Watch the awkwardly empty room beat their chests in this story from WIN News
Three actions in the space of a week have targeted Wollongong Coal’s Russell Vale Mine.
Firstly, a Picnicket by group Stop Russell Vale Mine – read the Mercury article here
Secondly, a 40-car strong car convoy by Illawarra Climate Justice Alliance – read the Mercury article here
Thirdly, a Pram Picket by Extinction Rebellion Northern Illawarra – read the Mercury article here
The deadline for Federal Environment Minister Sussan Ley to make a decision under EPBC legislation on the Russell Vale Mine UEP has been further delayed, with 31st August 2021 named as the new deadline.
An upland swamp was heard squealing with joy at the announcement.
The recent “Sharma Case”, Sharma v Minister for the Environment, where the Court rules the Minister owes a duty of care to protect young people from the human health impacts of climate change, has impacts on the approvals necessary to recommence work at the Russell Vale Colliery.
The Environmental Defenders Office (EDO) has written to the Federal Environment Minister, Sussan Ley, insisting she needs more information about the climate effects of the proposed Russell Vale expansion to make a decision following the Sharma Case. Minister Ley now has an extension until the 8th of July to decide whether to give the Russell Vale Mine approval under the Federal Environment Protection, Biodiversity and Conservation (EPBC) Act.
Telephone the Minister on (02) 8574 6707 or write to him via his contact web form at: https://www.nsw.gov.au/nsw-government/ministers/minister-for-planning-and-public-spaces
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: https://www.nsw.gov.au/nsw-government/ministers/minister-for-planning-and-public-spaces
(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
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.“
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
The Independent Planning Commission proceedings can be publicly viewed via www.ipcn.nsw.gov.au/livestream
0411 378 923
POWA INDEPENDENT PLANNING COMMISSION SUBMISSION GUIDE
RUSSELL VALE REVISED UEP 09-0013
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:
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)
- NEW INFORMATION shows that subsidence may be much greater than originally portrayed
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.
2 Gujarat NRE Coking Coal Ltd NRE No. 1 Colliery Longwall 4 End of Panel Report, p.15, Accessed 26.9.20 at http://wollongongcoal.com.au/monitoring-r/
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 https://majorprojects.accelo.com/public/7f32dda24beaa9a6c18ea7d52be9c53d/RtPAC%20Second%20Review%20FINAL.pdf (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 https://moam.info/mine-subsidence_5c555997097c47034d8b45b0.html
8 Russell Vale Revised Underground Expansion Project (MP09_0013) | Secretary’s Final Assessment Report, p.13, accessed at https://www.ipcn.nsw.gov.au/projects/2020/08/russell-vale-underground-expansion-project (“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 https://www.ipcn.nsw.gov.au/resources/pac/media/files/pac/projects/2020/03/narrabri-gas-project/correspondence/edo/sackett-narrabri-gas-project-ipc-advice-revised_final.pdf
20 11th Emissions Reduction Fund auction results, 18 September 2020
Accessed at: http://www.cleanenergyregulator.gov.au/ERF/Pages/News%20and%20updates/News-Item.aspx?ListId=19b4efbb-6f5d-4637-94c4-121c1f96fcfe&ItemId=837