Willoughby Environmental Protection Association (WEPA) Inc, Castlecrag NSW, made the following submission on the project:

Change to mining policy

Our association strongly supports the proposal to remove clause 12AA of the current NSW Mining SEPP. We congratulate the Minister on this move and urge that this change takes place as soon as possible after the closing date (21 July).

This amendment will go a considerable way to restoring balance and fairness to the SEPP. The SEPP could be further improved by additional amendments:

1) Part 9A of the SEPP needs to be amended so that it also makes open-cut coal mining prohibited development within the exclusion zones currently applied to coal seam gas.

2) Further exclusions for coal and gas should also be listed in Schedule 1 of the SEPP, including the Special Areas of Sydney's drinking water catchment, the Broke-Fordwich wine region, a 10km buffer around equine and viticulture critical industry clusters and productive farmland, productive aquifers and critically endangered woodlands.

3) The list of critical industry clusters needs to be expanded to include additional clusters identified through a systematic process, in addition to horse-breeding and wine-growing in the Hunter.

4) The 2km exclusion around urban areas and residential zones should be extended to also apply to all household dwellings - for both unconventional gas and coal mining.

5) For water resources, the prohibition must include alluvial aquifers and 2km around fourth order streams in an expanded Part 9A.

6) Part 12AB (Non-discretionary standards) constrains consent authorities from adopting more stringent environmental standards than the SEPP allows. This is utterly irresponsible and is leading to poor environmental and social outcomes. The action of this provision must be reversed so that development cannot occur if it breaches the standards, but consent authorities are free to adopt more stringent standards where appropriate.

7) Similarly, the "voluntary" land acquisition and mitigation policy is fundamentally unjust and must be repealed or dramatically altered.

8) The Major Projects Offset policy must be changed to restore the "like-for-like" principle on all offsets and limit the use of mine-site rehabilitation and complementary measures for offsetting.

9) Ensure the public can appeal poor decisions. The Minister and Planning and Assessment Commission must ensure that the next mining projects being considered, Drayton South, Narrabri Gas, and Bylong Projects have full merits appeal rights retained.