This is the submission from Rivers SOS to the NSW Government’s consultation process about the effects of industry and mining on the aquifers that supply NSW with water.
The river systems and water resources of NSW are our concern. Without water, prime agricultural land is useless. In the most arid continent, water supplies must be carefully
conserved. We fear that money power and short term vision prevents the conservation of water.
Since our inception we have called for a 1 km safety zone to protect 3rd order rivers and above from mine damage.
This distance is based on research into irreparable damage to river systems caused by longwall mining, as witnessed in the Southern Coalfield (e.g. Lower Cataract and Georges
Rivers), in the Hunter (Diega Creek, Bowmans Creek, Glennies Creek, South Wambo Creek), in the Western Coalfield (Goulburn River) and in the Woronora Special Area of Sydney’s drinking water catchment (Waratah Rivulet).
The 1 km safety zone would also protect major tributaries near confluences. We have witnessed serious damage to numerous tributaries, e.g. in the Upper Nepean River, where
some are polluted and/or have virtually ceased to flow due to typical subsidence-induced cracking. At sites in places like Kurri Kurri we have witnessed devastation by acid mine drainage in Hunter River catchment creeks.
With the more recent expansion of CSG extraction we are further alarmed at the millions of litres of water extracted from aquifers as part of the process. Underground aquifers of
course feed our river systems and the gross depletion envisaged will have drastic impacts on our water supplies.
In the worst cases, the approval given for CSG bores in Sydney’s drinking water catchment’s Special Areas is, in our view, totally irresponsible, as is the ongoing depletion of the already depleted Great Artesian Basin.
Leakage of saline and naturally BTEX contaminated dewatering waste is contaminating groundwater and river systems, as is the breaching of aquifers, even before inevitable
recourse to fraccing chemicals to extend the lifetime of a gasfield as gas yields decline.
In view of the increasing threat to NSW’s water resources, we were encouraged by the present government’s pre-election promises to protect valuable water assets from mining and CSG extraction. However the draft Aquifer Interference Policy fails to honour this promise.
The threat to water resources is not resolved in this draft, in spite of the fact that more research and hurdles such as “minimum harm requirements” make approvals more complex. More hoops to jump through, at the end of which the policy – to our great disappointment – allows business as usual to prevail.
It does not in the end offer protection to our priceless rivers and water sources, and their
dependent ecosystems. It will allow drastic interference with groundwater systems.
We urge you to revise this draft in order to protect 3rd order and above rivers, to keep mining and CSG extraction outside drinking water catchment areas, and to keep mining and CSG extraction at a safe distance from major lakes and storage dams.
Following are some comments on certain items in the draft:
S2.5: We strongly oppose the suggestion that State Significant mining and CSG developments will be exempt from the need to hold an AIA (aquifer interference approval). These are generally the largest and most damaging developments. It is correct to leave such decisions to the Planning Assessment Commission but hardly reassuring when from past experience we have found that PAC panels of experts have been weighted with people who regularly work as consultants to the mining industry, despite the availability of well-qualified people without conflicts of interest.
We trust that this situation will be rectified. But we remain opposed to exemptions of any kind. There certainly must be no exemptions and no approvals for interference under
Biophysical Strategic Agricultural Land in particular.
S1.2, S3.2: Fraccing chemicals must be banned altogether. Bland assurances by exploration companies that no fraccing will be used are meaningless. Once the lease is sold to a production company, infrastructure is in place and the yield eventually begins to decline the company will have increased leverage on the Government for planning concessions. Surely there is sufficient evidence about the contamination of rivers and drinking water in the USA to prevent their use in NSW.
S2.4: The policy on post-closure of mines takes into account that there will be a continued take of water after closure until an aquifer system reaches equlibrium. It is acknowledged that this may take “months to centuries” after cessation, and therefore the proponent must retain a water licence for the whole period or surrender the licence to the Minister. This policy is impractical if the process takes many decades and therefore we would recommend that a substantial bond is asked for upon closure. We are extremely concerned over the issue of acid mine drainage from abandoned mines. Companies must pay substantial bonds in advance, as remediation is very expensive if indeed possible.
S3.0: We approve of the advertising of all AI applications and hope that this will be extensive. We also approve of the proposition that advice from the NSW Office of Water will be publicly available.
S3.1, S3.3.4: We are not convinced that any forms of remediation are successful. Given our current state of knowledge, it is ludicrous to utilise the “remediation” mantra uncritically. Underground aquifers breached by CSG bores cannot be re-sealed. Connectivity of aquifers breached by CSG bores cannot be reversed. Contamination of groundwater by naturally occurring coalseam contaminants or fraccing fluids cannot be reversed. Grouting of cracks in damaged river beds is at best a short term band-aid solution. Attempts to rehabilitate open cut mines with new vegetation fail to regenerate either agricultural land or biodiverse environments due to disturbance of the top soil. The NSW Office of Water slogan of “account for, avoid, prevent and remediate” is a recipe for
and acknowledgement of failure, to which we should add “abandon”, as eg for the Canyon Colliery in the Grose Valley.
S3.3.1: Exemptions of one sort or another will be countenanced for all water zones. Even in the Highly Productive Groundwater Zone within the Water Protection Zone, not to mention the Limited Intrusion Zone, CSG extraction may be approved. The use of language is Orwellian at this point: where is the “protection?”
S3.3.2: Concerning the list of the Minimal Harm Criteria, we note that most of these destructive impacts are already known to be caused by CSG and mining processes, so the process of re-inventing the wheel should be sidestepped. Impacts may vary somewhat from one site to another but they are predictable in essence if not always in scale. But even so, the predictions of impacts need careful site-specific research and we note that there is no army of qualified personnel equipped to undertake adequate research in this or other related fields.
S3.3.3: We very much endorse the commitment not to approve CSG bores if they will “modify the existing hydraulic connection between aquifers” and “cause more than minimal harm to the aquifer.” We think this would apply to the majority of CSG bores, and therefore we need to know who will be carrying out the research enabling such decisions. We do not have confidence in research carried out by consultants employed by CSG or mining companies.
In the above comments on your draft we are engaging in a less than satisfactory exercise,
because, as stated at the outset, we find the failure to offer proper protection to vital water resources a travesty, and a policy disaster for which future generations will pay dearly.
