STRATFORD EXTENSION PROJECT – SSD – 4966 SUBMISSION BY GLOUCESTER SHIRE COUNCIL TO AN EXHIBITION OF THE ENVIRONMENTAL IMPACT STATEMENT AND DEVELOPMENT APPLICATION January 2013 CONTENTS 1. INTRODUCTION .................................................................................................... 1 2. COUNCIL’S POSITION REGARDING THE PROPOSAL ................................................ 3 3. LAND USE AND COMMUNITY ISSUES FOR THE STRATFORD AREA a. Stratford Village ......................................................................................... 5 b. The Gloucester LGA ................................................................................... 12 c. Cross Valley wildlife corridor ...................................................................... 12 d. Impacts on community health .................................................................... 16 4. THE MINE PLAN a. Audit of current DA .................................................................................. 18 b. Embankments and voids ........................................................................... 18 c. Roseville West Pit..................................................................................... 21 5. MINE IMPACT ISSUES a. Noise and blasting .................................................................................... 22 b. Health, Air quality and Dust ...................................................................... 35 c. Water i. Surface water ............................................................................... 41 ii. Groundwater ............................................................................... 47 d. Traffic ...................................................................................................... 57 e. Agriculture ............................................................................................... 66 f. Socio-economic assessment ..................................................................... 71 g. Tourism ................................................................................................... 76 h. Flora/fauna .............................................................................................. 77 i. Non-Aboriginal Heritage ........................................................................... 88 j. Lighting .................................................................................................... 103 6. REHABILITATION....................................................................................................105 7. POST CONSENT ASSESSMENT, MONITORING AND CONSULTATIONS ...................... 108 8. CUMULATIVE IMPACT a. Ground and surface water ......................................................................... 112 b. Integration with AGL CSG project ............................................................... 113 c. Socio economic impacts ............................................................................. 113 d. Incremental expansions of SMC ................................................................. 114 e. Other coal mines and CSG projects ............................................................. 115 f. Long-term management of the site ............................................................ 115 9. PROPOSED CONDITIONS OF CONSENT .................................................................. 116 1) INTRODUCTION Gloucester Shire Council is the local government authority for the area in which the Project is proposed to be located. Council has sought to develop a comprehensive submission to address its concerns, and the concerns of the local community. In preparing this submission Council has drawn on the resources of its staff, members of the local community, and some limited external consultant advice. Council established a Working Group to discuss the Development Application and the comprehensive information contained in the EIS. A list of the people participating in this Working Group is attached as Appendix 1. Council also sought discussions with representatives of several Government Agencies (the EPA, and the NOW) to assist in understanding issues related to noise, dust and water, and both the impacts on the community and proposed mitigation measures included in the proposal. Councillors and staff received a briefing by representatives of Yancoal Australia Ltd on the 14th December 2012. Council has also held discussions regarding proposals it would seek to be included in a Planning Agreement associated with any approval that might result from this application. Gloucester Shire Council’s primary interest in this application relates to how, and if, this proposal should operate within our local environment, without causing unacceptable impacts on the community in terms of environmental, social or economic impact. Whilst the applicant has sought to address these issues in their EIS, their primary focus is on the extraction of the resource in a cost-effective and efficient basis. Council needs to consider their aspirations, and must seek to ensure that any impacts are either effectively managed or are mitigated to acceptable levels for the individuals affected, or the whole community well-being. Council understands the imperatives of the applicant, and the benefits to the State in terms of royalties and resource production, but the major impacts of this project will be experienced in the immediate locality and the Gloucester area at large. Council has particular concerns for the community of Stratford and the surrounding rural landscape. They are being asked to endure ongoing impacts from this large-scale (in local terms) extractive resource activity in very close proximity to a small rural village, and the small- scale landscape of the Gloucester Valley which is historically and economically significant. The Stratford village community were asked to accept a “boutique” coalmine on the subject land in 1995, which would operate for approximately 15 years. That mining has occurred, and has been extended, and is now subject to this further proposal for extension. Despite clear community expressions of concern (through the CCC, Council resolutions, and at public meetings) to oppose 24 hour activity so close to the village, this proposal now seeks to Appendices to Submission by Gloucester Shire Council to an Exhibition of the Environmental Impact Statement and Development Application – Stratford Extension Project – SSD 4966 P a g e | 1 return to 24 hour operation, and to mine up to 1 km from the village boundary. The EIS makes no mention of this fact. There has been ongoing complaint by the community about the impacts of this historical mining, to which they say the ongoing response by the proponent is to “charm and disarm”. That is to say, their complaints are listened to sympathetically, but there is ongoing comment that there is no real result from these complaints. Council's interests in this project are broad at one level and particular in another. Council is the roads authority for all roads providing access to the proposed development, and servicing the local community. There are particular concerns about the safety and suitability of the Bucketts Way to carry the increasing size and numbers of vehicles associated with ongoing and extended extraction of the coal resource proposed by this project. Council recognises the economic contribution that employment of local residents and the engagement of local services brings to the local economy. The social and economic benefits of this proposal however, need to be carefully examined so that the community which is asked to bear the most impacts of the proposal might also benefit more fairly as well. Whilst there are jobs there are other negative impacts on other businesses through such things as loss of apprentices and general labour to the mines. Council has relied on information contained in the EIS to inform its responses to the proposal. Where we can, we have sought to discuss the issues of concern in light of what is presented in the EIS, together with other information available (relevant standards, technical reports, consultants advice, etc) to outline our specific concerns. We have examined what the EIS says about impacts and proposed mitigation, and provided specific comments regarding specific proposals, and where possible or appropriate, have suggested either alternative mitigation or possible conditions of consent. We have not always been able to find answers and where such issues of concern are raised, we trust that the Department will seek to address and resolve these matters in its assessment, and in any determination of the proposal. There are a number of significant issues that impact on our ability to respond effectively to this EIS on the many issues this project creates. These are discussed in section 4. Council and our community also need to assess this DA in the light of other extractive resource proposals and approvals in the area. There will be significant environmental effects that are cumulative across the Shire for water, air quality, noise, transport and scenic amenity, and community well-being. There will also be significant combined effects on the industries of tourism, agriculture, health services and housing. Council expects that the assessment of this application will give consideration to these cumulative impacts as well has the specific coalmining project itself. Appendices to Submission by Gloucester Shire Council to an Exhibition of the Environmental Impact Statement and Development