Adani’s Carmichael mine wants to guzzle 12.5 billion litres of water each year, despite the major impacts this will have on farms and the environment. The public has until Monday 27 October 2021 to make a submission to the federal government urging it to carry out a full assessment of the impacts of this consumption.
Earlier this year, the Australian Conservation Foundation (ACF) challenged Adani’s water plan in the Federal Court and won. In May 2021, the court determined that Adani’s North Galilee Water Scheme (NGWS) must undergo a full independent environment assessment. After the Federal Court ruling, Adani claimed it didn’t need the water from the NGWS to operate the mine. But now, Adani’s water scheme is back on the table. It’s a reminder that Adani doesn’t have all the approvals and all the water it needs to operate.
A surge of submissions calling for a full independent assessment will maximise pressure on the federal government to ensure that all impacts are considered.
The StopAdani campaign has put together a handy guide with all the information required to make a persuasive submission:
Adani is not above the law. The full independent environment assessment, arising from what’s known as the water trigger, is a core feature of our national environment laws. It is designed to protect Australia’s precious aquifers and rivers from the impacts of large developments, such as Adani’s proposed Carmichael mine.
Unless we make our voices heard, the Federal government could try to find a way around it for Adani’s benefit. This is a chance for citizens to make sure the full weight of the law is applied to scrutinise Adani’s plan to exploit Queensland's water.
Key reasons why Adani’s water plan should not be approved include:
- Significant impacts on water resources. Australia’s sensitive, dry inland environments, and the farmers that rely on them, are dependent on water available during periods of high rainfall to replenish reserves. Adani’s application states the NGWS will not have a significant impact on water resources, despite enabling the company to take up to 12.5 billion litres of water per year. However, Adani has been shown to consistently underestimate the environmental impacts of its mining operations and its statements should not be accepted at face-value. The Environment Minister must require Adani to complete a full environmental impact assessment that considers the impact of its water pipeline on Queensland’s river systems and wetlands, including the Scartwater Lagoon.
The Federal Court’s ruling on the water trigger must be adhered to. The Federal Court ruled the Minister made an error of law when not applying the water trigger to the previous assessment of Adani’s North Galilee Water Scheme. The Federal Government and Adani had argued the water trigger assessment was not needed because the NGWS pipeline was not itself a coal-mining development. The Federal Court determined that that reasoning was in error and that the water trigger should apply. The Minister must follow the law as declared by the Federal Court and apply the water trigger to the assessment of the NGWS so the impacts on Queensland’s water are properly assessed.
Full impacts of the NGWS must be considered. Adani’s application notes the potential for the NGWS to be used by other proposed coal mines in the Galilee Basin but does not specify the likely volume of water consumption. The NGWS could enable multiple mines to take many billions of litres of scarce water to wash coal, leaving behind a toxic legacy. Adani must be required to specify the full scale of the NGWS and then to complete an environmental impact assessment that considers all of the adverse impacts of the likely peak water extraction on the Suttor River. Further, the impact of extraction of surface waters the ability aquifers to be replenished should also be assessed. Piecemeal consideration of proposed water losses will understate their full impact.
- Adani has failed to address shortcomings identified by an expert hydrologist. The ACF submission to the previous assessment process in 2019 is published here. ACF’s submission contains an independent expert report by Flinders University Hydrologist Dr Adrian Werner that assesses Adani’s referral documents and concludes that they require modifications to be able to properly assess the impact of the NGWS on the Suttor River. Specifically, Dr Werner’s report finds that Adani’s assessment focuses on the effect of the NGWS on peak flooding and does not properly address impacts on smaller flows. This means Adani’s documentation does not adequately prove that there will not be a significant impact on water resources. Adani’s documents referring the NGWS for assessment fail to address shortcomings identified by Dr Werner.
Impacts on threatened species. Adani’s application notes the NGWS will impact on threatened species including the Ornamental Snake, Squatter Pigeon, Black-Throated Finch, Koala and Waxy Cabbage Palm but states the impacts are ‘unlikely to be significant’. The Minister must require detailed surveys of habitats and populations to be completed and considered in a full environmental impact assessment.
Downstream impacts on the Great Barrier Reef Marine Park and World Heritage Area. Adani’s application states that the proposed action will have no impact on the Great Barrier Reef. However, the Suttor River feeds the Burdekin River. The Burdekin sub-catchment is a Great Barrier Reef catchment. Recent research has identified that the Burdekin River is one of just four rivers that are most likely to affect water quality on the Great Barrier Reef. Given the sensitivity of the Great Barrier Reef to changes in water quality, the proposed action must be assessed via a full environmental impact assessment to identify and minimise downstream impacts.
- Adani’s environmental compliance history. Adani Group companies have a poor environmental track-record. In 2020, Adani was found guilty of providing the Queensland government false and misleading information relating to land clearing associated with the Carmichael coal project and received a criminal conviction. Adani has also breached Federal environmental approval conditions seven times and was fined by the Queensland government for releasing polluted water into sensitive wetlands next to its Abbot Point coal port. The Environment Minister should use her discretion to closely scrutinise this history as relevant to the proponent of the NGWS.
To make submission by Monday 27 September: