NWPA present their objection to the Narrabri Stage 3 Coal Mine Expansion to the IPC

Thank you for the opportunity to come before the IPC, to contribute to the case against approving the Narrabri Stage 3 expansion.

I’m Johanna Evans and I represent North West Protection Advocacy, a grassroots environmental advocacy group which is committed to preserving the cultural and ecological values of the Pilliga Forest. I pay my respects to the Elders of Gomeroi/Gamillaraay Country, past present & emerging.

It’s inconceivable to us that this project has made it this far based on its greenhouse gas emissions alone.

Madam Chair and Commissioners, Stage 3 has been described to you as a “brownfields” project, but with the expansion footprint being mostly in native forest, it’s a misleading description to justify the fragmentation and cutting to shreds of the largest inland temperate forest in Australia. The image shows the Stage 3 project area, looking to the north over the top of Bulga Hill. It’s hardly brownfield. The entire Pilliga is sacred to the Gomeroi.

This part of the Pilliga is significant all levels. Locally, Pilliga is home to hundreds of species, including Black Cockatoo, Koala, Pilliga Mouse, Spotted Quoll, hundreds more, it is a living biodiversity bank.

A wombat burrow photographed at Bulga Hill. Proponent fails to mention wombat in their documents that I can see, correct me if I’m wrong. The Eastern Cave Bat, listed as threatened on the BC Act breeds at Bulga Hill. The noise from the nearby proposed ventilation shaft could impact this bat. The subsidence could impact the wombat. Inferior brown coal or biodiversity?

Regionally, Pilliga is the recharge zone of the Great Artesian Basin. It is a state significant resource and should be formally recognised and protected from projects exactly like this one.

At a national level, the Pilliga’s importance is in mitigating climate change impacts by staying intact! To avoid catastrophic climate impacts we must leave forests like the Pilliga undisturbed. Through its association with the GAB, its essential to economy and agriculture for a large area.

This presentation raises issues around cumulative impacts and the importance of wholistic, comprehensive monitoring of groundwater impacts (including the IESC request tracers be used to track contamination). We need to consider all activity across the GAB. Cumulative impact is when the combo of projects in a region will have a greater impact than when singular. In this We have this situation with Stage 3. It’s a tipping point for the Pilliga.

“Narrabri Stage 3 Groundwater assessment states “Groundwater modelling undertaken as part of this study provided a preliminary assessment of the impacts of the proposed Project but did not assess the cumulative impacts of development of the adjacent Narrabri Gas Project. This is an oversight and needs correction.

Two heavy industries, the gas and coal, come together atop the crucial recharge zone of the Great Artesian Basin. Neither one accounts for the other in any meaningful way in the proponent’s documentation. Quite simply, the true cumulative impact is being ignored. We cannot have both these projects, we should not even have one.

DPIE Water did note in their Supplementary Advice: “There are apparent inconsistencies between groundwater models for different developments in the area …”

To the west, right next to the proposed Stage, the Santos CSG Project is about to begin, approved in August 2020 by the IPC. While on the surface they may be a few km apart the underground connectivity of aquifers has long been suspected and discussed by experts. Connectivity could have impacts such as underground spread of contamination from injected brine, aquifer drawdown, cracked aquifers, salinity, chemicals of potential concern and other pollution from the Whitehaven inaccurately characterised and analysed drilling waste processes.

Why Commissioners has this tool not been developed further? It’s called Assessing the cumulative impact of mining scenarios on bioregional assets in the Namoi Catchment.

Cumulatively, we must also consider projects to come, the Inland Rail further to the west, more habitat fragmentation, and Gorman North, a new fossil fuels exploration area south of Narrabri and to the north of Stage 3. The Gorman North precinct would bring coal and potentially oil shale exploration almost to the doorstep of the town of Narrabri and is immediately adjacent to the Namoi River.

IPC Commissioners, who will take responsibility should our fears be realised and we see the collapse of this incredible biome which is home to so much biodiversity and which so many rely on for livelihood via the water. Will you take responsibility? Will you make sure the proponent is required to monitor thoroughly as the experts recommend if you approve this?


At both the Santos and now Narrabri Underground Stage 3 assessments, experts like the Water Expert Panel and Independent Environmental and Scientific Committee have recommended monitoring that the proponent arrogantly belittles and then flatly denies.  In many instances Whitehaven can be seen in their responses to the IESC to just ignore what is recommended.

The IESC concluded that any cumulative impacts would be adequately avoided if the conditions were applied. This confidence is not warranted. There are too many red flags. Too much data missing across the GAB.

The IPC signed off on the Gas, stating multiple conditions assuring risks could be adequately managed. Santos applied to the NSW EPA to cease to monitor 37 bores in the project area. No data no problem?  One of these bores is called Tullamullen, it is located on the eastern edge of the Santos gasfield. Not far from Bulga Hill. It’s in the Stage 3 area.

We applied by GIPA for information about the drastic groundwater monitoring changes we were witnessing on the Santos Water Portal. What we learned from the disclosed documents has relevance to the Stage 3 application.

Tullamullen was showing big impacts. It was taken out of action by Santos and the EPA admits it was “found to be susceptible to underground mining”. The bore dropped 6 points in pH in just 3 months between November 2015 & February 2016. The EC was fluctuating wildly, analytes of concern were noted.

The bore was measuring the Digby formation at 218m, the Digby is part of the Gunnedah Oxley Basin and the next formation up from the target coal seam, it is slightly deeper though than the seam being mined for coal.

When the IESC comments on Stage 3 and makes specific monitoring recommendations (termed “comments”) we stand behind the recommendations/comments of the experts, not the proponent Whitehaven Coal and not the DPIE Assessment report. Why employ experts to provide scientific advice and then ignore it?

The public don’t have access to crucial data:

The GISERA Faulting Study – years overdue. It’s meant to assess the possibility of faults as potential connectivity pathways in the GAB Floor in the area of Bohena Creek.

If there are already existing faults in the basin floor coupled with the induced faulting as stated by Hydro Stimulations in the Groundwater Report Parts A & B for Stage 3, then there is a bigger than “minimal” chance of the GAB leaking into the coal seams and eventually into the Gunnedah/Oxley Basin due to the difference in the geographical height and water pressure in the larger Great Artesian Basin. See the comment on the Gateway Report.

The NSW Coal Basin Water Monitoring is still not operational. Years overdue. Millions of tax payer dollars spent. The bores on Plumb Rd in the gasfield have never worked properly and are now not even showing standing water level.

How can cumulative impact on groundwater be assessed when monitoring is so weak?

Let’s go now to some specific IESC ‘comments’ which are very good advice.

Comment 1 states: I paraphrase a bit

“Overall, the IESC considers that there is still a material risk of impacts on water resources given the current intensive use of groundwater in the region, the predicted extent of subsidence and groundwater drawdown by the project, and the proposed development’s proximity to significant water resources such as the Namoi River ……. Many of these potential impacts were discussed in the IESC’s previous advice in2019 and are still not adequately addressed.”

Whitehaven’s response is to effectively give the expert committee the flick, citing its own ‘high degree of confidence” in its water resources and associated data.

When weighing up the carefully considered, sage advice of the IESC with Whitehaven’s self-praise I take this opportunity to remind you that Narrabri coal mine is at the highest risk level under the EPA’s risk-based licensing system.

Comment 2 states

“The potential for long-term drawdown of the watertable in this water-stressed Groundwater Management Area is of concern and warrants further investigation, modelling and monitoring”

Whitehaven – yeah nah.  Let’s stick to our Waste Management Plan. “No further ground truthing was necessary”, says the same company that near Turrawan at Maules Creek failed to monitor the condition of impacted Back Creek vegetation, then, at its prosecution by NRAR for water theft, claimed lack of evidence of harm!

Comment 3a:

“IESC notes a number of issues with the proponent’s assessment of groundwater impacts. … However, IESC does not consider that all relevant parameters (e.g. hydraulic conductivity) and boundary combinations have been considered in the proponent’s assessment of potential impacts…

Whitehaven, advised by AGE, responds that “a model with this level of detail in the vertical direction would likely not be capable of accurately predicting long term regional drawdown patterns (i.e. drawdown in the horizontal direction).”

Despite this admission of limitations of the model to accurately predict drawdown – which they currently admit to be 2m and possibly up to 10m – the proponent continues to ignore the IESC, providing long-winded excuses why IPC should ignore IESC’s advice.

Comment 3D

Maybe the most breathtaking example of Whitehaven’s arrogance is its response to Comment 3c. IESC called for a bi-annual update as works progress. Calling for twice yearly recalibration of the Stage 3 groundwater model in the face of uncertainties and noted the need for increased groundwater monitoring.

The proponent’s response is one of disdain. Assisted by AGE Consultants, well-known advisers to the water thieving CSG industry, the stingingly sarcastic response is:

“It is assumed that ‘bi-annually’ in this case means every two years (biennial) rather than every six months. Six-monthly updates would require a near-continuous rolling program of data collection, processing, model re-calibration and predictions.”

IESC recommends rolling twice yearly calibrations precisely because of the rapid depressurisation predicted. To suggest every two years is an adequate Adaptive management measure is nonsense.

The NSW EPA knows all of this, and yet to our knowledge these matters have not been brought to the attention of the IPC in its agency advice. I stand to be corrected if I am wrong.

IESC’s Comments 3e and 4 allude to the noticeable lack of water quality monitoring, which we see already happening to the west in the gasfields, namely reduced frequency or no monitoring at all. The comments continue and the responses continue to underwhelm. I run out of time here but will include more in our subs.

The IESC is independent. It has no vested interest to unnecessarily obstruct industry and commerce. On the other hand, the proponent has a vested interest to avoid the consequences of catastrophic water loss and contamination, deferring reporting and monitoring until it is too late.

If Whitehaven get what they want, management plans will be massaged behind closed doors, DPIE will fail to enforce the guidelines of CCC’s so that community members can’t get honest and timely answers. Farmers will lose and the forest will lose. We need to avoid the devolution of all obligations into management plans.

Right now there is an opportunity to draw a line in the sand. We call on you to reject this new approval and if not then you must implement the IESC’s advice, in full, in the conditions.

DPIE’s recommended conditions will undermine Adaptive Management, not enable it, allowing problems to worsen without scrutiny for lengthy periods while damage is happening.

The cumulative impacts of Stage 3 will be fatal to groundwater in the Pilliga, the farms, the precious water and life contained will be lost. Who will be held responsible? I do hope that what you hear and learn today will have bearing on your final decision.

Thankyou for your time today.

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