EnergyAustralia is attempting to present its proposed new water entitlement for Yallourn mine rehabilitation as a reduction in demand on the stressed Latrobe River and Gippsland Lakes system.
https://engage.vic.gov.au/potential-water-access-for-yallourn-mine-rehabilitation
It is not.
The company is seeking access to up to 27 GL of water each year for mine rehabilitation, compared with an existing power-generation entitlement of 36.5 GL a year. On paper, that looks like a reduction of 9.5 GL.
But the existing 36.5 GL is a 'paper' entitlement and not a measure of Yallourn’s historical use nor its actual impact on the river.
EnergyAustralia’s own environmental reporting shows that Yallourn has historically taken an average of about 26.6 GL a year from the Latrobe system and returned approximately 13 GL a year of treated water. That means its net historical use has been about 13.6 GL a year.
Under the proposed rehabilitation entitlement, EnergyAustralia could continue taking up to 27 GL a year while the substantial return flows associated with power generation cease.
The result will be relatively straightforward: Yallourn’s net depletion of the Latrobe River system could rise from about 13.6 GL a year to as much as 27 GL a year.
That is not a reduction. It is an approximate doubling.
Yet EnergyAustralia claims the new entitlement would “substantially reduce demand” and leave an additional 9.5 GL unallocated compared with the existing entitlement.
In our view this is selective accounting. It obscures the real hydrological effect of the proposal on the Latrobe River, the Lower Latrobe Wetlands, Lake Wellington and the wider Gippsland Lakes system.
How much water is 27GL per year?
It is the equivalent of draining the Maroondah Reservoir completely dry each year, all simply to accelerate the filling an open cut mine pit and all drawn from the Latrobe River system.
A river already in deficit
The Durt-Yowan/Latrobe River and its tributaries are an essential source of freshwater for the Gippsland Lakes, including the Ramsar-listed Lower Latrobe Wetlands.
The Victorian Government’s Central and Gippsland Region Sustainable Water Strategy identifies an environmental water deficit of 129 GL a year in the Latrobe River and estuary. It also commits the government to recovering additional water to improve river health, water quality, habitat and drought refuges.
Allowing EnergyAustralia to remove the practical benefit of around 13 GL a year in historic return flows would directly undermine the government’s own water-recovery commitments.
The river cannot be restored by promising to return water with one hand while authorising a major new net loss with the other.
EnergyAustralia’s application also acknowledges that the loss of power-station return flows may increase reliance by irrigators on the Latrobe Reserve. This further confirms that the proposal would leave less water circulating through the system.
Water stored in a mine void is water lost to the river
EnergyAustralia argues that water used to fill the proposed pit lake is not “consumed” because it remains in the landscape and may provide ecological or rehabilitation benefits.
The CWA's position is that this argument should be rejected.
Water placed in a mine void is no longer available to provide the baseflows, freshes, high flows and floodplain inundation required by the Latrobe River, its wetlands and the Gippsland Lakes.
The ecological value of water depends on where it is, when it arrives, how often it flows and how long it remains available to the river system. Water stored in a pit lake cannot simultaneously perform the freshwater functions needed downstream.
A mine lake may be useful for geotechnical stability or site rehabilitation. That does not make the water ecologically available to the Latrobe River.
EnergyAustralia should not receive a 30-year licence to take regardless of need
The proposed entitlement should also not operate as a standing right to take up to 27 GL every year for as long as 30 years, irrespective of how quickly the approved rehabilitation outcome is achieved.
Any water entering the mine through the Morwell River Spillway, flood events, river breakouts or connected overland flows will contribute to the pit-lake level. Those inflows should reduce the remaining volume EnergyAustralia is permitted to take under the entitlement.
Otherwise, the company could reach its rehabilitation target sooner through captured river or floodwater and still retain the right to continue extracting under the full entitlement.
The entitlement must therefore be tied to a maximum cumulative rehabilitation volume, not simply an annual extraction limit and a maximum term.
Rivers last—not rivers first
EnergyAustralia should also be required to demonstrate that recycled, manufactured and other lower-impact sources have been exhausted or are not reasonably available before it is permitted to take water from the Latrobe River.
River water should be the source of last resort.
The cost of rehabilitation should be borne by the mine operator, not transferred to waterways, wetlands, Traditional Owners, irrigators and future generations.
Any price imposed for river water must reflect its scarcity and environmental value, the loss of return flows, climate risk and the recognised 129 GL annual environmental deficit. Revenue should be directed back into measurable recovery of the Latrobe River, Lower Latrobe Wetlands, Gippsland Lakes and Traditional Owner water outcomes.
CWA’s position
The Concerned Waterways Alliance is calling on the Minister for Water not to approve EnergyAustralia’s proposed entitlement in its current form.
Any new entitlement must:
- be assessed against Yallourn’s historic net use of about 13.6 GL a year, not the nominal 36.5 GL paper entitlement;
- be reduced by at least 13 GL a year unless equivalent, enforceable and independently verified environmental water recovery is secured;
- apply a binding “rivers last” source hierarchy;
- include a cumulative volume cap and automatic reduction as spillway, flood and other inflows contribute to filling the mine;
- terminate when the approved rehabilitation level or cumulative fill volume is reached;
- confine all water use to narrowly defined rehabilitation purposes;
- prohibit the sale or transfer of mine water for unrelated commercial uses; and
- require full public reporting, adaptive pricing and reinvestment in river recovery.
Safe and stable rehabilitation of the Yallourn mine is necessary. But EnergyAustralia must not be allowed to disguise an approximate doubling of its net take as a reduction in demand.
The Latrobe River and Gippsland Lakes are already paying the price of decades of extraction and modification. Mine rehabilitation must contribute to their recovery—not deepen the deficit.
Our submission can be read in full at: https://concernedwaterwaysalliance.org/cwa-submission-potential-water-access-for-yallourn-coal-minerehabilitation/
For an overview of the Latrobe River and Gippsland Lakes System watch the CWA produced video below: