The Concerned Waterways Alliance has lodged a submission with the Water Minister opposing EnergyAustralia Yallourn’s proposed bulk entitlement for water to rehabilitate the Yallourn coal mine.
https://engage.vic.gov.au/potential-water-access-for-yallourn-mine-rehabilitation
CWA supports the safe, stable and accountable rehabilitation of the mine. However, this should not come at the expense of the already flow-stressed Latrobe River, Lower Latrobe Wetlands and Gippsland Lakes.
The CWA makes the point that application presents the proposed entitlement of up to 27 GL a year as a reduction from Yallourn’s existing 36.5 GL annual entitlement however on the face of it this comparison is misleading because the existing entitlement is substantially greater than Yallourn’s actual net water use.
EnergyAustralia’s own environmental reporting shows that Yallourn has historically taken an average of about 26.6 GL a year from the Latrobe system while returning approximately 13 GL of treated water. Its net historical use has therefore been about 13.6 GL a year.
Under the proposed rehabilitation entitlement, up to 27 GL could be taken annually without the equivalent return flows associated with power generation. The result would be an approximate doubling of Yallourn’s net depletion of the Latrobe system.
This would occur in a river system already identified by the Victorian Government as having an environmental water deficit of 129 GL a year. The Central and Gippsland Region Sustainable Water Strategy commits the government to recovering water for the Durt-Yowan/Latrobe River and Gippsland Lakes. Removing the practical benefit of Yallourn’s historic return flows would work directly against that objective.
The submission also rejects the argument that water placed in the proposed pit lake is not “consumed”. Water stored in a mine void is no longer available to provide the baseflows, freshes, high flows and floodplain inundation needed by the river, wetlands, estuary and Gippsland Lakes.
CWA is calling for any rehabilitation water entitlement to:
- be assessed against Yallourn’s historic net use rather than its nominal paper entitlement;
- be reduced by at least 13 GL a year unless equivalent and enforceable environmental water recovery is secured;
- apply a “rivers last” hierarchy, requiring recycled, manufactured and other lower-impact sources to be pursued first;
- account for all water entering the mine from spillways, floods and connected overland flows;
- impose a cumulative volume cap, with the entitlement reducing as the approved pit-lake level is reached;
- prohibit mine water from being sold or supplied for unrelated commercial purposes;
- apply full opportunity-cost pricing, with revenue directed to river restoration and Traditional Owner water outcomes; and
- require transparent public monitoring and reporting.
Safe rehabilitation of the Yallourn mine is necessary. But it should not transfer the environmental cost to a river system already suffering from severe flow stress.
The full CWA submission is available for download below.