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 Error or omission Request for the PAC’s Major Project response Assessment Tonnage 6 4.7 mtpa over 5 years, yet application is for 3mtpa (p.6) Limit extraction to 1 mtpa “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than requiring Wollongong Coal (WC) to produce reports based on the new extraction rate of 1 mtpa, DPE has allowed this outdated documentation to remain.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 1
process, by enabling the application for further longwalls using the piecemeal approach that has characterised this mine’s operations for many years. “Mine was p. 47 “These here first” residents knowingly moved into an area with a high existing noise exposure.” Is it really p. 30 “This assessment has concluded that: - the UEP coal resource is significant based on – its There should be an “high quality high quality coking coal…” The quality of the coal is yet to be proven. Former CEO Arun independent investigation coking coal”? Kumar Jagatrampka has taken the proponent to court disputing payment due to poor into the quality of the coal quality of the coal. The current Director of Wollongong Coal, not long after joining the in the Wongawilli seam of company commented in the CCC meeting that the coal was of poor quality. Yet this was not the proponent’s coal minuted. lease area. The findings could inform a proper assessment of the value of 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 Implement measures as measures prior to commencing UEP. per PAE Holmes report. p. 53 Instal monitors in residential areas, not just around the mine. Fan vents over p. 53 DoPE states that vent shafts are not included in application because they are on the plateau Fans should be moved to West Corrimal “well removed from the sensitive receivers” the escarpment, away from residential area 2
Trucking p. 57 Increase of 11 laden coal trucks to 17 per hour, or 34 trips per hour including return trip Contribute to cost of from Port Kembla Coal Terminal Bellambi Lane as requested by WCC Abuse of PPR was not People who had made submissions were not notified of the PPR and the opportunity to process publically comment on the revised proposal exhibited PAC’s PAC makes PAC Reports for MOD 1 and MOD 2 of PWP commented on how this mode of planning Only approve 1 million previous comments, but application and approval is not best practice. However, the PAC did not condition any tonnes and reduce the comments does not requirements that would put an end to this practice. This UEP application is being set up to project area to Wonga condition allow and even encourage the same kind of abuse of process. East. them Submissions Ref: p. 15 Submissions were solicited by the proponents from employees or from supporters of Disregard all the Wollongong Hawks. submissions from The submissions from the employees are not in the public interest but are in the personal, employees and vocational and financial interest of the employee. supporters of Wollongong 68 of the template submissions have no name on them and/or no address and/or Hawks as being not identifying details are illegible. However these submissions have been given the same indicative of public weight as the submissions that are many pages and detailed and produced by experts in interest. their field. Project p. 8 Project boundaries in MPA have been altered and are confusing boundaries in p. 46 MPA have Inconsistencies in project boundaries – Fig 4, p. 8 vs Fig 17, p 46 been altered and are confusing Processing p.6 refers to This is the first mention of processing on site of any developemtn document. The colliery is Independent investigation coal on site “Continued approved to extract and export ROM coal and is not approved for processing. It raises the into breach of approval minimal question, if RV Colliery is processing coal on site, how much and what are implications of conditions by processing processing this for the local residents? How is this being conditioned? coal on site (sizing and screening) Inadequate DPE contact Very difficult to obtain information and clarification about the document from the DPE. DPE needs to implement information only works “2- Planner has no bounce on email indicating that she is on leave or what day she works or of some quality assurance 3
provision by 3 days per an alternative contact. This is the only contact on Dept website for this project. measures and – dare we DoPE fortnight”, was say it? – a more customer “on leave for a service oriented culture. month over January” PAC Public n/a GNRE/WC took 6 years to get to this point. Why was the PAC communication of this Meeting meeting rushed through over the Xmas/New Year/ Australia Day period? timing Multiple Gujarat NRE/WC have used numerous consultants for the same discipline. Each new Truly independent consultants consultant condems the previous one. Eg Bellambi Gully flood mitigation, Air quality, Noise. consultants should be appointed by DPE and Each starts again and takes a different tact and/or methodology. The result is cheaper paid for by funds that are outcome for the mine, worse outcome for the residents and environment. provided by Major Project Applicants. No timing on History of non-compliance, even when there was timing. This is unacceptable. Statement of Statement of Commitment needs time Committment frame for each commitment. Compliance with the time frame should be strictly monitored. ROM coal PWP and UEP ROM is defined in WC’s documents, as raw coal (UEP EAR Definitions), is applying for extraction, The PWP is approved and UEP applying for the extraction, transportation and exporting of transportation ROM coal. ROM coal is defined in projects as “Raw coal as mined that has not undergone and export of any screening, crushing or washing”(UEP EA Definitions). Previously there has been no ROM coal 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 of 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 4
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