Be there: POWA Creek Convoy, 10am Sunday May 7th

Its been a long time coming, but POWA is organising a follow-up to our Water Catchment Convoy of 2020. This time, we will be keeping it local, and visiting the suburban creeks of the Illawarra that we know and love – and have been impacted by the local coal mines we have been campaigning against for the last 5 years.

Come along, learn about your local waterways, and feel inspired to fight to protect the waterways that provide habitat and make our area a more-lovely place to live.

We will be starting from Lowden Square (eastern side of Wollongong Train Station) at 10am, and heading southwards to:
– Collins Creek, Woonona
– Bellambi Creek, Bellambi
– Allens Creek, Unanderra
– Brandy and Water Creek, Figtree
… and finishing up at Mt Kembla for a lovely picnic, wrapping up around 2pm.

We will have a mini bus, but will also need some people to bring their own cars for the tour.

Keep an eye on the Facebook event for more info closer to the date.

POWA one of 35 groups to endorse “Emergency Climate Action: No more coal and gas; 43% carbon emissions cut by 2030 is not enough” rally in Sydney today

From Green Left Weekly:

Climate activists from 35 grassroots groups came together for a march on August 7 to send a strong message to the Anthony Albanese Labor government that its recently legislated 43% cut to emissions by 2030 target is not enough to avert catastrophic climate change.

Climate scientists say Australia should set a target of 75% emissions cut by 2030.

The marchers demanded:

  • No new fossil fuel projects, including Kurri Kurri, Narrabri, Beetaloo and Burrup Hub;
  • Stop the power companies profiteering: 100% publicly owned renewable energy by 2030;
  • Climate jobs and a just transition now;
  • First Nations justice: Stop Santos’ attack on Gomeroi Native Title;
  • Defend the right to Protest: stop police repression of climate protesters; and
  • Protect ecosystems and stop logging native forests.

The march was endorsed by: Fireproof Australia; Knitting Nannas Sydney; NSW Nature Conservation Council; Protect Our Water Alliance; Amnesty International Australia; Stop Adani Sydney; Water for Rivers; Maritime Union Australia Sydney; Greens; Socialist Alliance; Extinction Rebellion Drummers; No Incinerator for Western Sydney; Wage Peace and Disrupt Wars; Sydney Extinction Rebellion; Stop Coal Seam Gas Sydney; Justice Action; Bob Brown Foundation; Sydney Industrial Workers of the World; Rank and File Action (Sydney University); Uni Students for Climate Justice; Kids Against Gas; Australian Mothers Against Gas; Western Sydney Direct Action; NSW GasBan; North West Protection Advocacy; Latin America Social Forum; No more incinerators Matraville; Workers for Climate Action; National Tertiary Education Union Sydney University branch; National Union Students; Black Flag Sydney; Lithgow Environment Group; Democratic Kurdish Community Centre of NSW; and Save the Bay.

Speakers included: Rilka from Blockade Australia, NSW Greens MLC Abigail Boyd; Veronica Koman, from Amnesty International Australia; Maritime Union Australia Sydney branch secretary Paul Keating; Dr Rada Germanos, from Protect Our Water Alliance (POWA); Dorothee Babeck, from the Bob Brown Foundation; and Paddy Gibson.

Have your say: make a submission opposing The Dendrobium Mine Extension Project (SSI-33143123)

Submissions close 14th June 2022have your say here

Our recommendation is that you write a short, unique submission which explains why you oppose this project.

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.


Mining corporation Illawarra Coal Holdings (South 32) has a revised proposal for the expansion of Dendrobium Mine in Sydney and Wollongong’s water catchment. The Environmental Impact Statement for this project is now on exhibition.The Dendrobium Mine Extension Project (SSI-33143123) proposes 19 years of destructive longwall mining in the water catchment for Wollongong, Macarthur and Sydney.

The proposal seeks approval to continue use of the mine and infrastructure until 2041, and to expand longwall mining into Area 5, extracting up to 5.2 million tonnes of Run of Mine (ROM) coal each year until 2035.

This is despite predictions of the accelerated closure of the uncompetitive coal-fired power industry, [1, 2] and technological changes that mean the steel industry globally is in transition [3], making the future of the market for metallurgical coal increasingly uncertain.

Meanwhile, NSW and federal governments have pledged millions of dollars to Bluescope Steelworks in Port Kembla to support transition to low or zero carbon steel.

Illawarra Coal Holdings Pty Ltd had previously submitted a proposal for an even bigger expansion, and this was rejected by the NSW Government’s Independent Planning Commission. The Independent Planning Commission stated that the threat to the drinking water catchment was the main reason for their rejection of the project.

Since then, the mine expansion has been declared State Significant Infrastructure. This is the first time a coal mine has ever had the special status of State Significant Infrastructure. In effect, it means that the NSW Minister for Planning makes the decision as to whether or not to approve the project.

The rationale for State Significant Infrastructure Status is flawed

According to the NSW Government, the rationale for declaring the expansion of Dendrobium Mine in Sydney and Wollongong’s water catchment as State Significant Infrastructure is that the expansion of Dendrobium Mine is essential for the operation of the Port Kembla steelworks. However, Bluescope Steel had already made provision for purchasing and transporting coal from other mines [4], and has also secured considerable Federal and NSW Government funds to investigate transition to low- or zero-carbon steel production. [5, 6]

Damage to Sydney and Wollongong’s drinking water catchment

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. 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.

Mining induced subsidence will damage the watercourses and swamps that feed our drinking water reservoirs. Despite the reduction in the overall size of the project, longwalls themselves proposed for Area 5 are still 305m wide.

South 32 predicts that 305 metre wide longwall panels may result in subsidence of 2m to 2.45m [7]. Previous mines of similar width have caused 2.5m to 3 m of subsidence, so South 32’s prediction may be conservative [8].

The expansion is not consistent with current land use of the area as a water catchment

The impact of this mine expansion will not be neutral or positive, it will leave the water catchment worse off in terms of both quantity and quality of water. Offsets in the form of the payment of money cannot replace a drinking water catchment. No matter how much water is recycled, or how many desalination plants we build before the next drought, our drinking water catchment is essential infrastructure, and should be prioritised over a privately-owned coal mine. 

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. 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.[9]

This mine expansion impacts on the ability of the water catchment to collect, clean, and store water and negatively impacts on the sustainability and resilience of the supply of drinking water for Sydney and Wollongong, in terms of both water quality and quantity. Water that enters and then flows out of mines picks up contaminants along the way. Current measures for managing this problem have been shown to be insufficient to prevent impacts on waterways [10].

The risk of pollution events in the catchment is real, and is not adequately addressed in the Environmental Impact Statement.

Should this proposal be approved, the mine will still come within 1000m of the Avon Reservoir. 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[11]. In dry years, the watercourses in the mined area that flow into Avon Reservoir are expected to totally dry up.

The southern catchment is vital to the sustainability and resilience of the supply of drinking water to Sydney and Wollongong. It supplies up to 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. 

DPIE’s report on South 32’s previous unsuccessful application to expand Dendrobium Mine noted that it will take 100 years for groundwater levels to stabilise in Area 5. 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 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.South 32 acknowledges that the mine will continue to discharge water long after that mine has closed. Their own estimate is that the mine will discharge 13 to 15 litres PER SECOND, for the foreseeable future, and certainly long after the mine has closed. 

South 32 have said that the size and location of longwalls in Area 5 is necessary for the economic viability of the mine. They provide no evidence or explanation as to why the profits of a private company should be prioritised over the drinking water supply of people living in Sydney and Wollongong. 

Water quality

According to DPIE’s report on South 32’s previous unsuccessful application to expand Dendrobium Mine, 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.

South 32 use a number of sediment ponds and dams as part of their operations. In the recently approved Modification 9, South 32 noted that management plans for sediment dams meet requirements determined by HEC (2022) in accordance with the Landcom(2004) and the Department of Environment and Climate Change (2008) guidelines, and that “[v]isual inspections of the drainage channels and sediment basins would be undertaken on a monthly basis and following rainfall events in excess of 89.7 mm in 5 days.” In March of this year, the Illawarra experienced rain events considerably in excess of 89.7mm, with a number of occasions on which rainfall exceeded 100mm in a single day.

As in the case of bushfire risk, it is essential that mine infrastructure and monitoring is adequate to the real world conditions that we have already experienced, let alone the predicted and modelled increase in heavy rainfall and flooding that could impact sediment ponds and dams as the climate impacts intensify. It is simply not enough to say that the project meets outdated technical requirements, rather than standing up to the conditions that we are all experiencing.  

Damage to Aboriginal Cultural Heritage

There are 31 Aboriginal Heritage sites in and close to Area 5, with 6 of these sites directly over longwalls. Sites named in the Environmental Impact Statement include: 13 axe grinding grooves, 8 shelters with art, 2 shelters with deposits, 1 shelter with art and deposits, 6 shelters with art and potential archaeological deposits and 1 isolated find.

Representatives of the Illawarra Aboriginal Lands Council and other Registered Aboriginal Parties have also reminded South 32 that cultural heritage cannot be confined to specific and isolated ‘sites’.

One comment from a Registered Aboriginal Party included in the report expresses it well: “From a cultural values perspective, a lot of importance has been placed on the item’s locations, but in terms of cultural values everything that is on the land holds relevance to Aboriginal culture. Sites are the story law, and everything that forms part of the land provides context to the story of the culture. It’s about whole of country rather than specific sites. Sadly, the mining company’s response to the impact of this mine expansion on Aboriginal people and Aboriginal culture and heritage is that further reducing the impact on Aboriginal culture and heritage “may be less economically viable”.  

South 32 provide no evidence or explanation as to why the profits of a private company should be prioritised over the cultural heritage of Aboriginal people. 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. [12]

Impact on koalas and their habitat

Koalas have recently been declared Endangered in NSW. The Environmental Impact Statement notes that there are koalas living in the area that will be undermined, but includes no current survey of koala numbers or locations. There is no management plan for koalas who may be living in the ecosystems that would be cleared for infrastructure, other than offsetting that includes a bio-banking scheme that has not yet been negotiated, and payment to a government trust. It is hard to see how these future arrangements will prevent a devastating impact on actual, living koalas who may be present in land to be cleared for infrastructure. 

Water loss and impact on swamps and waterways means that the ecosystems of the catchment are ‘dewatered’. This is a real and devastating threat to plants and wildlife in the catchment, including a koala population that remains inadequately documented and studied. 

It is very difficult for independent scientists to get access to the Special Areas of the catchment to undertake peer-reviewed research of koala populations in the Special Areas. Access to the Special Areas for independent assessment and preservations of koala populations is an integral part of ensuring the survival of koalas as a species. 

Impact on Aquatic ecosystems

The mine expansion will impact on aquatic habitat and lifeforms, due to both water loss and contamination of water from mine outflows, and leaching of minerals into waterways.It is very difficult for independent scientists to get access to the Special Areas of the catchment to undertake peer-reviewed research of aquatic habitat and lifeforms in the Special Areas.  

Impact on 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 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. In its scoping report South 32 claim to “protect significant stream features”. However, the proposed mining will undermine around connected feeder swamps and smaller streams. This is a concerning misunderstanding of how the ‘significant stream features’ function and how subsidence and cracking around them impacts water storage and flow.

There are 22 swamps in the mining area, with 15 swamps directly above proposed longwalls. When rock beneath upland swamps is cracked, 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.[13]

Coastal upland swamps also provide carbon capture and storage ecoservices. [14] 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.

Bushfire risk

Dewatering of the ecosystems of the catchment increases bushfire risk. 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.

The SEARS for this project specifically require that the mining company address climate impacts and hydrological changes in relation to bushfire management in its Environmental Impact Statement. The EIS notes that there are bushfire management plans in place, and discusses historical ignition factors involved in bushfire risk and reduction of fuel load. However it does not address climate or hydrological impacts. 

It is concerning that the plan does not specify what methods might be used for fuel reduction, leaving open the possibility that planned burns may themselves become a bushfire ignition risk or that fuel reduction may include further unmonitored clearing of habitat and ecosystems. 

Reference is made to the mitigation of methane emissions by ‘flaring’ of gas released from the mine. The bushfire plan does not discuss risk of ignition of bushfires from flaring of gas from the mine, or plans to mitigate this risk.

Impact on sustainable jobs

It is claimed that the project will maintain the existing workforce of 650, plus an additional 50 workers, with 100 additional temporary workers during the construction phase. We note that even the non-construction workforce will not have ‘jobs for life’, but jobs until the end of the lease in 2041, or, more likely, until the mine closes because it is uneconomic to operate.

The real employment argument for this mine has always been the purported ’10 000 jobs’ at Bluescope steelworks and other businesses in the supply chain for the mine and the steelworks. What this argument fails to address, however, is that sustainable industries such as renewable hydrogen production, renewable energy, recycling of rare earths from e-waste, conventional recycling, and low or zero carbon steel production will also support thousands of jobs, with considerable research indicating that sustainable industries will actually deliver more jobs directly and indirectly, when compared to the fossil fuel industry. [15, 16]

The question for those weighing up how to best ensure employment opportunities now and in the future is whether to continue to risk an essential resource, water, for the sake of a few more years of an industry that is already struggling to find markets for its products, and is putting workers onto short term contracts in order to reduce future liabilities when the mine closes, or whether to prioritise the transition to industries that will inevitably grow as support for the fossil fuel industry rapidly becomes economically unviable and socially untenable. 

Impact of coal wash, mine outflow and brine dumping on creeks, waterways, harbours and oceans

In April 2022, South 32 reported that it had stopped sales of coal wash material. This fact does not appear to have been reported in the Environmental Impact Statement. This directly contradicts assurances given in the Environmental Impact Statement that current approvals for the West Cliff Coal Emplacement Area will be adequate to the project because “IMC’s supply of coal wash for engineering purposes (e.g. civil construction fill), or for other beneficial uses, reducing the quantity of coal wash required to be emplaced at the West Cliff Coal Wash Emplacement Area”. [17]

It is concerning that Illawarra Metallurigcal Coal reported in April that it would be ceasing sales of coal wash, and yet allowed an Environmental Impact Statement that included sales of coal wash as part of its operations in an Environmental Impact Statement that went on exhibition in May. 

One fifth of the Dendrobium mine output is waste material that is trucked through the Special Area to another lease area and dumped into bushland. One million tonnes of coal wash per year will be piled at the head of George’s river in the West Cliff Coalwash Emplacement. Emplacement mounds will leach contaminated water into the headwaters of the Georges River. 

Expansion of this mine would mean an increase in water discharged from the mine into Allans Creek, Unanderra. This is the same creek that was recently identified as exceeding safe levels of heavy metals.[9]

Risk of damage from Phytophthora cinnamomi

Phytophthora cinnamomi is a mould. It is a soil-borne plant pathogen that can be spread on surfaces such as shoes or vehicles. It is not native to Australia, so our native plants have not evolved resistance. Any activity in the water catchment, including construction and mining, risks spreading this pathogen to as yet unaffected areas unless stringent infection control measures are used. 

Climate impacts

As the Project is proposing to extract from Area 5 which has “a higher gas concentration”, the Extension project would more than triple current direct (Scope 1) greenhouse gas (GHG) emissions. 

In total, the Dendrobium Extension Project would result in ~88 million tonnes CO2-e of GHGs. This is equivalent to the emissions of ~280,000 average Australian households over 18 years. The Extension would add between 12.2  – 15.5 million tonnes of CO2-e of direct Scope 1 and 2 GHGs to the NSW GHG inventory over the life of the Project. 

Based on the average Scope 1 emissions (assuming flaring) of 789,551 tonnes CO2-e per annum, the Dendrobium Extension could become the 4th highest emitting coal mine in NSW.

These emissions will primarily be fugitive methane emissions, which must be urgently reduced. The International Energy Agency – in their Net Zero by 2050 report – has called for the “elimination of all technically avoidable methane emissions by 2030”. 

It is pertinent to note that GHG modelling is only described during the life of the mine – i.e. estimations of ongoing fugitive emissions after 2041 have not been described in the EIS.

In 2020-21, 33 industrial facilities in NSW reported emitting more than 100,000 t CO2-e of GHG emissions (excluding electricity generation). Of these 33 facilities, 24 (~70%) were coal mines.[18].

Despite comprising a significant chunk of NSW’s contribution to greenhouse gas emissions and climate change, there is no effective regulation to drive down direct and indirect (Scope 1 and 2) emissions from coal mining.

The NSW Department of Planning admitted in February 2022 in its assessment of GHG emissions at the Narrabri Underground Stage 3 coal project, that “there is no clear guidance on how to assess potential mitigation or abatement measures (e.g. what measures are considered ‘reasonable and feasible’ or ‘best practice’), both for current and future activities”[19] 


[1] Australia’s solar tsunami to trigger coal collapse

[2] Solar Power Is Winning From the Energy Crisis. Wind Is Losing

[3] Green steel tracker

[4] Dendrobium mine expansion won’t threaten BlueScope’s existence, says Cr Cath Blakey

[5] NSW hydrogen plan puts renewables on ‘level playing field’ with fossil fuels, gas producer says

[6] Wollongong industry, academia team up to tackle decarbonisation 

[7, 8] Subsidence Report for Dendrobium Mine, MSEC, 2019, pp 35 – 37, accessed at:


[10] EPA fines Dendrobium Coal $15K for alleged water pollution$15k-for-alleged-water-pollution


[12] First Nations leaders urge NSW to adopt Juukan Gorge inquiry protections

[13] Final Report of the NSW Bushfire Enquiry, p. 241, accessed at:

[14] Cowley, K.L. & K.A.Fryirs (2020) Forgotten peatlands of eastern Australia: An unaccounted carbon capture and storage system. Science of the Total Environment. 730 (2020) 139067.

[15]Start with steel: A practical plan to support carbon workers and cut emissions

[16] Renewable Energy Employment in Australia

[17] South32 cuts Illawarra energy coal sales as COVID, wet weather hit production

[18] The largest Scope 1 GHG emitting facilities in Australia (excluding the electricity sector) are covered by the Australian Government’s Safeguard Mechanism. Facilities that emit more than 100,000 t CO2-e per annum are required to report to the Clean Energy Regulator. 

[19] NSW DPE, January 2022, Narrabri Underground Mine Stage 3 Extension Project (SSD 10269) | Assessment Report , pg 55  

JOIN US: Don’t sell out to coal, Minister Roberts!

Friday 3rd June


Department of Planning and Environment, 84 Crown Street, Wollongong

Minister for Planning and Homes, Anthony Roberts, now has the final say on the Dendrobium Mine Expansion. On Friday June 3rd at 8:30am we’ll be at his Department’s local office doors.

Never before in NSW has a coal mine been given this extra special red carpet to approval.

The NSW Independent Planning Commission already rejected this mine expansion, because of the permanent damage the mine is already causing in the Sydney-Illawarra Water Catchment. But, the NSW Government tore up that decision, replacing it with a political process where the Minister decides.

Let’s send a loud message to the Department of Planning (DPIE) that this mine is not supported by the community. Nowhere else in the world allows coal mines in a public water catchment.

Submissions to the Minister are open to the public until June 14. POWA will publish a submission guide later this week, stay tuned.

There is a large courtyard out the front of the Department of Planning. It is easily wheelchair and pram accessible.

There is lots of space to spread out.
Please bring your mask and colourful signs/banners.

See you there water protectors!

Find the Facebook event here

Update and explainer: Dendrobium SSI process, what you can do, and upcoming POWA community information night

This is an update to POWA supporters and allies about the latest developments around the Dendrobium extension project and how to intervene in the planning process to protect our water and environment. As part of our response to South32’s new extension plan, POWA will be holding a public forum on January 20. We encourage you to come along and participate. (See details below)

As you may be aware, the NSW Government has recently declared the Dendrobium mine extension as State Significant Infrastructure (SSI), in spite of the Independent Planning Commission’s (IPC) rejection of the mine’s extension as a State Significant Development (SSD) in 2021. In February, the IPC decided to block the mine’s expansion because it would have unacceptable impacts to water security as well as biodiversity, threatened ecological communities and cause irreversible damage to 58 identified Aboriginal cultural artefacts and values. It also found the mine would cause serious degradation to 25 watercourses and swamps in the Metropolitan Special Area and release significant amounts of greenhouse gases.

The IPC’s decision to protect the water catchment and the environment was an important outcome for numerous ecological campaigns and for POWA as the main group opposing the project. 

Overturning the Independent Planning Process

The IPC decision was immediately condemned by coal corporation South32 and criticised by prominent members of the NSW Government, who vowed to overturn it. South32 and the NSW Minerals Council have been lobbying the government for months to overturn the Commission’s decision. In early December, NSW Deputy Premier Paul Toole and Planning Minister Rob Stokes announced they were pushing forward with the Dendrobium expansion. The decision to grant SSI status followed a motion on the issue in State Parliament, moved by One Nation, which was supported by the Liberals, the Nationals, the Shooters, Fishers and Farmers Party, the Christian Democrats, and the Labor Party. 

The Government has designated the mine State Significant Infrastructure due to its alleged role in providing coal for the Port Kembla steelworks. However, the IPC found that most of Bluescope’s coal came from other mines, the majority of Dendrobium coal over the next 20 years would be exported or transported elsewhere, and Bluescope’s preferred coal would not be mined by the expansion until almost 20 years into the project. Recently, BlueScope’s general manager of manufacturing David Bell told a ‘virtual town hall’ that work on the Port Kembla wharves would allow the steelmaker to bring in coal from elsewhere if need be. 

The IPC decision stated that the economic value of the water supply catchment and the costs of scope 3 greenhouse gas emissions was an equally important consideration as the coal & steel industry. The Government did not mention the water supply, environmental, or emissions concerns of the IPC in its statement about the SSI mine expansion plan. 

As POWA continues to highlight, what the Illawarra needs is renewable energy, green steel, and a just transition, not another coal mine. This is where sustainable jobs and incomes will come from.
The new plan would extend the life of the Mine to 2041 and would involve the extraction of millions of tonnes of coal each year. This is the first time that a coal mine has been declared State Significant Infrastructure in NSW and would set an alarming precedent.

Crucially, the SSI declaration removes the IPC and any independent decision-making body from the approval process, making the NSW Minister for Planning and Homes the consent authority for the project. The Planning Department previously recommended that the IPC approve the project and the planning minister has now given himself the power to decide on this project. The removal of independent oversight calls into question the role of IPC and the Department of Planning, Industry & Environment (DPIE) and suggests the ‘capture’ of the State Government and most NSW political parties by coal companies. It is untenable for the DPIE to do the assessment of this project since they previously backed the flawed claims by South32, which were rejected by the IPC.

Extension Impacts

The powerful campaign opposing extended mining at Dendrobium has resulted in a revised plan, which is less destructive than South32’s original proposal. Due to our collective efforts the proposed longwalls have been reduced by half, which would potentially involve less damage to the water catchment, and have a reduced impact on Aboriginal heritage areas, with six sites to be directly undermined, compared with twenty-two previously. Nonetheless, POWA continues to oppose any mining in the water catchment, as well as the other destructive impacts of the extension proposal. These impacts include – 
– Perpetual surface water loss
– Undermining of streams & swamp
– A range of other risks to local ecology and biodiversity
– Undermining of at least six Aboriginal heritage sites
– Greenhouse gas emissions
– Increased danger of bushfires

The SSI assessment process

When an application is made for the Minister’s approval for SSI, the Planning Secretary prepares environmental assessment requirements, or SEARs, for the project. The Department published the SEARs for the proposed extension just two days before Christmas.
The SEARs identify the information that must be provided in the mining corporation’s Environmental Impact Statement (EIS), including the matters that require further assessment and the community engagement that must be carried out during the preparation of the EIS. 
What preparing an Environmental Impact Statement (EIS) typically involves:
In normal process, the preparation of an EIS usually involves the proponent (in this case South32):
• Engaging with community
• Undertaking detailed technical studies to assess the impacts of the project in accordance with any relevant Government legislation, plans, policies & guidelines
• Refining the design of the project to avoid or minimise the impacts of the project.

The preparation of the EIS should involve a process of impact assessment and design refinement, development of mitigation measures & consultation with community, stakeholders and government agencies.
The Dendrobium Mine Extension Project must take into account the issues raised by the IPC in its refusal of the project and should be subject to a whole of government merit assessment in accordance with the requirements of the Environmental Planning and Assessment Act 1979.

Public exhibition & submissions

Once complete, the EIS will be checked by the Department before being placed on public exhibition for a minimum period of 28 days.
During the exhibition period, anyone can make a written submission on the EIS.
POWA has many questions and concerns about the Dendrobium SSI Process.
We remain opposed to the impacts on the water catchment and the environment as listed above.

Regarding this new and unprecedented process for mine approval, we think it is very important that the community has answers to the following questions:

1. Will NSW DPIE publish their final assessment report for the project and allow opportunity/time for the community to get expert critiques of the document prior to the Minister’s decision?  

2. Who will write the DPIE Final Assessment Report?   

3. Will the writer of the new DPIE Final Assessment Report assess South32’s EIS from an ecological sustainable development perspective as required by the NSW EP&A Act?

4. The economic analysis commissioned by the DPIE to assess the Dendrobium Expansion Environment Assessment was rejected by the IPC, particularly around the reliance of Bluescope Steel on the project. So, who will conduct the investigation and assessment of the importance of local coal supply to BlueScope Steel?  And what are the terms of reference for that?  

5. Who will conduct the economic costs/benefits assessment of the revised project? Will DPIE ensure that this work will go through a rigorous tender process where the credibility of any would-be contractor is thoroughly vetted?  Will DPIE ensure that it does not provide a biased brief or Terms of Reference to the contractor?  

6. Will the NSW DPIE uphold the current requirement of the koala SEPP 2020 for habitat value in its assessment of South32’s EIS?

7. Can the community be confident that the criticisms of the previous economic assessments (or economic assessment reviews) made by experts who appeared on behalf of POWA to the IPC, will be thoroughly addressed so that the same errors are not present?   

8. What are the community’s appeal rights related to any decision the Minister makes on the project?

What you can do

1) Contact Anthony Roberts, NSW Planning Minister’s Office
Phone – (02) 8574 5600
Request to leave a message for the Minister. Introduce yourself, tell the office staff what you are calling about and ask the person responding to record your concern.

DPIE Webform –
The webform allows you to leave a message/enquiry. Use key words such as Dendrobium and State Significant Infrastructure in your title.

Here are some things you might wish to say/write:
– Tell the Minister/MP of your disappointment in this decision to change the Dendrobium coal mine expansion to State Significant Infrastructure (SSI)
– Demand a truly unbiased and transparent assessment of the proposal by DPIE, one that focuses on the public interest and the protection of the water catchment.
– Ask any or all of the 8 questions listed above 
– Seek assurance that all the criticisms, issues and concerns raised by experts in the IPC submissions process and by the IPC itself are addressed in DPIE’s assessment of the new proposal. 
– Ask for an independent economic assessment of the need for this project, including an investigation on how Bluescope Steel’s coal needs will be met while it transitions to zero carbon steel
– Demand adequate time for community and experts to prepare submissions on South32’s Environmental Impact Statement.

2) Prepare a submission on South32’s Environmental Impact Statement (EIS)
It will help if you are ready to make a submission as quickly as possible during the EIS public exhibition period, whenever that may be. POWA will send out emails and messages on social media when the EIS becomes available and submissions are open.

3) What’s next for Dendrobium – Community Information Night
POWA is holding an informative online briefing for anyone interested in opposing the new mining extension proposal. The forum will be held on Thursday, January 20, 7pm. Please invite your friends/anyone who may be interested.

Register here:

More information is available on facebook here: –

Make sure NSW Planning Minister Rob Stokes says “NO” to Wollongong Coal’s ‘do-nothing’ climate plan

Telephone the Minister on (02) 8574 6707 or write to him via his contact web form at:

POWA at HONK! festival, Wollongong, January 2020

Wollongong Coal Ltd is preparing a plan for management of greenhouse gas emissions (GHGEs) from Russell Vale Colliery. GHGEs will be produced as a result of diesel fuel use and electricity consumption on site. And as this is a ‘gassy’ mine, a lot of methane and carbon dioxide will be released. And then of course there’s the carbon pollution that occurs when the coal is transported and burnt.

Although it has a relatively small coal output, Russell Vale Mine is among the top 100 Scope 1 greenhouse gas emitters in Australia.

But the draft GHG management plan reveals WCL does not want to commit to any action to reduce any of these emissions.

The carefully worded draft plan says WCL will “consider” efficiency if they purchase new equipment, “review renewable energy opportunities”, “track… electricity bills” and similar actions, the outcomes of which are neither measurable nor enforceable.

There are no plans at all to minimise, avoid or mitigate any of the fugitive emissions from this expansion. Fugitive emissions comprise 99.6% of all Scope 1 emissions for this development. The 1,412,900 tonnes of fugitive GHG emissions are equivalent to the annual GHG footprint of more than 67,000 Australians.

At this time, we need to rapidly reduce GHG emissions. The NSW government must not let expanding coal mines off the hook.

Will you write to the NSW Minister for Planning, Rob Stokes and ask him to ensure that WCL will be required to implement real concrete, transparent and measurable GHG mitigation at Russell Vale mine?

“Any single source of greenhouse gas emissions is a small fraction of the total, yet the cumulative, shared problem of climate change is enormous and quite possibly existential.”(1)

The NSW government doesn’t require coal miners to take responsibility for the Scope 3 emissions released in the burning of the coal they’ve mined (86.3% of GHG emissions from this mine). At the very least, Minister Stokes should require concrete, measurable reductions of Scope 1 and 2 GHG emissions from the Russell Vale Mine expansion. And the Scope 1 and 2 GHG emissions which cannot be reduced should be 100% offset by Wollongong Coal.

Please phone or write to the NSW Minister for Planning now and ask him to reject Wollongong Coal’s ‘do-nothing’ draft GHG plan and instead, to ensure real, measurable and enforceable reductions from the Russell Vale Mine expansion.

Your message can be as long or short as you like and should:

(1) refer to Draft Russell Vale Colliery Air Quality and Greenhouse Gas Management Plan;

(2) demand actions that are concrete, transparent and measurable to reduce the project’s GHG emissions, including fugitive emissions;

(3) demand that emissions be offset if technology is not available for mitigation emissions; and

(4) request a response to your communication.

Telephone the Minister on (02) 8574 6707 or write to him via his contact web form at:

(1) Expert Report on the Greenhouse Gas and Climate Implications of the Narrabri Gas Project (SSD-6456), Professor Penny D Sackett, Honorary Professor, Climate Change Institute, The Australian National University, Advice Provided to IPC NSW re Narrabri Gas Project: 9 August 2020, pg 3

Have your say: make a submission to the IPC opposing the Russell Vale Mine expansion



Make a submission to

– The deadline to register to speak at the public hearing is 5pm AEDT on Monday 12 October 2020. The public hearing will be held on 19 and 20 October 2020.

– The deadline for written submissions is 5pm AEDT on Tuesday 27 October 2020.

Make your submission a ‘unique’ submission

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:


  • 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.


Wollongong Coal barely touches on Aboriginal Cultural Heritage in their planning documents.

The Illawarra Local Aboriginal Land Council (ILALC) opposes the proposal, and write:

To support our position on this matter we would like to draw attention to the findings in the original Environmental report which highlighted that over 200 sites were already recorded in the vicinity of the mining operation. Furthermore, the report identifies that no systemic evaluation of the landscape has occurred to confirm these numbers were complete. In addition to the potential damage to these sites we are concerned no assessment has been conducted in relation to the Aboriginal cultural landscape and the values, stories and belief structures that sit within this very important cultural area.The report acknowledges that the archaeological significance of the identified Aboriginal sites was determined by their research value, representativeness, intactness and rarity and that on the basis of these criteria. While we agree with the high significance finding identified, we contest the reasoning and the process used for this rating. We assert the fact that Aboriginal people and our cultural history should not have its importance ranked by its research value, combined with structures that have been determined by a values position of non-Aboriginal people. Furthermore, we recognise that this landscape and area holds significance that can’t be constrained to scientific value. The destruction of this area will eliminate, without the potential for repair, a significant cultural and environmental landscape which has already seen the destructive hand of western values. We therefore demand that this continued destruction and undervaluing of Aboriginal history stop and that we rightfully be respected as the custodians of this land, as you cannot return what you continue to destroy.


  • 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.


  • 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.


  • 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.


  • 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.


  • 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.


  • 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.


2 Gujarat NRE Coking Coal Ltd NRE No. 1 Colliery Longwall 4 End of Panel Report, p.15, Accessed 26.9.20 at

3 Russell Vale Revised Underground Expansion Project (MP09_0013) | Secretary’s Final Assessment Report, op cit, p. 48

4 Russell Vale Colliery – Underground Expansion Project, Russell Vale East, Revised Mine Plan Groundwater Assessment, GeoTerra, p. 97 accessed 26.9.20 at (p. 390 of whole document)

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


8 Russell Vale Revised Underground Expansion Project (MP09_0013) | Secretary’s Final Assessment Report, p.13, accessed at (“DPIE Final Assessment Report”)

9 Ibid, p. 13

10 Russell Vale Revised Underground Expansion Project (MP09_0013) | Secretary’s Final Assessment Report, op cit, p. 14



13 Russell Vale Revised Underground Expansion Project (MP09_0013) | Secretary’s Final Assessment Report, op cit, p. 66


15 Expert Report on the Greenhouse Gas and Climate Implications of the Narrabri Gas Project (SSD-6456), Professor Penny D Sackett Honorary Professor, Climate Change Institute, The Australian National University Advice Provided: 9 August 2020, p. 24, accessed at





20 11th Emissions Reduction Fund auction results, 18 September 2020
Accessed at: