Submission on the BHP Dendrobium expansion

Rivers SOS has been concerned for some time with the impacts of longwall mining in the Special Areas of Sydney’s drinking water catchments. We have had delegations over the years to Planning Ministers Keneally and Kelly and also Shadow Planning Minister Hazzard to discuss these concerns.

We have also been involved in the development of the Aquifer Interference Policy (AIP), making a submission to the draft in May this year.

We view with alarm the SMP for Dendrobium Area 3B. We see this as yet another example of a mining proposal with predicted and expected impacts on river systems which are totally unacceptable to our organisation and, we believe, to the community in general.

Because we value river systems, we especially value their lifeblood, their feeder swamps. This SMP proposes to undermine all of the most significant swamps in the entire Dendrobium area with predicted impacts of bedrock cracking which will be catastrophic.

As with the first swamp undermined at Dendrobium (Swamp 1) the cracked swamps will drain and dry out, rendering them vulnerable to fire, erosion and vegetation changes.  The result will be that they no longer function as a swamp, with no water-holding capacity, and no longer able to provide the base flow to rivers as they did right through dry times many months after rain.

We expect that the Government will view this application in light of recent developments which indicate a greater understanding and acknowledgement of the value of upland swamps and the threats posed to them by longwall mining. We refer to the 2010 Bulli Seam Operations Project PAC Report and the 2012 listing of the Coastal Upland Swamps of the Woronora Plateau as an Endangered Ecological Community, both of which are clear statements of the values of these swamps.

Any approval of this SMP must include conditions which fully protect the upland swamps of the area and the rivers which emanate from them.

We are aware of new information which has come to light in the SMP’s Groundwater Study with regard to the extent of the collapsed zone above the mined area, related to the width of the longwalls.  There are serious implications here for potential breaching of the Bald Hill Claystone and subsequent draining of surface water and shallow aquifers across the entire Area 3B.

Especially now in the light of this information we would urge the inclusion of the Special Areas in the Strategic Regional Land Use mapping process and AIP considerations. Their exclusion from this process to date has been unwise and illogical.

The community will no longer accept mining which results in damage such as has occurred to Waratah Rivulet and which is predicted in this SMP. Government and BHP can do much better than that. Dendrobium’s Area 3B SMP application relates to some of the most environmentally sensitive areas for mining and comes at a time when community sensitivities are heightened regarding mining impacts across the state.

It is Rivers SOS policy that we oppose mining in drinking water catchments, however, given the general approval given in 2001 we know the reality is that mining will be approved in some form.  We urge you to consider very carefully the ramifications of what is before you in this SMP and not to be influenced by BHP’s “need” for a hasty decision to allow them to start mining in Feb. next year.

The time taken to work out a sensible plan that fully protects the environment will be time well spent, whereas no amount of time will fix the problems that will arise if this plan goes ahead as is.

Yours faithfully,

Caroline Graham
Southern Coalfield Regional Representative
Rivers SOS

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