April 2001

Clarence Colliery Lease Extension

Comments of the Environmental Impact Statement by Blue Mountains Conservation Society

1. Impact on the Natural Environment

The Society has special concerns about the possible impact the mine extensions will have on the Blue Mountains National Park, particularly CCL705 and EL5072, which adjoin the Park. In light of the response to uranium mining in  Kakadu National Park and the threat to its World Heritage  status, a similar situation should be avoided here. World Heritage status is not a permanent gift and can be revoked which would have a detrimental effect on tourism for the whole of the Blue Mountains and nearby areas.

The Society is satisfied that the mining methods of first workings and partial extraction do not incur appreciable subsidence, unlike more drastic extraction methods which we oppose. We note that certain areas (Figure 5.6) of high environmental value or under roads, rail-lines etc have been designated for these low risk extraction methods only but we feel these are inadequate. It is our intention that once mining has been completed in EL5072,(stages 1,2) we shall be pressuring to have this area included within the Blue Mountains National Park. At present this area is an obvious intrusion into the National Park and the borders should be re-drawn to include it. Consequently we are anxious that the pristine quality of this area should be preserved.  The proximity of CCL705 to the National Park and the likewise possible inclusion of parts of it into the National Park also impose the same restrictions. National parks officers have indicated that severe mine subsidence would rule out the inclusion of an area into the park for safety reasons. The areas designated in Fig. 5.6 for low extraction methods in other parts of the proposed extension are quite extensive but we feel a better solution would be to impose these restrictions on the whole of the mining lease. We do not believe this will affect the economic viability of the operations. The EIS admits that full extraction methods can lead up to 1 metre of subsidence which would permanently and irreversibly damage the environment, its tourist potential, pose a threat to World Heritage status and have a detrimental effect on the catchment and thus the water supply to Lithgow.

Recommendation: that all mining in the proposed extension area be restricted to the first workings and partial extraction methods and that no full extraction methods be permitted

The Society has concerns about the quality of water currently being discharged into the Wollangambie River(which flows through the World Heritage area) although we note the adherence of the company to EPA criteria. There seems to be an abnormal growth of slime mould which may be attributed to higher than usual values of soluble manganese and iron in the discharge water. We note (page 4-7) that a new water management system is being considered but we feel that this should be an integral part of the application process. The preferred system being considered by the company to pump all the mine water into the Farmer’s Creek/Cox’s River system has appeal.The company attributes its current water problems to bad mining practices by the former owners which reinforces our suggestion that no full extraction should be permitted. The quality and quantity of water made available to the Lithgow City Council could be affected by severe subsidence in the catchment areas.

Recommendation: a full investigation of the water issues on the mine site should be undertaken by relevant authorities before approval for extensions to the lease is granted.

Although the Society is primarily concerned with the natural environment, transport issues and the pollution problems that are generated are of concern. We applaud the Clarence Colliery for using rail as the preferred method for transport of coal for export. It is our understanding that they would prefer to use this method to transport coal to the local power stations but are hampered by a lack of rail facilities at the Delta Energy operations. We would support strongly any moves initiated by the Lithgow City Council to encourage Delta Energy to receive their supplies by rail and thus minimise truck movements through Lithgow township. Construction of rail facilities at the power stations would be a valuable source of employment.

Recommendation: that all efforts should be made to move coal from the Clarence Colliery site by rail

4. Flora and Fauna Protection

The Society is satisfied with the flora and fauna study undertaken and would agree that low impact mining methods (first extraction, partial extraction) would have no significant impact on species numbers or diversity. To maintain this situation, no full extraction methods must be permitted. Of concern for flora and fauna is the number of recreational vehicles (4WDs and trail-bikes) using tracks and roads within the current Newnes State Forest and we would hope that more of this area will be incorporated into National Parks.

Recommendation: that in accordance with our first recommendation, only partial extraction methods be used to guarantee adequate protection for fauna and flora.