NCWQ Environmental Report May 2019
By Pat Pepper, NCWQ Environmental Adviser
Update on the impact of Carmichael Coal Mine in the Galilee Basin: In previous reports and submissions to Government, concerns have been raised about the impact of mega mines in the Galilee Basin, in particular the Carmichael mine. Theseincluded
- Contribution to greenhouse gases including that from the coal exported overseas;
- Impact on ground water users in the Galilee Basin;
- Loss of biodiversity and the probability that biodiversity offsets will not adequately redress this loss;
- Impact of dredging at Abbot Point and
- Increased shipping within the Great Barrier Reef Marine Park.
NCWQ submissions on impact of Carmichael Coal Mine; impact of expansion of ports on the GBR environs; dredging and disposal of dredged material at Abbot Point; Galilee Coal Project at Bimblebox Nature Refuge
Details of objections to the granting of the mining lease and the environmental authority, the judicial review of the environmental authority and litigation against the mine involving native title have been detailed in previous reports. Supporting Information from NCWQ Environment Adviser, P.M. Pepper B.Sc. M.Sc. Ph.D for submission to Federal Government and Queensland Government; http://envlaw.com.au/carmichael-coal-mine-case/
As reported previously the initial proposal to extract up to 60 million tonnes per annum of coal for 150 years from an estimated coal resource of 8.3 billion tonnes was reduced to a project lifetime to 60 yearswith estimated total production of2.3 billion tonnesof thermal coal. The originally proposal was for a new 189km rail line to the Port of Abbot Pointfor export principally to India to be burnt for electricity production, and for expanded capacity of the Port of Abbot. Subsequently, proposed port expansion has been reduced in size and the decision made to use the existing rail line for the initial stage of the project.
In addition to climate change, one of the major impacts of the mine is on groundwater. http://envlaw.com.au/carmichael-coal-mine-case/
Groundwatermodels aim to determine the likely effect of mining on groundwater levels and flows of water to and from key areas. If the groundwater levels decline below thresholdscritical to the function of whole ecosystems, such as the Doongmabulla Springs, irreversible harm can occur. Groundwater models can also be used to assess changes in flows of water to and from springs and streams, such as the Carmichael River, which crosses the mine site.
In late 2018 and early 2019 CSIRO and Geoscience Australia(GA) wrote two reports for the Federal Government on specific questions on groundwater monitoring, management and modelling planned by Adani Pty Ltd for its Carmichael mine proposal.
Their review pointed out three major flaws:-
- Over-prediction of flow from the Carmichael River into the aquifers below.
- Hydraulic conductivity values used in the model were significantly different from the values estimated by previous testing of the geological layers at the mine site.
- Bore heights used to calibrate the model were incorrect
If the model is corrected to address these flaws, the review points out that the drawdown at the Doongmabulla Springs will in all likelihood be higher than required under Adani’s federal approval conditions.
In addition which underground aquifers feed Doongmabulla Springs has not been identified.Substantive corrective measures for reversing future spring-flow impacts from mining have not been defined
Unless Adani puts forward its plan for dealing with these very real risks, regulators cannot hope to make an informed decision about the risk the mine poses to the Doongmabulla Springs.https://www.csiro.au/en/News/News-releases/2019/Statement-on-Adani-Carmichael-proposalhttps://theconversation.com/unpacking-the-flaws-in-adanis-water-management-plan-116161
Adani’s groundwater dependent ecosystem management plan(GDEMP) for its proposed Carmichael coal mine was recently approved by Federal Environment Minister after the company made commitments to fully address these issues. However, there is serious concern whether the company can or will address these issues.https://www.abc.net.au/news/2018-12-17/adani-water-management-plan-criticised-by-csiro/10625228https://theconversation.com/unpacking-the-flaws-in-adanis-water-management-plan-116161
A January 2019 analysis by EDO Qldof the latest version of Adani’s Black-throated Finch Species Management Plan showed the company had gone backwards in its commitments to the endangered species, reducing its proposed offset area by more than 2000 hectares compared to previous versions of its plan.https://www.edoqld.org.au/update_adani_mine_project11 March, 2019
The Groundwater Dependent Ecosystem Management Plan and the Black Throated Finch Management Plan still need to be approved by the Queensland Government before significant disturbance can commence at the Carmichael Coal Mine.
Water licences: As reported previouslyCarmichael coal mine has been granted an unlimited 60-year water licence. Water pressure is an issue with flows from artesian bores now roughly half what they were in 1915. Since then, the water level in some bores has fallen by as much as 80 metres, and a third of bores have stopped flowing altogether. This directly affects the human, plant and animal communities that rely on artesian water. https://theconversation.com/why-does-the-carmichael-coal-mine-need-to-use-so-much-water-75923 April 13, 2017. Supporting Information from NCWQ Environment Adviser, P.M. Pepper B.Sc. M.Sc. Ph.D for submission to Federal Government and Queensland Government; http://envlaw.com.au/carmichael-coal-mine-case/
EDO QLD are currently taking the Federal Government to court, acting on behalf of Australian Conservation Foundation, over the Government’s decision to allow Adani’s North Galilee Water Scheme to proceed without an assessment of its impacts on precious water resources. The scheme involves a 61 km pipeline for Adani to extract and pump up to 12.5 billion litres of water a year from the Suttor river.
Adani was granted their associated water licence and surface water licence for the Carmichael Mine on 29 March 2017. https://www.edoqld.org.au/update_adani_mine_project11 March, 2019
History of offences:Previously reported allegations of Adani’s environmental offences in India include causing salinity in water supplies, the illegal destruction of mangroves and sand dunes and the blocking and filling of creeks. http://www.smh.com.au/federal-politics/political-news/emails-reveal-officials-probing-environmental-and-financial-concerns-with-adani-supermine-20171102-gzdc5h.htmlReport_Earthjustice and Environmental Justice Australia. The Adani Groups Global Environmental Record_29 Oct 2015.pdf
The Queensland Government is investigating whether Adani has breached its environmental licence for the second time in two years with the release of coal-laden floodwaters from its coal port at Abbot Point in the state’s north.https://www.abc.net.au/news/2019-02-13/adani-facing-government-probe-abbot-point-wetland-release/10805206
With high definition satellite imagery, drone footage, public bore registers, and on-the-ground observations and photography, EDO Qld and their client, Coast and Country, have delivered evidence to the Queensland Government that Adani has broken the law by clearing land, building roads, and commencing dewatering operations without the correct approvals in place.https://www.edoqld.org.au/evidence_supports_the_case_adani_broken_the_law30 December, 2018; https://www.edoqld.org.au/update_adani_mine_project,https://www.edoqld.org.au/update_adani_mine_project
Jobs:Initially 10,000 direct and indirect jobs peaking from 2024 with $22 billion in taxes and royalties were predicted. In court in 2015, the company economics expert instead said it would create an extra 1,464 jobs in Australia — 1,206 of them in Queensland — and generate $16.8 billion in taxes and royalties.
While the revised mine plan could be less than a quarter of its original scale, Adani has not publicly put forward a new projection for jobs or tax and royalty streams. It is yet to reach a final deal with the State Government on how its royalty payments might be deferred in the mine’s first five years.https://www.abc.net.au/news/2019-04-26/what-we-know-about-adanis-carmichael-coal-mine-project/11049938
It would seem prudent to delay the commencement of the project given the advice from CSIRO and the company’s poor record of environmental management in Indiaand Australia until these issues are addressed.