Notes for PAC Public Hearing, 3 February 2015 Illawarra Residents - - PowerPoint PPT Presentation

1 Notes for PAC Public Hearing, 3 February 2015 Illawarra Residents for Responsible Mining presentation, Part 1 (Presented by Kaye Osborn) 4.7 mtpa over 5 years, yet application is for 3mtpa. This document contains major errors and omissions. We do not believe that this document provides information of a quantity and accuracy that would enable the PAC to make an informed and responsible decision regarding this proposal. We do not believe that the Department of Planning and Environment really understand the mine and colliery and what is happening there. Given that the proponent proposes to mine under the Sydney Water Catchment Special Area, this lack of understanding is quite alarming. We ask the PAC to reject the application. The following are details of errors and omissions in the Major Project Assessment document produced by the Secretary of the Department of Planning and Environment (DPE) Topic Page No in Major Project Assessment Error or omission Request for the PAC’s response Tonnage 6 4.7 mtpa over 5 years, yet application is for 3mtpa (p.6) “The proposal to increase transport of coal from a current level of 1 mtpa to 3 mtpa….” The 3 million tonnes is a historic figure and has no relevance for this application. Rather than requiring Wollongong Coal (WC) to produce reports based on the new extraction rate

• f 1 mtpa, DPE has allowed this outdated documentation to remain.

The inclusion of the 3 million tonnes figure leaves the way open for continuing abuse of Limit extraction to 1 mtpa

2 process, by enabling the application for further longwalls using the piecemeal approach that has characterised this mine’s operations for many years. “Mine was here first”

• p. 47 “These

residents knowingly moved into an area with a high existing noise exposure.” Is it really “high quality coking coal”?

• p. 30

“This assessment has concluded that: - the UEP coal resource is significant based on – its high quality coking coal…” The quality of the coal is yet to be proven. Former CEO Arun Kumar Jagatrampka has taken the proponent to court disputing payment due to poor quality of the coal. The current Director of Wollongong Coal, not long after joining the company commented in the CCC meeting that the coal was of poor quality. Yet this was not minuted. There should be an independent investigation into the quality of the coal in the Wongawilli seam of the proponent’s coal lease area. The findings could inform a proper assessment of the value

• f the coal in relation to

the risks to the water catchment of mining it. Air quality

• pp. 52-53

We support Council’s call for Wollongong Coal to implement a range of air quality mitigation measures prior to commencing UEP. Implement measures as per PAE Holmes report. p. 53 Instal monitors in residential areas, not just around the mine. Fan vents over West Corrimal

• p. 53

DoPE states that vent shafts are not included in application because they are on the plateau “well removed from the sensitive receivers” Fans should be moved to the escarpment, away from residential area

3 Trucking

• p. 57

Increase of 11 laden coal trucks to 17 per hour, or 34 trips per hour including return trip from Port Kembla Coal Terminal Contribute to cost of Bellambi Lane as requested by WCC Abuse of process PPR was not publically exhibited People who had made submissions were not notified of the PPR and the opportunity to comment on the revised proposal PAC’s previous comments PAC makes comments, but does not condition them PAC Reports for MOD 1 and MOD 2 of PWP commented on how this mode of planning application and approval is not best practice. However, the PAC did not condition any requirements that would put an end to this practice. This UEP application is being set up to allow and even encourage the same kind of abuse of process. Only approve 1 million tonnes and reduce the project area to Wonga East. Submissions Ref: p. 15 Submissions were solicited by the proponents from employees or from supporters of Wollongong Hawks. The submissions from the employees are not in the public interest but are in the personal, vocational and financial interest of the employee. 68 of the template submissions have no name on them and/or no address and/or identifying details are illegible. However these submissions have been given the same weight as the submissions that are many pages and detailed and produced by experts in their field. Disregard all the submissions from employees and supporters of Wollongong Hawks as being not indicative of public interest. Project boundaries in MPA have been altered and are confusing

• p. 8
• p. 46

Project boundaries in MPA have been altered and are confusing Inconsistencies in project boundaries – Fig 4, p. 8 vs Fig 17, p 46 Processing coal on site p.6 refers to “Continued minimal processing (sizing and screening) This is the first mention of processing on site of any developemtn document. The colliery is approved to extract and export ROM coal and is not approved for processing. It raises the question, if RV Colliery is processing coal on site, how much and what are implications of this for the local residents? How is this being conditioned? Independent investigation into breach of approval conditions by processing coal on site Inadequate information DPE contact

• nly works “2-

Very difficult to obtain information and clarification about the document from the DPE. Planner has no bounce on email indicating that she is on leave or what day she works or of DPE needs to implement some quality assurance

4 provision by DoPE 3 days per fortnight”, was “on leave for a month over January” an alternative contact. This is the only contact on Dept website for this project. measures and – dare we say it? – a more customer service oriented culture. PAC Public Meeting timing n/a GNRE/WC took 6 years to get to this point. Why was the PAC communication of this meeting rushed through over the Xmas/New Year/ Australia Day period? Multiple consultants Gujarat NRE/WC have used numerous consultants for the same discipline. Each new consultant condems the previous one. Eg Bellambi Gully flood mitigation, Air quality, Noise. Each starts again and takes a different tact and/or methodology. The result is cheaper

• utcome for the mine, worse outcome for the residents and environment.

Truly independent consultants should be appointed by DPE and paid for by funds that are provided by Major Project Applicants. No timing on Statement of Committment History of non-compliance, even when there was timing. This is unacceptable. Statement of Commitment needs time frame for each

• commitment. Compliance

with the time frame should be strictly monitored. ROM coal PWP and UEP is applying for extraction, transportation and export of ROM coal ROM is defined in WC’s documents, as raw coal (UEP EAR Definitions), The PWP is approved and UEP applying for the extraction, transportation and exporting of ROM coal. ROM coal is defined in projects as “Raw coal as mined that has not undergone any screening, crushing or washing”(UEP EA Definitions). Previously there has been no mention of processing of the coal but clearly this has been taking place (WC has been screening and crushing coal with mobile plant) and graded wast coal is dumped on an adjoining site. Now in the MPA (Table 1), WC is continuing minimal processing and disposing

• f coal rejects adjacent to site. The UEP EA (Table 1.3 Coal Reject Management) clearly

states existing operation waste rock is re-used on-site as landscaping, road surface and as a clean structural filling material, while the proposal waste rock will be used on site. The Draft Project Approval Conditions define the site as land to which the project approval applies, as

5 specified in Appendix , that excludes the emplacement area. Traffic MPA (Table 11, p57) states traffic volumes will only increase 0.3-1% but UEP EA (p203) states Bellambi Lane peak hour morning and afternoon will increase by 7.1% and 6.8%; traffic volumes are based on number of vehicles so a small car and a fully ladened B double count as the same; 1 B double is the equivalent road wear as 22,000 cars; DoPE does not support the view that WC should contribute financially to the wear on Bellambi Lane because the project is of only 5 years (GNRE have been operating since 2004, that is over 10 years and with this project it will be 15 years). Who is to bear the cost, the rate payers?; drivers code of conduct has been instigated for years with very little success, the proponent needs to take responsibility for trucking of coal rather than shifting the blame to the drivers; it has been incorrectly stated in the MPA and the UEP that the majority of the staff enter via Shaft 4, this reduces 100’s of traffic movements a day not being included in the traffic study; Socio- economic There is no mention if all previous outstanding taxes and royalties have been paid by WC; at the last PAC meeting WC said they employ 254 people (now stated as 219); MPA states cost

• f met and thermal coal to be $150 and $90 tonne, current cost is $129 and $63, that is 20%

and 30% lower; also quality of coal from this mine is poor; indirect employment multiplier was developed by NSW Mineral Council and is 1.5 higher than the figure adopted by DRE; DoPE has also scrutinised the information and considered alternate multipliers and has come to the conclusion that the UEP would result in significant socio-economic benefits, although they will not share this information with the public (if it exists at all); given that coal prices are continuing to fall and/or totally unpredictable, if we take the $’s generated by this UEP and reduce it by 20% the royalties to the NSW people will be $27.2m, that is $3.6 per person (or 72 cents per year).