Submission on the NSW Coal & Gas Strategy by National Trust

Conclusion

 
It appears to the Trust and to the community at large that, in recent years, gas and coal exploration licences and approvals for mining and gas production have been issued with few restrictions or restraints and this has led to a major community backlash across NSW. Dealing with many of these development proposals as State Significant Developments has largely “locked-out” community input via local government authorities, yet the adverse impacts of these developments are primarily felt at the local level.

There is a perception also that mining companies (and their investors) are in a rush to exploit as much coal reserves as possible before climate change issues force coal mining to be abandoned and that this headlong rush is both risky and ill-considered. Mining companies must be held accountable into the long-term for any on-going adverse effects of their activities.

The NSW Coal and Gas Strategy has the potential to properly identify these concerns and to recommend appropriate guidelines and restrictions to ensure that these industries are not given an environmental carte blanche but are forced to address the long-term and indirect costs of their production, which to date have been typically borne by individuals and local communities.

Development approvals for coal and gas extraction should only be determined following full regard to all foreseeable environmental, heritage, community, social and competing-use impacts. Competing use impacts are particularly relevant, as coal and gas extraction and processing industries have significant potential to sterilise land for alternative uses for many years, if not indefinitely.

The Trust makes the following recommendations in regard to the formulation of an ecologically sustainable NSW Coal and Gas Strategy:

1.    Any coal mining in sensitive areas must, at the very least, utilise lower impact methods for coal extraction, rather than Longwall methods, and extensive areas of subsidence protection zones should be established.

2.    Longwall coal mining must not be permitted beneath Landscape Conservation Areas, protected water catchment areas, rivers, streams, creeks or wetlands.

3.    Neither longwall coal mining nor coal seam gas production should be permitted where there is any risk of damage or pollution of subterranean aquifers.

4.    Reported damage to heritage values during ongoing mining operations must result in reviews of those operations to determine the impacts and put in place less-damaging alternatives.

5.    Open-cut mining must not be allowed to threaten the destruction of whole towns, with their built fabric and social values, prime agricultural land or recognised heritage landscapes.

6.    Gas production facilities must not be sited within, nor impact upon, prime agricultural land, recognised heritage landscapes or within protected water catchment areas.

7.    The Community and their local government representatives must be kept fully informed and briefed on all gas and coal exploration activities and the scope of existing mining leases throughout the State.

8.    Before agreeing to any further exploration or mining leases or renewal of such leases, full environmental impact assessments and social impact assessments need to be undertaken and placed on exhibition for community comment.

The Trust recognises that economic factors tend to dominate any considerations relating to mining activities. The Trust would make the point that, if the only way that mining (or any activity) can be profitable is by utilising environmentally or socially unacceptable practices, then these industries are simply unprofitable.

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