions created by Whitehaven.
Secondly, an anomaly is identified in the GHG emissions calculations.
Table 3-6 outlines that the original mine approval estimated the Scope
1 and 2 emissions over the lifespan of the mine to be a total of 4.8 M
tonnes. However, strangely, with an increased production (almost
double) of the extension the GHG emissions are predicted to be reduced
at 4.1 M tonnes for the lifespan of the mine. How can a project twice
as big, create less emissions?
At a valuation of (the low end of central costing used in Appendix J
at $24) the true cost of these emissions would be in the vicinity of
$360,000,000. A vastly different number to the number identified in
the report of $52M (down from $57M from the original project
approval).
Furthermore, the number used in the summary of the GHG emissions work
is actually $0.28M as it is taken as the "NSW share of costs
associated with increased GHG emissions has therefore been calculated
with reference to NSW GSP as a percentage of world GDP, which is
around 0.54 per cent. On that basis, the social costs of the GHG
emissions associated with the Project using futures prices for EUA
futures amount to around $0.28 million in NPV terms, compared to $0.31
million in NPV terms for the Approved Mine. (Appendix J pg 38)".
Furthermore, two weeks ago Whitehaven agreed to incorporate the
recommendations of the Task Force on Climate Related Financial
Disclosures into its Annual Report for next year. Brian Cole told the
community they were not really involved in the climate aspects, but
this is not true.
The recently released International Panel on Climate Change Report
states categorically that the burning of fossil fuels must be urgently
reduced, the International Energy Agency states that this will force a
decrease in demand for coal, halving by 2040. It doesn't appear as if
a decreasing demand for coal has been factored into the financial
feasibility of the project.
11. New Social Impact Guidelines Not Used in Original EIS
New Social Impact Assessment Guidelines were only bought in by the
Department in 2018 therefore the Vickery project has not been
considered under them. It is difficult to properly assess the
extension without consideration of the full project in terms of the
newly released social impact guidelines.
12. Cultural Heritage Impacts Understated
Significant social impacts will occur through the destruction of
historical property "Kurrumbede". As noted in the EIS the property is
to be of at least "local" significance (P44) and appears to recommend
it to be heritage listed. Unfortunately the property, home and other
infrastructure is not currently protected by heritage listing and has
been identified to be impacted by mining. The EIS also does not
provide for a clear plan for returning the property to the community
upon closure of the mine.
Another important building is also located on Kurrumbede and its
significance has been ignored. This building was home to Australian
Freestyle Multi-Olympiad Boy Charlton during his 8 years as a jackaroo
on the historical property. During this period he would train in the
Namoi River adjacent to Kurrembede and went on to compete at three
Olympic games. He won one gold medal, three silver and one bronze and
set five world records.
This building has been under lock and key for many years and was never
assessed for its national heritage significance nor are there any
plans for its protection and preservation. This is a large omission.
Appendix R section 4.3.3 states that Kurrumbede is already heritage
listed, demonstrating inconsistencies yet again in the EIS.
We do not believe a full and proper assessment of the property have
been undertaken. We note prior studies have been undertaken by Dr Sue
Rosen and we request that her report be made available publicly and be
included as part of the EIS and be incorporated into any future
project conditions of approval and mitigation strategies in an effort
to protect this heritage.
13. Exclusion of Relevant Narrabri Shire Council Extractive Industries
Policy
The Social Impacts chapter (Appendix R) outlines applicable plans for
the region (p57) however it omits the Narrabri Shire Council
Extractive Industries Policy which includes a few applicable points
including:
* Demand a `Nil' effect position in regard to the quality of surface
water, domestic, stock and irrigation aquifers used by our community.
* Demand a `Nil' net effect on above ground environmental assets.
* Adopt a position requiring that mining proposals are designed to
have no final void;
This policy has not been upheld with the EIS.
The Social Impacts Chapter does a good job in outlining the current
employment situation across the region. It points out that Narrabri
Shire is a net (P67) importer of miners. There are currently 1,124
jobs available and only 313 miners (as of 2016). Whilst Gunnedah Shire
is a net exporter of miners with 737 miners living there for only 227
mining jobs. Clearly, this shows that many miners live in Gunnedah
Shire and travel for work in Narrabri Shire.
14. Traveling Stock Route Closures Impact Aboriginal People and
Graziers
Partial closure of Braymont road would stop cattle movements along the
Travelling Stock Route (Pg91) towards Blue Vale rd at the Crown land,
plus stop cultural access to the river. TSR's play a vital role to
aboriginal people and graziers and a mining company should not have
the power to simply close this public land that provides other
functions. Aboriginal people are extremely limited in their ability to
access their traditional lands, especially land with river access.
15. Dark Sky Park Impacts Should be Assessed in Full EIS
Siding Springs is an important scientific asset and employer in the
region. It is now classified as a Dark Sky Park, indicating the
importance of a lack of night time light pollution. This
classification has been made since the original approval of the
Vickery mine. Therefore the full project should be subject to a full
EIS, not just the Extension. The light pollution impacts on Siding
Springs are mentioned on page 95 of Appendix R.
16. Agricultural Industry Impacts Grossly Understated
Pg 96 Appendix R states that the project is not expected to impact on
farming livelihoods. This is an outrageous statement made a number of
times by the proponent. It goes on to state that it is all grazing
country (Class 4 only). Whilst the proponent currently owns the land
area on which the mine is to be built, they have deemed this to be not
good quality agricultural land. However, areas that will fall under
the voluntary acquisition zone are very good quality land, with
significant infrastructure investments on them and will find it
impossible to continue to farm it.
17. Impacts to Boggabri Community Are Significant and Not Addressed
Appropriately
There is no doubt that the township of Boggabri will bear the brunt of
the negative social impacts from the establishment of Vickery. The EIS
outlines these likely impacts in Appendix R, however the mitigation
and management strategies are woefully inadequate.
Appendix R page 103 outlines the huge and sudden population growth
expected for Boggabri with 71 new residents (28 families) expected.
Whilst the EIS spins this as a positive for creating a "safe, healthy
and welcoming community" leadership should be shown in managing this
massive upheaval to the community. The EIS states that this is an
8.28% population growth which will occur for the ongoing operational
phase following the one year construction phase. This is an
unsustainable level of growth to occur in one year on a community that
already suffers from myriad social impacts from the current mining
projects.
It goes on to describe how this will change the character of Boggabri
on pg 105, yet it is not sensibly and thoroughly described how this
will be mitigated and/or managed. The EIS state that Whitehaven Coal
(or do we call them Vickery Coal now?) should have an active role in
reducing the conflict, particularly through the use of transparency.
Sadly the track record to date demonstrates the proponent's inability
to be transparent and active.
As one simple example; At a meeting with Brian Cole (Whitehaven) and
the Boggabri and District Business and Community Assoc (13th August
2018) that was intended to update the community about the Vickery
project, Brian excluded the fact that a new borefield would be
established. There was high concern for the water impacts and Brian
said the company did not need to buy any new licences to run Vickery
and never once mentioned the new borefield. This is another example of
the deceit by omission shown to the community shown by the proponent.
During this meeting and again at the Emerald Hill Community meeting
Brian Cole went to great lengths to explain how Whitehaven were
employing a large number of aboriginal people. He then stated that
these people would have otherwise been on unemployment benefits. This
is a despicable statement to make, twice, and shows the complete
contempt that the proponent has for the community.
The EIS identifies that Boggabri requires the construction of 19 new
homes to handle the increased population (because essentially all new
jobs will need to be filled by people from outside the region) but
when the negative impacts are assessed it zooms out to an LGA scale
and indicates that there will be no negative impact at an LGA level.
There are no concrete ways identified to overcome this housing
shortage, meaning locals will be left to overcome the problems created
by the proponent.
It is simple to ground-truth these grand estimations as the Boggabri
community has been through exactly this same process just five short
years ago. In the EIS for Maules Creek promises for jobs and business
development as well as support for social infrastructure was espoused
by the proponent. The community is tired of these games and seeks only
honesty from the proponent in an effort to proactively and positively
plan for the likely impacts caused by this mine.
Another mine of this scale could have huge opportunity to improve the
lives of the people of Boggabri and surrounds. But to start with a
basis of exaggerations, understatements and lies as is seen in the EIS
is not a healthy way to begin.
18. Insufficient Rehabilitation Plan
There is no rehab planned for the first 7 years of the mine life. This
is unacceptable and rehab should begin from the start of the impacts
from the mine.
19. Agricultural Impacts Understated
Appendix H provides the agricultural impacts assessment and it
understates the impact that the Vickery mine will have on agricultural
production of the region.
To start with, below is a map from 2014 showing the country owned by
mines in the region. This is drastically outdated now and many more
properties have been purchased since. But a map similar to this should
have been provided in the EIS in order to understand the full gravity
of the agricultural land taken out of productivity due to mining.
Already more than 76 family farms have been purchased by Whitehaven
around this region. Not only has this hollowed out the community,
creating large social impacts, it has also taken this land out of
agricultural production. Economic analysis should also be undertaken
of the agricultural production lost due to mining - this is absent
from the EIS.
A gross misrepresentation is being attempted by the proponent. They
say boldly that the project will not have any impact on strategic
agricultural land. Assumedly they come to this assumption based on the
fact that they own the area of land on which the mine infrastructure
is based. This has not been used as productive agricultural land as it
is owned by the proponent. However the voluntary acquisition zone of
the mine (that area that will be unliveable due to the impacts of
mining) does include strategic agricultural land that is highly
valuable, with good quality soils and very high levels of agricultural
infrastructure.
This mine will cease the ability of a family with "intergenerational
ties to the land" to allow them to continue to farm even though
"consultation identified their desire to stay on the property, however
they fear it would be uninhabitable due to noise and dust impacts"
(Social Impact Assessment). If this property were rendered
uninhabitable by noise impacts from the mine, that would have
considerable implications for agricultural production that are not
considered in the EIS.
There are six other properties that have at least one residence within
approximately 1 km of the rail spur, with two of those properties
bordering the rail spur.
The economic impact assessment includes the impact from agricultural
land used as biodiversity offset and that disturbed directly under
infrastructure but excludes land expected to be acquired by the
proponent under the Voluntary Land Acquisition and Mitigation Policy.
This should also be considered under the Cumulative impacts Guidelines
(yet to be developed by the Department) for all of the mines in this
region.
Attachment One - Namoi Water assessment of Maules Creek Conditions of
Approval
Attachment Two - ASIC report on Vickery Coal Mine Pty
Attachment Three - EDO and LTG report on surface water take by Maules
Creek mine

Respose

Liverpool Plains Shire Council submission attached

Uploaded

The attached submission is made jointly by Maureen Kingshott and Barbara
Guthrie

Armidale Branch NPA objects to the Vickery Mine extension project