Make a submission on the Underground Expansion Project

Make a submission on Wollongong Coal Ltd’s Underground Expansion Project before 29 August.

Go to the Department of Planning website and make your submission

Some points for submissions follow.  Choose the points that resonate with you, or write your own:

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

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

Some of the reasons for my objection are listed below.

Climate change and Greenhouse Gas (GHG) Emissions

  • Coal mining, whether for energy or steelmaking, produces the GHG Emissions that are causing dangerous climate change. This project is estimated to result in 11,624,000 tonnes of GHG emissions through the mining and the burning of the coal.

A risk to Greater Sydney Water Catchment

  • The mining will take place in the Special Areas of the Greater Sydney Water Catchment – areas that forbid public access because of their sensitivity and strategic importance – and up to the shores of the Cataract Reservoir.
  • Not only will the mining infrastructure, such as access roads and vent shafts, disturb and damage the catchment, the proposal for Bord and Pillar mining will result in up to 100 mm in subsidence.
  • The extraction for the Wonga Central Development Mains extends under the Cataract Reservoir itself. Cataract is severely affected by drought and is currently at only 29% of capacity.  Mining should not be permitted anywhere near Great Sydney water supply reservoirs.

Triple seam mining

  • The mining is particularly risky because a third seam of coal is being mined beneath two previously mined seams. Triple seam mining has little precedent and impacts are difficult to predict.
  • The proponent admits that instability in the overlaying old Bulli seam workings may cause pillar collapse and subsequent subsidence of 1 to 2 metres. It is unacceptable of the NSW government to allow such risky mining in the water catchment for 5 million people of Greater Sydney in a time of drought.

The proponent is not fit and proper to hold a mining licence

  • Wollongong Coal and its parent company Jindal Steel and Power Ltd, are currently the subject of an investigation by the NSW government’s Resources Regulator into whether or not they are a ‘fit and proper’ entity to hold a mining license. The company has a history of failing to comply with conditions of approval.  Even its auditors have questioned its capacity to continue as a going concern; its current liabilities exceed its current assets by nearly A$1 billion.  Wollongong Coal is not a ‘fit and proper’ entity to operate a coal mine in the water catchment of Australia’s largest city.

Impacts on local community

  • The colliery site at Russell Vale is closer to dense residential areas than any mine in Australia. Residential communities have suffered the impacts from this mine over many years, including noise and particulate pollution. In this day and age, Russell Vale is not a suitable location for a colliery.
  • Wollongong Coal plans to build a coal processing plant at the Russell Vale Colliery and process coal on site. The Russell Vale mine is the closest mine to any built up residential area in Australia and is not a suitable area for coal processing.  Moreover, the proponent has been unable or unwilling to comply with many conditions of past approvals and the NSW government has proven to be unable or unwilling to enforce compliance.  Residents have no confidence in  “conditions” or “commitments” to operate the processing plant according to suitable standards.

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

  • Previous applications and approvals promised numerous items to protect the community and environment that have never been met by the proponent. These include but are not limited to: truck loading facilities, sound walls, covered conveyors, limited stockpiles, sealed roadways and realignment of Bellambi Creek. Now in this new revised project, Wollongong Coal is promising the same or similar things.
  • Wollongong Coal is currently operating right at this moment under three non-compliances: the realignment of Bellambi Creek to protect it from pollution and flooding (due Oct 2012); the removal of 200,000 tonnes of oversize coal that was illegally stockpiled on the adjoining slag heap (due July 2019); and, the dedication of land to Council in a 1989 approval from Wollongong City Council (due 1990). All of these obligations still have not been met.
  • A proponent with such a poor record of compliance should not be considered for, let alone granted, approval to mine. The NSW Department of Planning’s inability or unwillingness to enforce compliance (with the conditions that it itself has stipulated) undermines confidence in the planning system.

We ask that you reject this application from Wollongong Coal and commence a process to close the mine at Russell Vale permanently.

Thank you for considering this submission.

Yours sincerely,