Wollongong, New South Wales — Residents are this morning celebrating the Independent Planning Commission’s rejection of the controversial Dendrobium Mine Extension, holding a party outside of State Labor MP Paul Scully’s office. On Friday, the IPC rejected the proposed expansion within the special areas of the Greater Sydney Water Catchment, citing that “the risk of adverse events to the environment are high and likely to be irreversible”.
Protect Our Water Alliance (POWA) spokesperson Rada Germanos said “it is only through the hard work and commitment of our communities that this enormously destructive project has been stopped – if it weren’t for the hundreds of locals who wrote opposing submissions to the original EIS, this approval would have been rushed through.
The IPC has made the sensible decision, the decision that protects priceless Aboriginal heritage, endangered ecosystems, as well as the water security of five million people. But this decision would not have been made if the community didn’t stand up and take action.”
Several state politicians, including Opposition Natural Resources Minister and Wollongong MP Paul Scully, expressed surprise and concern about the IPC decision, citing concerns for the job impacts in the Illawarra region. Deputy Premier John Barilaro has even vowed to attempt to overturn the IPC’s decision. This comes as the Peabody Metropolitan Mine in Helensburgh has halted production and locked its workers out for a further two months, citing a downturn in the global demand for coking coal.
“It is clear as day that the Illawarra needs a transition plan – a plan to move us away from dirty destructive industries, and towards cleaner manufacturing technology such as Green Steel. If our politicians are genuinely concerned about jobs, then they should be focusing their energies on a just transition plan for mine workers, rather than just backing their mates in the coal lobby time and time again. The original Green Jobs Illawarra Plan was written in 2009 — and has sat on the shelf for the last decade.”
“The IPC has made a decision in the interests of the community, and the community will continue to fight to make sure this decision is upheld. POWA will continue to fight for a total ban on mining in the water catchment, a ban that will protect ecosystems, protect culture, and protect the water that we all depend upon.”
Independant Planning Commission’s (IPC) public engagement in late 2020 recieved 1550 unique written submissions, with 60% of those opposing the Dendrobium Mine Extension.
Ultimately, the IPC sided with the concerns of the community, and rejected the proposed expansion.
As an excerpt from the Executive Summary (p 4) explains:
“Significant concerns were raised during consultations undertaken by the Department [of Planning, Industry and the Environment] and Commission in relation to several key issues: mine design, subsidence, ground and surface water impacts, biodiversity and upland swamps, Aboriginal cultural heritage, greenhouse gas (GHG) emissions, the ‘NorBE test’ and bushfire risk…
However, after careful examination of all the evidence and weighing all relevant considerations, the Commission has found that the longwall mine design out forward by South32 does not achieve a balance between maximising the recovery of a coal resourse of State significance and managing, minimising or mitigating the impacts on the water resources and biodiversity and the other environmental values of the Metropolitan Special Area,
For the reasons outlines in this Statement of Reasons, the Commission is of the view that the impacts of the Project outweigh the benefits from an approval, such that the Project should be refused. The Commission concluded that the level of risk posed by the Project has not been properly quantified and based on the potential for long-term and irreversible impacts — particularly on the integrity of a vital drinking water source for the Macarthur and Illawarra regions, the Wollondilly Shire and Metropolitan Sydney — it is not in the public interest.”
Wollongong, New South Wales — Community group Protect Our Water Alliance has expressed outrage at the NSW government Independent Planning Commission’s approval of Russell Vale mine expansion despite widespread community opposition and ongoing uncertainty about the damage that it will cause to the Special Areas of Greater Sydney Water Catchment. However, Russell Vale still requires approval under the EPBC Act as a controlled action and while the IPC was not required to consider Wollongong Coal Ltd’s fitness to carry out the mining, the federal approval will require this.
Protect Our Water Alliance (POWA) spokesperson Kaye Osborn said “Throughout the IPC decision process it became clear that the NSW Department of Planning and Minister Rob Stokes don’t actually know how much damage this mining expansion will do to our water catchment. It’s concerning that they have such disregard for our vital water resources when less than a year ago we were in crippling drought.”
Wollongong Coal will mine up to the shores of the Cataract Reservoir, which supplies water to Camden, Campbelltown and Wollondilly, and is a backup supply for Greater Sydney. The bord and pillar mining method which will mostly be used is expected to be less damaging than longwall mining. However the expansion area is already riddled with historic mines making it unstable; with key risk factors for cracking and subsidence unknown due to inaccessibility of the old mine workings, even the Resources Regulator said “we are in the dark in making decisions in relation to Russell Vale Colliery’s proposed revised underground expansion project”.
“It will be residents and taxpayers who will pay the price of this mining expansion through further damage to the water catchment, more pollution of our air and waterways and accelerating climate change,” said Kaye Osborn. “The 118 conditions of consent are useless if the NSW government will not monitor and enforce them and Wollongong Coal has a long track record of serial non-compliance with conditions of development approval.”
“The IPC has also failed to address the issue of water discharge from the adits in Russell Vale, merely requiring the company to “make a plan” for how they are going to deal with the water outflow that is expected to commence in 2057. The NSW government is leaving a legacy of catchment damage, water loss and contamination, an eternal cost of mining for future generations to pay.”
“The IPC was not required under the EP&A Act to consider whether the proponent is “fit and proper” to carry out the mining in a responsible and compliant manner. However, the project still requires approval under the EPBC Act, which does have a requirement to consider the environmental history of the applicant. This will be an interesting process for Wollongong Coal Ltd and is the next hurdle that the miner will need to jump.”
“POWA will continue to oppose the Russell Vale mine expansion, and all mining in our water catchment.“
Longwall mining is the most destructive form of underground mining possible.
Long gone are the days when hundreds of miners were employed to chip away at a coal seam with hand picks.
Now huge machines called shearers rip through a “wall” of coal typically 250 – 400 metres wide. As the shearer removes coal, hydraulic supports hold the roof of the coal seam up. As the shearer moves forward, the roof collapses behind it. This causes subsidence (vertical sinking) and fissures to appear in the ground above.
The Dendrobium Mine Extension Project proposes 28 years of destructive longwall mining in the water catchment for Wollongong, Macarthur and Sydney. It will result in damage and loss of water to swamps, water courses and the Avon, Cordeaux and Nepean Reservoirs. Sydney is the only city in the world that allows longwall mining in a publicly owned water catchment. The proposed mining is in the protected “Special Areas” of the water catchment upon which 5 million people rely for drinking water. Dendrobium already has the highest water loss of any mine operating in the Greater Sydney Water Catchment area. This proposed expansion would more than double the water loss from our catchment due to mining operations.
The Department of Planning, Industry and Environment (DPIE) has acknowledged the damage that the expansion will cause, and yet still supports the expansion. DPIE in its assessment report says:
“Anticipated subsidence impacts include fracturing of streambeds and diversion of surface water underground; losses from the reservoirs due to increased permeability in the solid rock mass separating them from longwall voids; and impacts on surface water quality, including an increase mobilisation of metals such as iron. Stream function would be impacted due to cracking of creek beds, loss of pool holding capacity and loss of baseflow reporting to streams from upland swamps and near-surface aquifers.”
The proposal seeks approval to continue longwall mining into two new areas – Area 5 and Area 6 – to mine 77.2 million tonnes (Mt) of Run of Mine (ROM) coal over 28 years, with up to 5.2 Mt ROM coal per year extracted. This would be about 80% metallurgical coal and 20% thermal coal.
HOW TO MAKE A SUBMISSION
You don’t have to be an expert to make a submission and your submission can be as long or short as you like.
Our recommendation is that you write a short, unique submission which explains why you oppose this project. ‘Unique’ submissions tend to carry more weight with the NSW IPC than ‘form’ submissions. To help you, we have created this submission guide. You may choose to include some (or all) of the points below depending on your personal views about this project.
POINTS FOR OBJECTING TO THE DENDROBIUM EXTENSION PROJECT (SSD 8194)
I object to the Dendrobium Extension Project (SSD 8194)
Mining induced subsidence will damage the watercourses and swamps that feed our drinking water reservoirs
South 32 predicts that it’s 305 metre wide long wall panels may result in subsidence of 2m to 2.45m. Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative.
The mining and associated subsidence will also cause cracking of the land on the surface – including rivers, creeks, smaller watercourses and swamps that feed our drinking water reservoirs – and subsequent water loss to the catchment. No level of damage is acceptable to the Special Areas.
The mining will come to within 300m of the Avon and Cordeaux Reservoirs. It will result in water losses from Avon, which is the only source of water supply to over 310,000 residents and businesses in the Illawarra region, as well as Cordeaux Reservoir, which along with Cataract Reservoir is the main water supply for Camden, Campbelltown and Wollondilly council areas and even as far afield as Nepean Reservoir, which is the water supply for the nearby towns of Bargo, Thirlmere, Picton and The Oaks.
All three affected reservoirs, Avon, Cordeaux and Nepean also supply water to Sydney.
As an important component of the Greater Sydney Water Catchment, these reservoirs supply between 20 and 30% of Greater Sydney’s water in normal times, and in times when Warragamba is compromised by water quality (for example the 1998 cryptosporidium and giardia water crisis, or the 2019/20 black summer bushfires which burned the Warragamba catchment) they may supply even more.
In dry years, the watercourses in the mined area that flow into Avon Reservoir are expected to totally dry up.
Millions of litres of water will be lost
The cracking and dewatering of watercourses, swamps and aquifers is expected to add the loss of many more millions of litres of water each day to the 10 million litres daily water loss from Dendrobium’s current and past mining.
Dendrobium’s average daily water loss for the duration of the expansion project will be 22 million litres (ML). Water loss will peak around 2032 to 2036 at 26ML per day. This is equivalent to the daily water usage of 130,000 people!.
The existing water discharge into Allans Creek, Unanderra will double.
This is the same discharge point that was recently identified as exceeding safe levels of heavy metals.
South32 wants to purchase water licenses and pay cash compensation to WaterNSW for the water they take from the catchment. This cannot possibly compensate for irreversible damage to the Special Areas and for the legacy of water loss. The water loss has been modelled for the 171 years from 2048 to 2319.
Government agencies outside Planning are concerned
The NSW Government’s Independent Advisory Panel for Underground Mining has said,
“It is not possible, at this stage, to be comfortable that the worst-case losses from the surface water regime have been identified. Stream depletion can arise from combinations of reductions in overland and groundwater flow to the streams and increases in stream losses to the groundwater.”
Water NSW has also questioned the reliability of the modelling stating that “previous iterations of the model had predicted surface water take at the existing Dendrobium Mine and that these predictions had increased 5-fold in the 5 years since 2014 (now 1372 ML/year)”.
WaterNSW has been clear that mining in the Special Areas causes loss of yield to the reservoirs and the swamps and water courses that charge them.
Damage to WaterNSW infrastructure
The mining expansion risks damage to critical WaterNSW infrastructure, including the dam walls of Avon and Cordeaux Reservoirs, the Lower Cordeaux Dam Project and WaterNSW’s Deep Water Access Project. It is even expected to cause ground movement at the dam walls.
WaterNSW’s Deep Water Access Project aims to provide water security for the Illawarra by constructing a deep water pumping system to access the reservoir’s deeper waters.
Avon Dam is the only source of water supply to over 310,000 residents and businesses in the Illawarra region and yet, WaterNSW says that the Dendrobium Extension Project could affect its ability to construct and operate this important infrastructure project.
The mining is also too close to the dam walls. WaterNSW stated that the 1000m setback from the dam walls is not enough and the setback should be at least 1500m, adding that, “Should any impacts occur to these dams, there is the potential that the risks and consequences could be extreme.”
As water courses fracture due to mining induced subsidence, metals will be dissolved and leach into the water. This will lead to an increase in metals in the water courses and reservoirs. Furthermore, this increase will worsen in the 100 – 200 year period of groundwater recovery.
WaterNSW in particular expressed concern about the levels of metal contamination, stating,
“WaterNSW is concerned that any increase in arsenic (or other heavy metals) may have a negative effect on water quality and aquatic ecology.”
Damage to Upland Swamps
The upland swamps of the Woronora Plateau play an important role in the water catchment by capturing and holding water, filtering it and in times of drought releasing it slowly into the creeks and rivers that feed into the reservoirs.
These swamps are also classified as Endangered Ecological Communities (EEC) and are significant in terms of their biodiversity.
The upland swamps provide a mosaic of permanently wet peaty soil within a dry sandstone landscape. Each swamp is a unique island community containing rare plants and animals. The specialised flora and fauna of the EEC also carry individual protection at species level. Dewatering the swamps will result in local extinctions in breach of multiple layers of State and Federal legislative protection.
There are 46 swamps in the mining area and 25 of these are expected to be cracked by the mining. Water drains away from swamps into the mining void, the swamps dessicate, the flora and fauna die off, and dryland species take over. The swamps lose their capacity to hold water in drier times. They are more prone to erosion and more prone to bushfire. Research shows that swamps that have been undermined are less able to recover after bushfire compared to swamps that were not undermined.
Coastal upland swamps also provide carbon capture and storage ecoservices.  Neither South32 or DPIE have considered or estimated greenhouse gas emissions associated with expected swamp destruction, or loss of carbon uptake that the swamps currently perform.
Dewatering of the forest, bushland and swamps above the mining will make the area more prone to bushfire. The water catchment was one of the few unburnt areas of bushland in the 2020 fires and it needs to be protected from mining induced degradation. It is also close to the highly populated residential areas of Wollongong that are located along the Illawarra Escarpment; making the catchment more fire prone makes the escarpment more fire prone.
A legacy of water loss and contamination for future generations
It will take 100 years for groundwater levels to stabilise in Area 5 and 200 years for Area 6. Thus the drawdown/dewatering impacts of the mining will remain long after we are gone. This is a problem that we will hand down to future generations, descendants that will be more challenged by climate change, subject to more extreme weather events, longer and more severe droughts and more serious bushfire risk.
The NSW Independent Advisory Panel for Underground Mining says that,
“At this stage, because there is a lack of clarity as to if and how Dendrobium Mine can be sealed, it should be assumed that surface losses from the catchment will occur over the long term and potentially in perpetuity.” 
The discharge water from the mining will also need to be managed and treated, perhaps in perpetuity, and this is another burden that we leave for future generations. Previous mining at Dendrobium has already burdened future generations with a legacy of water loss and contamination and this expansion will make it much worse.
Damage to valuable Aboriginal Cultural Heritage
A legacy of mining induced damage to Aboriginal Heritage sites at Dendrobium was recently revealed in the media.
The Aboriginal Cultural Heritage Assessment records and physical survey of only 6.91 % of the affected area, identified 58 Aboriginal heritage sites, including six new sites, in the area likely to be affected by longwall mining in Area 5 and Area 6. These were mostly rock shelters with/without art and deposits, and axe grinding groove sites located in creeks.
Although the DPIE’s Biodiversity Conservation Division proposed changes to South32’s mine design to avoid impacts to six Aboriginal heritage sites, changes were made by South 32 that would protect only one site. In a statement that was justifiably and understandably described as offensive by the Illawarra Local Aboriginal Land Council, the Department said:
“The five remaining sites are all located centrally above longwall panels. Given the limited risks of impacts, the Department does not consider that the scientific or cultural benefit of avoiding the risk of impacts is warranted.”
Monitoring of Indigenous cultural sites is required but there is no requirement to preserve or avoid these sites, and no penalties to South32 when it destroys them. It is reprehensible for mining interests to desecrate Aboriginal Cultural Heritage whilst the area remains out-of-bounds for the Aboriginal community.
Locking in 28 years of Greenhouse Gas Emissions, instead of decarbonising
The IPCC 2018 Special Report warned that to limit global warming to 1.5°C then, globally, by 2030, primary energy from coal needs to have reduced by a minimum of 59 %. In this context, this coal mining extension proposal spanning 28 years (to 2048) should not even be considered.
The proposal is estimated to create up to 23.7 million tonnes of CO2e in the production stage (“Scope 1 and 2 emissions”) and 237 million tonnes in the transport and consumption of the metallurgical coal produced (“Scope 3 emissions”). This brings the total emissions to between 256 million and 260.7 million tonnes of CO2e for the life of the project.
The DPIE will not consider the Scope 3 emissions from the consumption of the coal, arguing that these are the responsibility of the consumer. To put the volume of emissions in context, the federal government estimates Australia’s greenhouse gas emissions for the year to December 2018 as 538.2 million tonnes.
Thus, approval of this mine would lock in emissions over the 28-year life of the project equivalent to 48% of the 2018 annual emissions for all of Australia. Annually it would add an average of 9.3 million tonnes per annum (260.7 million tonnes over 28 years) of CO2e to the atmosphere.
This is comparable to 1.73% of Australia’s current annual emissions.
Australia is a major greenhouse gas polluter: in 2016 Australia had higher emissions than 90 % of all countries; had the seventh highest emissions per capita; and even worse as an exporter of GHG emissions, ranked third after Russia & Saudi Arabia for exports of fossil fuel CO2e potential. Coal makes up more than 80 % of this export.
The emissions from combustion of coal that Australia sells (i.e. scope-3 emissions) are very significant. Australia needs to take responsibility for them as well and rapidly transition to zero carbon steelmaking.
NSW Government locking in 28 years of destructive coal mining is irresponsible economic planning
We need to rapidly reduce greenhouse gas emissions to address global warming. One of the obvious – and appropriately ambitious, given the climate emergency – ways to decarbonise industry is to start with steel.
Port Kembla has been identified as having good prospects for moving from existing fossil fuel-based steel-making to making low-emissions steel. This transition would not only retain jobs in the Illawarra, it would position Australia well in the emerging low-carbon future.
No alternative is provided to this shockingly destructive expansion which will cause permanent damage to our water catchment
There should be no mining in the Special Areas of Greater Sydney Water Catchment; this is the stated position of WaterNSW and the legislated purpose of Special Area protection.
It is outrageous that DPIE not only support this destructive mining expansion, but the Department also required no alternative mine design options to reduce the damage should an expansion proceed. Having failed to explore any alternatives, the DPIE is claiming without evidence that narrower longwalls would still cause significant damage and “would come at an unsustainable economic cost” for the mining company.
The NSW government requires South32 to consider alternatives, including mining in domains for which they have existing approvals and modifying the design to “avoid key sensitive surface features, including swamps and water storage infrastructure”. South32 have failed to address these imperatives and yet the Department has supported the proposal rather than uphold standards of responsible planning.
In conclusion, this expansion project is not in the public interest and it should be rejected.
 Quote: DPIE Asesssment Report (Oct 2020) page xv.
 Figure SPM.3b, p14 IPCC (2018) Summary for Policymakers. In: Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty [Masson-Delmotte, V., P. Zhai, H.-O. Pörtner, D. Roberts, J. Skea, P.R. Shukla, A. Pirani, W. Moufouma-Okia, C. Péan, R. Pidcock, S. Connors, J.B.R. Matthews, Y. Chen, X. Zhou, M.I. Gomis, E. Lonnoy, T. Maycock, M. Tignor, and T. Waterfield (eds.)]. In Press. Accessed 03/09/2019 from: https://www.ipcc.ch/sr15/chapter/spm/
In October 2020, Protect our Water Alliance and Lock the Gate co-hosted a webinar on the future of a steel industry without coal – Green Steel.
Tony Wood from the Grattan Institute says government should commit to funding a green steel project powered and fed by hydrogen. The Prime Minister has just announced that low-carbon steel is one of five priority technologies that will receive targeted government investment.
Could a green steel project be built in the Illawarra? How many jobs would it create? What are the challenges and opportunities? And if the future of steel-making in the Illawarra is coal-free, how do we create new opportunities for people currently employed to mine coal under our drinking water catchment?
MC: Tim Buckley, Institute for Energy Economics and Financial Analysis
Dr John Pye is a senior lecturer at the Australian National University. Recently, he has joined an ANU ‘Grand Challenge’ initiative named Zero-Carbon Energy for the Asia-Pacific, with the proposal to develop pathways for the fully carbon-neutral production of iron and steel.
Tony Wood, Energy Program Director, Grattan Institute. Tony is one of Australia’s best-known commentators on energy policy. He is also co-author of a recent study called ‘Start with steel: A practical plan to support carbon workers and cut emissions’
Wollongong, New South Wales — Residents are this morning blockading at the Russell Vale Colliery, as the beleaguered mine’s expansion proposal heads to the Independent Planning Commission later today. Protect Our Water Alliance is joining local residents and Knitting Nannas to demonstrate in-person opposition to the mine, before the virtual IPC proceedings take place today and tomorrow. The coal mine is seeking a five-year extension of operations, to mine further beneath the Special Areas of the Greater Sydney Water Catchment.
Protect Our Water Alliance (POWA) spokesperson Rada Germanos said “The IPC is online due to COVID restrictions, but we are stepping out and stepping up in our opposition to this terrible project. It is crucial that we as a community do not let this project go ahead.”
If Wollongong Coal’s proposed expansion at the Russell Vale Mine goes ahead, it will be one of the top 100 emitters of Scope 1 greenhouse gas emissions in Australia. Furthermore, the mining expansion will drain both surface and ground water from the Cataract Reservoir catchment, part of the catchment’s Special Areas that forbid public access because of their sensitivity and strategic importance. In recent weeks a spotlight has also been shone on extensive damage to Aboriginal cultural sites in the Escarpment from coal mining.
“Our communities won’t see any benefits of this project, only a wrecked water catchment and warmed climate for generations into the future. There is also mounting evidence that the Aboriginal cultural heritage of the area is being trashed, with heartbreaking images of extensive and irreparable damage to sites such as Whale Cave from previous mining. It’s clear from these mining approval processes that there is a complete disregard for Aboriginal cultural heritage, and there will be more such important sites forever damaged should this mine’s expansion go ahead”
“POWA will continue to oppose the Russell Vale mine expansion, and all mining in our water catchment. Wollongong Coal cannot continue to rip up coal and ship it out overseas to its parent company. We are taking a stand and drawing a line in the sand. Mining is not compatible with preservation, and it is not compatible with a drinking water catchment. We demand an immediate and permanent ban on mining underneath our water catchment.”
POWA is a grassroots community group committed to defending the water security of our region. For more details about this campaign visit – www.protectourwateralliance.org
Our recommendation is that you write a short, unique submission which explains why you oppose this project. ‘Unique’ submissions tend to carry more weight with the NSW IPC than ‘form’ submissions. To help you, we have created this submission guide. You may choose to include some (or all) of the points below depending on your personal views about this project.
Wollongong Coal’s Revised Underground Expansion Project for Russell Vale:
I object to the Wollongong Coal Ltd’s Russell Vale Revised Underground Expansion Project (Major Project 09-0013).
Some of the reasons for my objection are:
DAMAGE TO GREATER SYDNEY WATER CATCHMENT
Risky Mining in our 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 an area underneath the shores of the Cataract Reservoir.
Triple seam mining It is particularly risky mining – despite being bord and pillar method, not longwall – 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.
NEW INFORMATION shows that subsidence may be much greater than originally portrayed The transcript of a meeting between the Resources Regulator and the IPC Panel on 13 October 2020 reveals that the subsidence impacts of the proposed mining may be much more serious than the Dept of Planning has portrayed. It appears that subsidence has continued above longwalls 4 and 5; what was reported several years ago as 1.4 metres of subsidence (still nearly 5 times the predicted subsidence of 30cm) is now 1.78m of subsidence. A subsidence engineer expressed concern that the cumulative effect of the new project beneath two previously mined coal seams could trigger instability of “marginally stable pillars” in the overlying Bulli Seam mine. The expert makes several concerning statements before the meeting was cut short for private “internal” discussions of the IPC commissioners and staff present. These include: – “It’s a substantial effort ….. to control the risk hazard of those marginally stable rock masses, because the – by nature, by definition, they do not need a lot of external force to become non-stable.” – “Importantly, without a reasonable understanding of this key risk factor” [the state and location of the marginally stable pillars in the Bulli seam] “we are in the dark in making decisions in relation to Russell Vale Colliery’s proposed revised underground expansion project. That’s an important message.” (1)
Wollongong Coal admits that instability in the overlaying old Bulli seam workings may cause pillar collapse and subsidence of the surface of almost 1 metre. It is unacceptable for the NSW government to allow such risky mining in the water catchment for 5 million people of Greater Sydney in a time of increasing drought.
More damage and water loss in our catchment Although the bord and pillar mining method could be expected to lead to less damage than longwall mining, the approval of this expansion would also reactivate a lapsed approval for longwall mining, enabling 25m of longwall mining close to the upland swamp, CCUS4, to extract the abandoned longwall machine in longwall 6. This longwall mining should not be allowed to go ahead. Previous mining of Longwall 4 resulted in subsidence of 1.4 metres which was nearly five times the predicted subsidence (2).
Ecosystem degradation The mining expansion will drain both surface and ground water from the Cataract Reservoir catchment. This dewatering, exacerbated by drought and climate change, will impact the biodiversity in the area. As the area dries out, it loses the ability to sustain native plants, animals, birds, reptiles and insects in the area.
Increasing bushfire risk The draining of ground and surface water caused by the mining will make the Cataract Reservoir catchment area, one of the few areas of unburnt bushland in NSW, drier and more flammable. This increases the bushfire risk, not only around Cataract Reservoir, but also along the heavily treed Illawarra Escarpment.
ETERNAL COST OF COAL MINING ON COMMUNITY AND FUTURE GENERATIONS
Ongoing water treatment requirements will cost future generations
The project will further the loss of ground and surface water from Cataract Reservoir and its catchment, adding 131 ML/year of ground water and 10 ML/year of surface water to losses from previous mining damage. This is estimated to bring the total ground and surface water loss from the project to 298 ML/year (3). This is the equivalent annual water usage of over 4,000 people.
Unending mine water discharge at the Illawarra Escarpment After the project is finished the mining void will fill up with water. The water will keep rising until it reaches the adit (mine portal) in the Illawarra Escarpment in about 2057. The water will overflow through the adit and the outflow will slowly increase, reaching 0.3ML (300,000 litres) per day in 2179 (4). WCL’s modelling shows that the volume of water outflow at the adit above Russell Vale will continue to flow, even beyond 2179. In other words, there will be escalating water discharge from the adit for at least 160 years… perhaps, in perpetuity.
The Planning Department’s failure to protect our water The outflow will need to be managed and treated and Wollongong Coal is proposing a commitment to do this for 10 years. The company, as the current mining lease holder, not generations of NSW taxpayers should be responsible for all future discharge. The Planning Department’s recommendation that Wollongong Coal be required to merely “make a plan” for outflow management is ludicrous; it is indicative of the Department’s failure to protect our water through decades of mining the Greater Sydney Water Catchment.
THE MOTIVATION FOR THE DEVELOPMENT
More mining around Cataract Reservoir The Dept Planning confirms that the purpose of this proposal is to pave the way for a much larger expansion of mining around Cataract Reservoir and to its west (5). It is reckless and lacking in forethought for the NSW government to further jeopardise the integrity of the water catchment. Cataract Reservoir area has been extensively mined already and the ground was still moving 25 years after a project in the 1990’s longwall mined around and under the Reservoir (6). The Special Areas of Greater Sydney Water Catchment should be declared off limits to mining. They should be protected, not only on the surface, but to the centre of the earth.
IMPACT ON LOCAL COMMUNITY
Proximity to Residential Areas
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 and “mitigation” measures will not remedy this.
Coal Processing Plant Onsite 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 (7) 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 safe and suitable standards.
Coal Trucks are a traffic hazard and pollution risk The coal would be trucked along Bellambi Lane, past people’s homes onto the Northern Distributor to Port Kembla Coal Terminal. The mine proposes to produce up to 1 million tonnes of coal plus 0.2 million tonnes of fill material per annum. The maximum truck frequency leaving the site will be 17 loaded trucks per hour, that is 34 truck movements per hour, or 1 truck every 1 minute 45 seconds (8). The Northern Distributor is already at capacity in peak hour with regular traffic jams; this large number of coal trucks will delay and endanger drivers on the main arterial road of the Illawarra’s growing northern suburbs. The coal trucks will also cause coal dust/particulate pollution along the trucking route.
Particulate Pollution The colliery is too close to residential areas, with homes bordering the colliery site on 3 sides, just 225 m from coal stockpiles and schools located just several hundred metres away. The colliery is a major source of particulate pollution. It is well documented that coal particulate pollution increases human morbidity and mortality from respiratory and cardiovascular disease. In this day and age, Russell Vale is not an appropriate location for a colliery, and particularly not for a colliery that wants to expand.
Pollution from two new coal stockpiles Coal stockpiles have a large surface area that is prone to dust generation. This development proposes two new stockpiles, bringing the total number to three (9). This will increase the stockpiled coal surface area further and exacerbate the particulate pollution from the colliery.
Pollution from loading coal onto trucks with tractors The proposed new truck loading facility will not be operating for years (if ever!) and until then loading trucks off the stockpiles with tractors on unsealed roads will create more particulate and noise pollution. WCL was supposed to build a truck loading facility as a requirement of their previous approval, but the NSW government failed to enforce this condition, so we are now left with last century methods of truck loading and the local community will pay the price.
THE ECONOMIC CASE FOR THE EXPANSION DOES NOT STACK UP
Short-changing NSW taxpayers The coal would be mined for supply of WCL’s parent company in India, Jindal Steel and Power Ltd (10); this expansion is unrelated to steel making in the Illawarra. By selling to the parent company, WCL is unlikely to get the best price and therefore the people of NSW are likely to be short-changed on even the meagre royalties.
NSW government’s failure to respond to the company’s financial situation Wollongong Coal’s liabilities outweigh its assets by approximately A$1 billion. It cannot be expected to properly resource mining in the sensitive and strategically important water catchment. Furthermore, the company is no longer listed on the Australian Stock Exchange and therefore even the basic accountability requirements for ASX-listed companies do not apply (11). The NSW government has been investigating whether Wollongong Coal is fit and proper to hold a mining license for 4 years but has never concluded the investigation or released the findings. The investigation is still going on, with the government just saying that they can’t establish that the company is unfit and improper (12). This company is not fit and proper. They should not be allowed to mine the water catchment of the largest city on the driest inhabited continent on earth.
CLIMATE CHANGE AND GREENHOUSE GAS (GHG) EMISSIONS
More Greenhouse Gas Emissions when we need to reduce emissions If the Russell Vale coal project goes ahead, an additional 304,600 t CO2-e per annum of Scope 1 and 2 emissions (13) will be added to the NSW GHG inventory at a time when NSW Government policy requires a reduction in GHGs of 35% by 2030 (14). In a recent submission on the Narrabri Gas project, former Chief Scientist of Australia Professor Penny Sackett stated that meeting NSW’s own 2030 GHG target “will require an annual new reduction of about 2.4 MtCO2-e per year, year on year” (15). The Russell Vale project would add about 0.3 MtCO2-e every year for the next five years, thus working in the opposite direction and nulling about 12% of the intended reductions in all other areas of NSW industry and commerce.
Top 100 GHG emitters for very little coal If approved, Russell Vale would be in the top 100 largest emitters of Scope 1 emissions in Australia. Russell Vale is a gassy mine, meaning a lot of methane would be released into the atmosphere during mining. Australia is already – by far – the largest exporter of metallurgical coal. Russell Vale would add only a very small volume of additional coal (about an extra 0.25% per annum) to export volumes but it would add a large volume of GHGs to NSW’s inventory.
A HIGH RISK THAT PROMISED SOCIO-ECONOMIC BENEFITS WON’T BE DELIVERED
Insecure employment and safety risks There’s a high risk that promised socio-economic benefits won’t be delivered or sustained given WCL’s inability to safely and profitably operate mines.
In April 2019, Wollongong Coal shut down operations at its Wongawilli mine throwing 45 people out of work after the NSW Resources Regulator identified “significant safety issues” (16).
In 2017 a ‘catastrophic failure’ of a diesel engine occurred at Wongawilli, which the Regulator said could have caused an explosion in the methane-rich underground workplace (17).
In 2014, 100 miners lost their jobs at Wongawilli after an expensive longwall machine was buried in a roof collapse (18). Workers were asked to take a pay cut to keep the mine going, but the company’s offer of $21.50 an hour combined with a loss of working conditions was voted down by miners. The miners were made redundant (19).
Wollongong Coal does not pay company tax Wollongong Coal has lost money every year since 2013 when the current majority owner took control. As the company has not generated a taxable income, zero company tax has been paid to the Australian Government since 2013. This is very unlikely to change in future.
It would cost the Australian government about $24,000,000 to offset the GHG emissions that Russell Vale will generate Wollongong Coal’s cost benefit analysis (CBA) overstates the benefits and understates the costs. For example, the CBA does not include the cost of offsetting emissions from Russell Vale. In September 2020, the Clean Energy Regulator paid an average of $15.74 per tonne of abatement to buy emissions reduction as part of their 11th Emissions Reduction Fund auction (20). Using this price as a guide, it would cost about $24M to abate the 1,523,000 t CO2-e of Scope 1 and 2 emissions that this project will generate in NSW over 5 years. As Wollongong Coal pay no company tax, they will likely contribute nothing towards the cost of abatement.
The proposed Russell Vale UEP is not in the public interest. We ask that you reject this application from Wollongong Coal and recommend a process to close the mine at Russell Vale permanently.
5 Russell Vale Revised Underground Expansion Project (MP09_0013) | Secretary’s Final Assessment Report, op cit, p. 14
6 Is there a 4th Dimension to Subsidence Monitoring? W Ziegler, Manager Mining Impacts, NSW Dam Safety Committee and H Middleton, Mining Regulation Officer, NSW Dam Safety Committee, Proceedings of the 9th Triennial Conference on Mine Subsidence, 2014, Accessed at https://moam.info/mine-subsidence_5c555997097c47034d8b45b0.html
Wollongong, New South Wales — Over 40 people attended a convoy touring mining-related damage to the water catchment on Sunday February 2nd, organised by community group Protect Our Water Alliance (POWA).
The community convoy started at Wollongong Railway Station, before travelling to Allan’s Creek in Unanderra, where over 5 million litres of water daily are discharged into the creek from the Dendrobium Mine in Mt Kembla. It then travelled to Redbank Creek in Picton, where longwall mining from the Tahmoor Colliery has caused extensive cracking in the rock of the creekbed. The convoy finished at Cataract Dam, where extensive mining operations have occurred beneath the reservoir since the 1970s. Cataract Dam is currently only 26% full.
Greater Sydney is the only region in the world where long wall mining occurs beneath vital water catchment areas. In a time of severe drought, water restrictions and bush fires, reservoirs in the Catchment continue to dwindle – reservoirs in the Illawarra region are currently between 25 and 45% full.
POWA spokesperson Dr Rada Germanos, said “Underground longwall mining is causing subsidence and surface-to-seam fractures in rock. This has drained creeks and swamps, and is destroying carbon-capturing ecosystems, as well as sites sacred to Yuin and Dharawal peoples.”
“A recent report from the Office of the Chief Scientist estimated that just two of the mines operating in the catchment are causing the daily loss of 8 million litres of water. Other studies have estimated that the water loss from catchment mining is as high as 34 million litres per day. This poses clear threat to our region’s water security into the future.”
POWA is calling for a permanent ban on mining underneath the Greater Sydney Water Catchment. Unauthorised entry into the protected Special Areas can incur a $44,000 fine, however coal mines continue to operate beneath these areas.
Two mines, Dendrobium and Russell Vale, are seeking NSW State Government approval for proposed expansions despite mounting community concern about their effects on the water catchment.
On the 25th of May – the same day a climate change rally was held in Wollongong – Wollongong Coal opened the doors of the Thirroul Community Centre to the public. The location choice was a bit strange, given that it was not held in suburbs that would be directly affected. Any Illawarra local worth their salt can tell you that parking in Thirroul on a sunny Saturday is a challenge. Perhaps just an oversight.
Upon arrival, locals were greeted by the cheerful staff of Umwelt. This is the Environmental Consultant Agency to which Wollongong Coal has no doubt paid a pretty penny, to chaperone each visitor through the presentation.
Each visitor was given a glossy booklet, complete with serene pictures of miners walking through the bush.
We were informed that the booklet was “more detailed” than the posters on the walls.
On further inspection, it seemed that several sections were omitted from the booklet – in particular the noise and dust contour maps.
Sure, they had pictures of them on the walls, if you could distinguish the dark blue contour lines from the dark green background. But unless you have a photographic memory, you couldn’t possibly recall the details of the maps.
Not to worry – we took our own pictures, and have provided them for you here.
Also missing from the booklet included the proposed colliery site plan. Not to mention proposed stockpile sizes for Run-of-mine coal , product coal and waste material.
Perhaps not surprisingly, there were zero attempts to estimate the Green House Gases that would be emitted by the expansion project.
Importantly for us, Wollongong Coal completely glossed over the issue of subsidence. Subsidence is the vertical shifting of earth which can cause cracks to appear in the surface, water loss and contamination. Although subsidence is much more prominent with longwall mining, is still occurs with bord-and-pillar mining. A simplistic diagram drawn up by geotechnical consultancy firm Strata Control Technology (SCT) seeks to show that the “typical” subsidence for first workings bord-and-pillar extraction is virtually none.
According to Department of the Environment  :
“Historically, this method of mining [bord-and-pillar first workings] was undertaken where the depths of cover were very shallow, the mine was small, or where the surface subsidence had to be limited” pg. 4
Note the key word; limited.
Bord-and-pillar first workings are not employed to eliminate any risk of subsidence, but rather limit the risk. In areas of the water catchment where an individual can be fined up to $44,000 for simply bushwalking, is it really acceptable that subsidence is merely limited?
Furthermore, the report  continues:
“where the pillars have been designed to be stable, the vertical subsidence is typically less than 20mm. Natural or seasonal variations in the surface levels, due to the wetting and drying of soils, are approximately 20mm; hence, vertical subsidence of less than 20mm can be considered to be no more than the variations that occur from natural processes and should have negligible impact on surface infrastructure” pg. 4
Firstly, the argument that mining companies should be able to deliberately cause up to 20mm of subsidence because similar variations may occur from natural processes – is a bit like an arsonist who feels it is quite within his rights to start a bushfire because they can also be caused by lightning strikes.
One would assume that there is a fundamental difference between changes in the “wetting and drying of soils” (which are presumably located in the top layers of the earth) and subsidence caused by the sinking of underlying strata.
This begs the following question, wouldn’t the 20mm of subsidence caused by underground mining simply be added to the natural variation that would occur in the soil, and not necessarily negate it?
Perhaps these are moot points when we consider that the 20mm subsidence figures are “best-case-scenario” estimations.
According to one researcher ; ‘Pillar design criteria based on field experience have met with mixed success”
Not only do unexpected things go wrong but we also know from scientific literature [3, 4, 5] that significant levels of subsidence occur over time due to the eventual degradation of support pillars. The mining company is only responsible for the health of the area for a relatively short period of time and wouldn’t be held responsible for any damage that occurs in the distant future.