| |
The Australian Coal Alliance
(ACA) refers to the report submitted by KORES to the
Department of Planning (DOP) seeking the
concurrence of the Director General in regards to a future
Environmental Assessment submission for an approval to longwall
coalmine in the Yarramalong and Dooralong Valleys. Longwall coal
mining has been determined as a Key Threatening Process in
Schedule 3 of the NSW Threatened Species Conservation Act 1995.
SYNOPSIS
There is no evidence in this report that community concerns have
been addressed in the “preliminary assessment of a proposed new mine
design” and in the supposedly “significant changes to identified
geological and environmental constraints” addressed by KORES. A
statement by a company spokesman that their new mine proposals
“would be one that safeguarded water systems” is without
any credibility and directly contradicts Department of Primary
Industry (DPI) publication PRIMEFACTS MINE SUBSIDENCE February
2006, which clearly illustrates that: Quote . . . “mining
under watercourses on floodplains, or in other relatively flat-lying
area may result in localised diversion of water flows and possible
increases in the incidences of flooding, erosion and other impacts”
and . . . “longwall mining is the major cause of mine subsidence in
NSW” . . Unquote.
The Dooralong and Yarramalong Valleys are relatively
flat-lying floodplain areas.
Proclaimed Public Water
Catchment
The proposed longwall mining project will penetrate and has the
potential to damage a critical Proclaimed Public Water
Catchment.
Longwall coal panels, some 4.25 kilometres long x 150-300 metres
wide, and with a height of 3.5-4.5metres, would be extracted
below the aquifers, creeks, natural drainage lines and valleys
floodplains. These natural water courses contribute to the
recharge of subsurface aquifers which account for 53% of the entire
Central Coasts' water supply catchment, and supply water for some
305,000 rural and urban community residents.
The ACA has been advised by consultant hydrogeologists of a
deficiency in general knowledge in NSW of the hydrological and
hydrogeological characteristics of the Dooralong and Yarramalong
valley aquifers. Recharge of these aquifers is from normal seasonal
precipitation in the Watagan Mountains, flowing to a south easterly
discharge on the coast.
The quantifiable level and time frame of recharge to these valley
aquifers is unknown but considered to be over very extensive time
periods. Current water balances and the maintenance of this need is
currently unidentified.
The coal seam waters are heavily polluted and would fail to satisfy
regulated legislative health standards for human consumption. These
waters present a serious problem in their disposal, treatment and
storage during the progressive removal of coal panels and would be a
serious threat to the sub- surface aquifer supply to the communities
and may result in a constantly changing water balance throughout
both valleys.
Subsidence - Residual and
Active
Residual and Active horizontal and vertical subsidence, arising from
longwall mining, is uncontrollable, irreparable and indeterminable
and has been recorded as a complete disaster in the Northern,
Southern and Western Coalfields of NSW. This process destroys the
ecological integrity and physical attributes of the environment,
creates social distress, is responsible for total loss and pollution
of potable water resources and is a repetitive event in perpetuity,
severely damaging property and buildings. The penetration of heavily
polluted coal seam waters, arising from subsidence and increased
permeability in the fractured zone, can pollute streams and
waterways and may severely impact upon terrestrial and aquatic
wildlife. Note: the repositioning of 3-4 panels away from the Wyong
River would not be free of horizontal subsidence problems.
The green riparian corridors in the Yarramalong and Dooralong
valleys could be subjected to environmental degradation, destroying
the habitats, ecosystems, biodiversity and ecological integrity of
these valleys. Some thirty-three (33) threatened species of
NSW wildlife and nineteen (19) avifauna species of national
environmental significance (protected under the Australian
International Migratory Bird Treaty- CAMBA and JAMBA Agreements -
with China and Japan, under the Commonwealth Environment Protection
and Biodiversity Conservation Act 1999, would be threatened by the
proposed longwall coal mine. The migratory waders feed in the
Tuggerah Lakes Barrier Estuary and are dependent upon the fresh
water discharge from Wyong River and Jilliby Jilliby Creek flowing
into this estuary, which is also subjected to ocean tidal inflows.
The interception of polluted coal seam waters, arising from
subsidence in the valleys, would cause these estuarine areas to
become heavily polluted and destroy aquatic organisms - a major food
resource of the national and international migratory waders. This
whole issue remains clouded in, and predicated upon, significant
subsidence impact modelling to develop enhanced empirical models for
the hydrogeological character of the overburden strata above the
coal seams in both valleys.
The site specific factors - geophysical conditions - of these
valleys are unique environments and cannot be reproduced in
modelling, and any statements attributed to KORES that they can,
should be treated with extreme caution. Any attempt to promote
public confidence, within the communities, that subsidence is
manageable and that the company will deal with this problem when
it occurs, is indicative of the need to strongly object to the
release of such misleading material by this company that “all can be
well in the end” - it cannot. The protection of important natural
and built-in features cannot be guaranteed, or mitigated for, in any
interpretive modelling.
Sub vertical open tensile fractures -
"cracking" - are related to high compressive stresses arising from
subsidence. Very high hydraulic conductivity and subsequent losses
in water flow and/or translocation of flow, is a major feature
arising from a dynamic subsidence wave. A relatively large number of
cracks occur in areas overlying longwall panels. (Final Report of
the Cataract River Taskforce. p.22 & 35. Ed. Everett, M., Ross, T.,
Hunt, G. - March 1998).
Public
Relations
KORES has refused to undertake direct public consultation with the
Central Coast communities affected by this project. Neglect of this urgent
public liability and responsibility, to the valley residents, is in
contradiction of their earlier statements that they would be “open
and transparent in all their public dealings”. It would appear that
this company is unable to produce any satisfactory evidence in
support of their statements regarding their announcements that
they would safeguard the water systems. Hypothetical
assurances “of control measures to deal with this problem”
would appear deceitful as this is an unmanageable problem; as
clearly evident in other longwall mining areas of NSW.
We have been advised by a KORES representative that they will not
attend any ACA meeting which would subject them “to
vigorous questioning.” At a recent KORES presentation (to a small
local representative group) it was clearly apparent that their
described technicalities and procedures, of their activities, is
well beyond the general understanding of their audience and appeared
to be misleading and evasive when explanatory requests were
submitted.
Tuggerah Lakes and
Barrier Estuary
The Commonwealth Environment Protection and Biodiversity
Conservation Act 1999 (EPBC Act 1999) regulates actions that will,
or are likely to threaten wildlife of National Environmental
Significance in the Tuggerah Lakes Barrier Estuary.
Sedimentary deposition is recorded as “principally from the
surrounding rivers and creeks and are deposited in shallow sea grass
habitats close to creeks and stormwater inflow" . . . and . . .
“water circulation and mixing are the physical processes that
play an important role in the ecology of an estuary”
(Tuggerah Lakes Estuary Process Study, Roberts, D., & Butler, K.,
Wyong Shire Council February 2001).
Gas Flows and Methane
Oxidation
The potential flow of gas discharge, arising from subsidence, should
be of major concern. Since the gas reservoir size, depth and extent
are already know, water quality in Wyong Creek/River and Jilliby
Jilliby Creek could be seriously polluted, as would the aquifer/s
within the two valleys.
The soil conditions in the two riparian corridors, and all the land
in the two valleys, could be subjected to the generation of anoxic
conditions from migrating methane oxidation.
How will this very serious problem be dealt with? There is no
mention whatsoever in the KORES Interim Report, yet such an event
would have a catastrophic impact throughout the valley communities.
NOTE:
Ms Janine Douglas, Senior Compliance Officer of the Department of
Environment and Heritage, Canberra. has advised that KORES are
required to submit their mining proposals to the Compliance Section,
and to the Referral Section in accord with Federal Legislative
requirements. |
|
