Underground Expansion Project EPBC Review – Make a submission

Take 5 minutes to make a submission:


In December 2020 Wollongong Coal received approval from the NSW Independent Planning Commission to expand its Russell Vale mine in Greater Sydney Water Catchment up to the shores of the Cataract Reservoir.  Up to 3.7-million tonnes of coal will be mined over five years using bord-and-pillar mining.  

This approval was a huge blow to the community; more than 600 individuals and groups objected to the expansion, while less than 200 supported it.

But Wollongong Coal can’t go ahead and start mining until it obtains approval under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).  The project has been referred for this Commonwealth approval for two reasons: firstly, the mining will impact a number of threatened species and ecological communities and, secondly, Wollongong Coal will undermine the catchment for the Cataract Reservoir which, as part of Greater Sydney Water Catchment, is a strategically important water resource.

The EPBC referral provides an opportunity to point out the unsuitability of Wollongong Coal Ltd to mine in such a sensitive and strategically important area.  Wollongong Coal has a history of non-compliance with specific legislation, a trust deficit on part of the Illawarra community, and has committed multiple breaches of planning conditions and community expectations.  And while the NSW’s EP&A Act did not allow the NSW Independent Planning Commission to take into account the suitability of the proponent in its decision making, under subsection 136(4) of the EPBC Act, the Federal Minister for the Environment can. The Minister may have regard to “a person’s environmental history” when considering whether to grant an approval and the conditions under which an approval would be granted.

If you’d like to find out more about Wollongong Coal, its mining operations and it’s environmental history, read this letter to the Federal Minister for Environment from Illawarra Residents for Responsible Mining Inc and Lock the Gate Alliance.

Make a submission

There is now additional opportunity to make comment on or before 25 February 2021 by emailing the mining company’s consultant, Umwelt, on mail@umwelt.com.au or mailing to Umwelt, 75 York Street, Teralba, NSW, 2284. Please copy your comments to epbc.comments@environment.gov.au

Need more details?

Details are provided in Wollongong Coal’s Draft Public Environment Report, entitled “Russell Vale Revised Underground Expansion Project – Public Environment Report EPBC 2020/8702”.  The report can be downloaded from Wollongong Coal Ltd’s website (third item under “EPBC Approvals”).

There is also a detailed letter to the Federal Minister for the Environment about Wollongong Coal, its mining operations and its environmental history.

Some points for your submission

Here are some points that you may like to include in a brief submission:

Russell Vale Revised Underground Expansion Project, Russell Vale NSW, EPBC Ref: 2020/8702

I write to comment on the Russell Vale Revised Underground Expansion Project, EPBC Ref: 2020/8702 and ask that the project be refused approval under the EPBC Act.

  • The proposed mining will take place in the Schedule 1 Special Areas of Greater Sydney Water Catchment, an integral part of a strategically important water resource upon which 5.5 million people of Greater Sydney rely.  Underground mining is a land use which is fundamentally incompatible with a water catchment.  The proposed mining will cause subsidence, surface cracking and water contamination up to the shores of the Cataract Reservoir.  The damage to the water catchment may be much greater than expected, due to the risky, complex and poorly understood triple seam mining plan.
  • A number of vulnerable and endangered communities and species are expected to be negatively impacted by the project, including:
    – Coastal Upland Swamps in the Sydney Basin Bioregion endangered ecological community
    – Giant Burrowing Frog
    – Littlejohn’s Tree Frog
    – Macquarie Perch
    – Silver Perch
    – Prickly Bush-Pea
    Since the Black Summer bushfires killed so much of our native flora and fauna, it is more important than ever to slow the extinction crisis and stop destroying our unique native species and ecological communities and their habitat.
  • Wollongong Coal Ltd does not have a satisfactory record of responsible environmental management and compliance with environmental laws.  In the past 5 years, the company has been the subject of more than 30 penalties, warnings, orders and investigations due to its failure to comply with mining conditions, standards and requirements.
  • The company’s serial breaches of planning conditions and community expectations have led to a trust deficit on the part of the Illawarra community.  Wollongong City Council has formally objected to this project on the basis of “Wollongong Coal’s poor track record on workplace safety, debt servicing and operating compliance”.  Furthermore, the company’s debts – liabilities exceeding assets by over $1 billion – mean it is unlikely to improve.

I urge you to refuse approval for this project.

Yours sincerely,



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