Response to Submissions

Shenhua Watermark RTS

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Q. Were environmental and social considerations incorporated into the mine plan? 
A. Detailed studies were undertaken in order to identify the most appropriate mine plan for the Project. This review process included the assessment of seven alternatives and incorporation of a suite of concessions to avoid and/or minimise the Project's environmental and socio-economic impacts.

The Project as proposed will result in the efficient recovery of a valuable coal resource nominated within Shenhua Watermark's Feasibility Study which are part of NSW's identified coal reserves. The recovery of this coal resource has been designed to occur with identified, manageable and acceptable environmental and social impacts resulting in material social and economic benefit to NSW.
Q. Will the Project design involve open cut mining on the floodplain, contrary to the conditions of EL 7223?
A. Shenhua Watermark was granted a renewal for EL 7223 by the NSW Minister for Resources and Energy on 19 January 2012. Activities to be undertaken within the EL are subject to a range of conditions as specified in the renewal documentation, including: 
"48. Any development approval sought by the licence holder within the initial term of the licence or during any extensions or renewals of the licence shall not include any of the following activities in the area covered by the licence:
• Long wall mining underneath the "deep alluvial irrigation aquifers";
• Long wall mining underneath the "floodplain";
• Open cut mining anywhere on the "floodplain".

The EL conditions do not define "floodplain".

On 9 October 2013, the Minister for Resources and Energy advised that the definition of the term "floodplain" is as follows:
"A floodplain is an area of low-lying, nearly flat plain adjacent to a river, formed mainly of river sediments and subject to regular flooding."

The flood modelling for the EIS indicated a small area in the Eastern Mining Area (adjacent to The Dip Road) may experience flood inundation during a 1 in 100 year flood event. Whilst this area (referred to as The Dip Road land below) is low-lying (less than 2% average gradient), the slope in the area has been drastically modified by contour banks and dams and is not indicative of a natural or residual floodplain. As such it was not classified as a floodplain in the Surface Water Impact Assessment as suggested by CCAG.

The Dip Road land is clearly not located adjacent to a river. The Mooki River is approximately 4 km to the east of The Dip Road land. In addition, the flood modelling in the EIS clearly demonstrates that the land is not "often" flooded by the Mooki River "at high water or when the channel reaches capacity". The Soils Survey and Land Capability Impact Assessment for the Project demonstrate that The Dip Road land is not predominately comprised of river sediments.

For the reasons as specified above, The Dip Road land is not considered to be a "floodplain" for the purposes of enforcing the conditions of EL 7223. As such, the Project design complies with the conditions of EL 7223.
Watermark Project
Response to Submissions
Operating Team
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