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Response to Submissions

Shenhua Watermark RTS

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Introduction

Following the public exhibition of the Environment Impact Statement (EIS) from the 28th February to 26th April 2013, the Department of Planning & Infrastructure provided to Shenhua Watermark a total of 139 submissions from various stakeholders, including regulatory agencies, special interest groups and individual members of the public, in relation to the Project. This Response to Submissions (RTS) document responds to those submissions received, which included 212 individual issues. Technical specialists involved in the preparation of the EIS have provided expert advice for this RTS.

The project has diligently and methodically responded to all issues raised in every submission, demonstrating Shenhua's commitment to keeping the community fully informed about the project. 

In response to feedback received from the community Shenhua Watermark has made significant changes to the Project to further avoid and minimise impacts to the community and the environment including: 

• A mine plan optimisation review which has proposed a reduction in the equipment fleet which
  has meant a reduction in dust and noise impacts to neighbouring properties; 
• The inclusion of a new biodiversity offset area that will provide additional ecological communities
  for protection in perpetuity;
• Making additional agricultural land available for future production by modifying the project's
  onsite offset areas to remove over 600 ha of Biophysical Strategic Agricultural Land
  from the offset package. 

Shenhua Watermark's RTS reconfirms the Project can unlock economic benefits in the local region and create more than 1,000 jobs while ensuring strict scientific based measures are in place to protect the environment.

Shenhua Watermark believes agriculture and mining can coexist in the region with large tracts of BSAL and other agricultural land preserved, no disturbance from mining of the Black Soil Liverpool Plains and the highly productive Gunnedah Formation alluvial aquifer, and a rehabilitation plan that will reinstate more than 1,000 ha of Class III agricultural land after mining is completed.

Summaries of key aspects from the RTS are detailed below: 

Mine Plan Optimisation

• A mine plan optimisation review has proposed a reduction in the equipment fleet for the Project by
  utilising fewer and larger trucks. This has resulted in reductions in air quality and noise impacts 
  and more than halved the number of occupied properties predicted to be in the zone off
  affectation and zone of management. 
• The fleet review has reduced the number of occupied properties affected by noise defined in the 
  zone of affectation from 6 to 3 and in the defined zone of management from 19 to 8. 
• Shenhua's studies concluded that operations will not exceed relevant average annual assessment
  criteria for dust and particulates. The revised mining fleet will further reduce dust emissions from 
  the project site over the life of the project. 
• The Project's mine plan maintains protection of the black soil plains with a 900 metre barrier
  between mining areas and the highly productive Gunnedah Formation aquifer and a150 metre
  buffer to the alluvial soils and black soil plains.

Groundwater

• Shenhua Watermark's Groundwater Impact Assessment is one of the most extensive ever
  conducted for a coal mining EIS in the Gunnedah Basin of NSW. The volume of data collected
  surpasses any project in the region and the quality of this data exceeds the standards required
  to confidently assess the impact of the Project on the groundwater regime.
• Shenhua Watermark has utilised data comprised of over 24,000 samples with more than two
  years baseline monitoring in each of the Projects 103 water monitoring sites which exceeds the
  requirements of the NSW Government's Aquifer Interference Policy.
• The RTS includes more than 60 pages of detailed response to all issues raised in respect of
  groundwater. It provides further clarity on the original baseline groundwater and surface water
  data that was included in the EIS and used in the modeling and re-confirms the veracity of the
  conclusions that have been made. 
• If requested by a landowner, Shenhua Watermark commits to monitoring any licensed private
  bores that are predicted to have a drawdown of greater than 0.25 metres as a result of the Project
  to validate the predicted impacts of the Groundwater Impact Assessment.
• Should the Project be approved Shenhua Watermark will develop a Water Management Plan in
  accordance with any conditions of consent and in consultation with relevant stakeholders.

Surface Water / Water Supply

• "Sediment-laden" water (i.e. surface runoff water from areas that are disturbed by mining
  operations but not having contacted coal) will be captured in sediment dams and treated to
  improve water quality prior to release from the site in accordance with discharge locations
  and criteria specified by the Environment Protection Authority in the required environment
  protection license, or returned to the mine water system if the water quality is not suitable for
  release.
• "Mine water" (i.e. water that has generally come in contact with coal) will not be discharged from
  the Project and will be used to meet site water demands, such as coal processing and dust
  suppression. The mine water management system has been designed to ensure sufficient storage
  capacity exists to contain all mine-affected runoff.
• There will be no adverse salinity impacts from the Project. The total average salt load released
  offsite in surface runoff and long term seepage will not be significantly increased by the Project.
• The Project will need water to meet operational demands such as coal processing and dust
  suppression during normal and dry periods. Where water cannot be sourced from the mine itself it
  will need to be sourced from offsite in a similar manner to other water users in the area.
• The maximum predicted offsite water supply for the Project could be obtained from an existing
  irrigation bore on land owned by Shenhua Watermark or other existing or proposed bores subject
  to the obtaining of all water licensing requirements .
• The Mooki River is unlikely to be a primary source of water for the Project due to the Mooki River
  generally being dry at the times where offsite water would be required. River flow only occurs after
  significant rainfall which would in turn result increased water availability onsite.

Air Quality

• A mine plan optimisation review has proposed a reduction in the equipment fleet for the Project
  by utilising fewer and larger trucks. This has resulted in reductions in air quality impacts. 
• The conclusions contained in the EIS were conservative and concluded that operations will
  not exceed relevant average annual assessment criteria for dust and particulates.The revised
  mining fleet will further reduce dust emissions from the project site over the life of the project. 
• Shenhua Watermark has completed a comprehensive air quality model using baseline air quality
  data collected prior to 2010. The air quality monitoring program will continue throughout the
  Project and all baseline data will be publicly available for the community and government
  departments.
• Shenhua Watermark will install a real-time air quality monitoring network, with a meteorological
  forecasting system, for the day to day management of air quality throughout the life of the Project.
• As part of the Project, Shenhua Watermark has committed to achieving an 85% dust control on
  haul loads, through speed control signage, and the use of water carts and/or dust suppressants.
• Shenhua Watermark will conduct relevant monitoring throughout the life of the Project to ensure
  the haul roads are being effectively managed to reduce dust emissions.
• Shenhua Watermark will install a water spray / dust suppressant system at the Project's rail load
  out facility for use as deemed necessary to assist in minimising dust impacts.

Noise

• A mine plan optimisation review has proposed a reduction in the equipment fleet for the Project by
  utilising fewer and larger trucks. This has resulted in reductions in noise impacts and more than
  halved the number of occupied properties predicted to be affected by noise. 
• Under the mine plan optimisation review houses on three properties will be in the zone of
  affectation and  houses on eight properties will be in the zone of management. Shenhua is
  committed to working with these property owners to identify ways to reduce these impacts
  over the life project and has commenced discussions with them. 
• Predicted noise levels are based on worst case operating and weather conditions, therefore noise
  levels would be lower than the predicted levels for much of the time. 

Koala

• Shenhua Watermark will ensure the protection of the local koala population through the Project's 
  Koala Plan of Management.
• The Koala Plan of Management has been revised and there is now a significant increase in the 
  area of habitat to be protected via offsets. In total 8,159 ha of preferred Koala habitat has been 
  protected - through retention, revegetation and rehabilitation within the Onsite Offset Areas and
  the new office biodiversity offset sites near Tambar Springs.This will provide major, long-term
  support for the conservation of the Koala in the region. 
• The removal of 847 ha of habitat will result in approximately 262 koalas to be translocated over
  the life of the Project which equates to 0.07% of the total Gunnedah population per year.
• The translocation is not expected to have a significant impact on the regional population of koalas
  as the Gunnedah population is considered to be robust and widely distributed.

Biodiversity Offsets

• Shenhua Watermark has significantly enhanced its Biodiversity Offset Strategy since the exhibition
  of the EIS. Through the inclusion of two properties near Tambar Springs more highly  valued like
  for like land containing threatened species habitat will be protected in perpetuity. 
• The new offsets package satisfies the NSW and Commonwealth Government's Biodiversity
  bio-banking calculators. 
• The revised Biodiversity Offset Strategy will now protect, revegetate and rehabilitate over 10,000
  ha of woodland and open forest and includes significant areas of known and potential habitat for
  species predicted to be impacted by the Project. 
• In response to community concern regarding Biophysical Strategic Agricultural Land (BSAL) within
  the Project's offset areas, Shenhua Watermark has excluded all of the 696 ha of BSAL in the Onsite
  Offset Area and 514 ha of existing agricultural land on the Additional Offsite Biodiversity Offset
  Area from the Biodiversity Offset Strategy for the Project to allow for its continued agricultural use.

Agriculture

• In response to community concern about biophysical strategic agricultural land within the Project's
  offset areas, they have been modified and all BSAL has now been removed and will be undisturbed. 
• Shenhua Watermark has excluded all of the BSAL in the Onsite Offset Area (696 ha) and 514 ha of
  existing agricultural land in the Tambar Springs Offset Area will be maintained to allow for
  continued agricultural use through the life of the Project. 
• The Project's impact on highly productive agricultural land is negligible, with only 96 ha of
  biophysical strategic agricultural land to be disturbed. This represents 0.048% and 0.05% of
  mapped BSAL in the Gunnedah and Liverpool Plains LGAs respectively.
• The Project's mine plan maintains protection of the black soil plains with a 900 metre barrier
  between mining areas and the highly productive Gunnedah Formation aquifer and a 150 metre
  buffer to the alluvial soils and black soil plains.

Social Impacts

• The Project will result in an incremental increase in population to the local area as shown in the
  Social Impact Assessment.
• The Project will require approximately 200 full-time equivalent employees from year 1 with a
  peak of 600 full-time employees expected at approximately year 21 of operations.
• Shenhua Watermark is committed to local employment and training measures to address
  workforce supply and skills issues.
• Shenhua Watermark is committed to provide a wide range of employment opportunities for
  residents across the North-West region including apprentices, traineeships and graduate placement
  programs.
• Shenhua Watermark is committed to establishing positive outcomes for the local community and
  surrounds in which it proposes to operate by means of monetary contributions, environmental and
  social management, mitigation and avoidance measures and ongoing consultation. 
• While the Project will result in some road closures, Shenhua Watermark is confident these will not
  cause significant impacts to the local community given current usage, alternative routes and the
  lack of residencies along the proposed closures.

Economics

• If approved, it is estimated the Project will create $960 million in direct and indirect output or
  business turnover in the local region each year and 1,208 direct and indirect jobs. This includes
  434 jobs in the mine and over 774 flow on jobs created to support the mine and to supply good
  and services to the workers and their families.
• While there are substantial local and regional economic benefits from the Project over the
  next 30 years, Shenhua Watermark is expected to pay more than $1.3 billion in company taxes
  and over $1.5bn in State Government royalties over the life of the Project.

 Floodplain

• EL 7223 was renewed by the NSW Government with a range of conditions including a
  prohibition of mining on the floodplain. The Project has confirmed with regulators the
  definition of a floodplain and no open cut mining will occur in areas that meet the definition of
  a floodplain. 
• The NSW Government provided Shenhua Watermark with a clear definition of the term
  floodplain, being "…an area of low-lying, nearly flat plain adjacent to a river, formed mainly
  of river sentiments and subjected to regular flooding."
• Land to the north of Dip Road where mining is proposed , which some have claimed is
  on the floodplain, is clearly not located adjacent to a river, is not subject to regular flooding,
  and has been drastically modified by contour banks and dams and is not indicative of a
  natural or residual floodplain. Therefore the land to the north of Dip Road is not considered 
  to be a floodplain. 
 

Q. Who is Shenhua Watermark?
A. Shenhua Watermark is the operator of the Project and is a subsidiary of the The Shenhua Group
Corporation Limited (Shenhua Group) which is one of the world's leading integrated coal based
energy companies and the largest coal supplier in the world. The business has a key focus on
the production and marketing of coal, power generation, railway transportation, port operations,
shipping, coal-to-liquids and coal-to-chemicals.

Q. When was the Watermark Licence granted to Shenhua ?
A. In October 2008, Shenhua Watermark Coal Pty Ltd (Shenhua Watermark), a subsidiary of the
Shenhua Group, was granted Exploration Licence (EL) 7223 by the New South Wales (NSW)
Minister for Mineral Resources. Since this time, Shenhua Watermark has operated in accordance
with the terms of EL 7223, including the payment of $300 M to the NSW Department of Primary
Industries (now Department of Trade and Investment, Regional Infrastructure and Services).

Q. What approval is the Shenhua Watermark Project seeking ?
A. The Shenhua Watermark Project is seeking State Significant Development Consent under
Division 4.1 of Part 4 of the Environmental Planning and Assessment Act 1979 for the
development and operation of a 10 Million tonnes per annum open cut coal mine for
a period of 30 years.

Q. Where is the Shenhua Watermark Project located ?
A. The Shenhua Watermark Project is located approximately 25 kilometres (km) south south-east of
the township of Gunnedah and 3km to the west of the village of Breeza within the
Gunnedah Local Government Area (LGA). The Project is approximately 282 km by rail from the
Port of Newcastle.

Q. What will the Shenhua Watermark Project comprise when completed ?
A. The Project will comprise:

• A standard mining equipment fleet of excavators and shovels, supported by haul trucks,
dozers, graders, drill rigs and water carts;

• Progressive rehabilitation of all disturbed areas and the co-disposal of tailings and coarse
reject within the Overburden Emplacement Areas;

• The construction and operation of a Mine Access Road;

• The construction and operation of administration, workshop and related facilities;

• The construction and operation of a Coal Handling and Preparation Plant with a throughput
of 10 Million tonnes per annum of Run of Mine coal;

• The construction and operation of a rail spur, rail loop, Kamilaroi Highway rail overpass,
associated train load out facility and connection to the Werris Creek to Moree Railway Line;

• Transportation of product coal by rail via the Werris Creek to Moree Railway Line and the Main
Northern Railway Line to the Port of Newcastle for export;

• The construction and operation of surface and groundwater management and reticulation
infrastructure including pipelines, pumping stations/bore field and associated infrastructure
for access to water from the groundwater aquifers in the vicinity of the Project, the Mooki
River and private dams to the north-east of the Project Boundary;

• The closure of Court Lane, Rowarth Road, Whitby Road, part of The Dip Road (from the
intersection of Clift Road to Nea Siding Road) and other unnamed paper roads within the
Project Boundary;

• The installation of communications and electricity infrastructure; and

• A workforce of approximately 600 full-time equivalent employees during construction and up
to approximately 600 full-time equivalent employees and associated contractors during
operation of the Project at full production.

Q. When did the Shenhua Watermark Project receive the Director General Requirements ?
A. The Director General Requirements (DGRs) for the Environmental Impact Statement were
issued on 19th April 2012 by the NSW Department of Planning and Infrastructure.
The DGRs were prepared in consultation with the relevant Government agencies with
input from the NSW Farmers Association.

Q. What are DGRs ?
A. The DGRs provide an extensive list of requirements which the EIS must address.

Q. Is Shenhua Watermark required to address the Aquifer Interferance Policy (AI Policy)
and Strategic Regional Land Use Plan (New England North West) (SRLUP) ?

A. Yes, the DGR's required that Shenhua Watermark address the criteria of the SRLUP and
AI policy and these have been included in the EIS.

Q. Will Shenhua Watermark mine the black soil plains or disturb the Gunnedah formation
aquifer regime ?

A. Shenhua Watermark will not mine the black soil Liverpool Plains. The Project will protect the
groundwater regime of the black soil Liverpool Plains with a minimum 900 m horizontal barrier
of natural material between active Mining Areas and the highly productive Gunnedah Formation
aquifer. There will also be a minimum 150 m buffer to alluvial black soils and black soil plains.

Q. Where will Shenhua Watermark mine ?
A. Disturbance will only occur in the ridge country on land owned by Shenhua Watermark.
There will be no disturbance to Mt Watermark or the Breeza State Forest.

Q. How will the visual impact of the mine be minimised?
A. There will be a number of activities taking place on site during construction and operations.
To minimise any visual impact to the community Shenhua Watermark will develop and
rehabilitate the Overburden Emplacement Areas as early as practicable that will form visual
screens. In addition tree screening will be undertaken along the Kamilaroi Highway.

Q. Will Shenhua Watermark extract Coal Seam Gas from the Project?
A. No. Shenhua Watermark will not extract coal seam gas as part of the Project. Shenhua is not
a coal seam gas company.

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