Comments to be attributed to the Deputy Premier and Minister for State Development,

Infrastructure and Planning, Jeff Seeney.

The Carmichael Project was independently assessed by Queenslands Coordinator General, without
political interference.
In making his decision the Co-ordinator General considered:
67 written public submissions and 18,000 online submissions on both the EIS and
supplementary EIS
39 technical reports on water impacts conducted over four years and totalling 5400 pages
completed by international consultants GHD
a peer review of GHDs body of work conducted by international consultants URS
analysis by professional officers within Queensland Government agencies, the Department of
Environment and Heritage Protection, the Department of Natural Resources and Mines, and
the Department of Science, Information Technology, Innovation and the Arts
advice provided by the IESC
an independent peer review of key elements of the IESC advice (groundwater flow
conceptualisation and the use of model boundaries) commissioned by the Coordinator
General and undertaken by Dr Noel Merrick an expert in groundwater modelling and
hydrology.
The CG has imposed 190 conditions on the project, and his report now goes to the Commonwealth
Environment minister for a decision on issues pertaining to the Commonwealth Environmental
Protection and Biodiversity Conservation (EPBC) Act under the assessment bilateral agreement.
Specific responses:
1. Why did the State Government consider it necessary to hire an expert to rebut this part of the
IESCs concerns?

A. It is standard practice for the Coordinator General to use his independent powers to draw
upon whatever independent expert advice he feels is necessary to adequately assess all the
material he must consider through the Environmental Impact Statement process. Dr Noel
Merrick was contracted in accordance with this process. The two main concerns of the IESC
relating to groundwater modelling were groundwater flow conceptualisation and model
boundaries. These issues were at odds with the advice of State Government experts, the URS
peer reviewer and GHD. The Coordinator-General considered that a third party independent
expert review would be beneficial to further confirm the governments and proponents views
and adequacy of the assessment.

2. Why did the State Government not commission similar expert reviews on any of the IESCs
other concerns?

A. See answer to Q1 why this scope was chosen. In accordance with the standard process for the
Coordinator-Generals assessment process under the State Development and Public Works
Organisation Act 1971, assessment of environmental issues was undertaken using the
analysis and advice of professional staff in DNRM, DSITIA, DEHP and the Office of the
Coordinator-General. Other matters raised by the IESC were addressed in accordance with
these standard processes.


3. How was Dr Merrick selected?

A. In accordance with the standard purchasing process for contracts less than $10,000, a
selection process was undertaken from a panel of three experienced groundwater experts
nominated by DNRM. Dr Merrick is a groundwater modeller, hydro geologist and
geophysicist with over 40 years experience in groundwater management issues and policies
and is familiar with the hydro-geology of the Galilee Basin.

4. How much was he paid?

A. See response to Q 3.

5. Does the State Government consider the other concerns raised by IESC to be equally ill-
founded?

A. The Coordinator-Generals Evaluation Report addresses all elements of the IESC advice
including those views that have been accepted.

6. Is it fair to say that the Coordinator-Generals conditions place the burden on the proponent to
find the missing data that the IESC drew to the attention of the State Government?

A. The Coordinator-General determined that the proponent provided sufficient information to
allow the project to be adequately assessed. A wide range of mitigation measures and
conditions were set to address all the predicted impacts of the project. Furthermore, the
Coordinator-General conditioned a comprehensive program of data gathering, monitoring,
review, and groundwater model updating for the next stages of the project so the actual
impacts can be quantified and mitigation measures adapted to address all water issues.

7. Comments to be attributed to Queensland Environment Minister Andrew Powell.

It is unfortunate that the Auditor Generals report ultimately reflects how things were when we
came to government, rather than what they are now.
The report has highlighted a range of legacy issues that have plagued previous Labor
governments for over a decade.
EHP had started work to address seven of the nine recommendations made by the Auditor-
General either before or during the audit.
We have implemented a new regulatory strategy that has ensured more environmental compliance
inspections are carried out than ever before.
The data contained within the report clearly demonstrates an increased rate of compliance checks
since 2012.
The comments in the report ignore the legislative obligations that all companies have and the
significant penalties that major breaches can attract. Serious environmental incidents are
extremely rare and EHP has a strong track record of taking enforcement action including legal
prosecution against resource companies that fail to meet their environmental obligations.

I am very confident with the new strategies, the new systems, and hard- working officers out on
the ground that EHP will continue to successfully manage any risk and protect our environment.
























IESC Issues and official Coordinator General response:
IESC Advice Coordinator-Generals Position
Groundwater flow
conceptualisation is not
supported by data. The IESC
therefore has no confidence in
the models impact predictions.

The CG has accepted Adanis groundwater modelling as
consistent with available data and that impacts have
been adequately identified and addressed. Groundwater
flows are consistent with groundwater head data.
Conditions require Adani to establish a groundwater
monitoring program to feed into regular groundwater
model reviews.

The proponents numerical
groundwater model uses no
flow boundaries and truncation
of formations on the western
side that influence the
predicted outcomes.
The CG has determined that Adani has not used no-flow
boundaries and that the modelling boundaries used in
the model are appropriate for the project and consistent
with available data. The IESCs basis for this advice is not
substantiated.
The Rewan geological
formation to the west of the
mine site may not act as a
barrier to flow of water into the
project area from the Great
Artesian Basin.
The CG has accepted that the Rewan formation is a
regional aquitard that prevents significant transmission of
water between the Great Artesian Basin and the Galilee
mine aquifers. Conditions require Adani to research and
monitor Rewan connectivity including any impacts of
mine subsidence.

GDE - Impacts on the
Doongmabulla Springs to the
west of the site are uncertain.
The CG has considered this issue and determined that
there are minimal likely impacts predicted for these
springs. Adani has been conditioned to establish a
comprehensive set of base line data and implement
surface and groundwater monitoring to identify and
impacts from the mine groundwater draw-down. Should
impacts be determined, Adani must mitigate or offset the
impacts.

GDE - There is uncertainty as to
the source of water or impacts
on the Mellaluka Springs to the
south of the mine site.
The CG has accepted this advice and conditioned Adani to
undertake sufficient survey bores to determine the
aquifer source for the springs, continue monitoring and
to mitigate or offset any impacts identified.

GDE - Impacts to riverine
vegetation (including the
threatened waxy cabbage palm)
along the Carmichael River may
be greater than predicted by
the proponent given reduction
in river flows.

The CG has accepted this advice and conditioned Adani to
implement surface and groundwater monitoring of all
riverine vegetation. Any impacts to the waxy cabbage
palm will need to be offset.
Cumulative impacts - the The CG does not accept that Adani should consider
project should consider the
impact of the proposed China
Stone project to the north of
the project, as well as approved
project (Alpha, Kevins Corner
and China First) some 80 km to
the south.

potential impacts of the China Stone project that has yet
to provide any relevant information through its EIS
process. Adani has been conditioned to contribute data
and funding to a DNRM regional water balance model
and assessment.
Cumulative impacts - The
Committee supports the
proposed regional scale water
model and balance assessment
to be undertaken by DNRM.

The CG has conditioned Adani to contribute data and
funding to this model.
Concerns that mine final voids
will fill with water and lead to
ongoing loss of groundwater
due to evaporation and
potential contamination.


The CG has conditioned Adani to partially refill voids to
above the coal seams and the general groundwater level,
minimising evaporation and long term groundwater loss.
Flood levees might impact on
ecology of the Carmichael River.
Adani has provided further information on this matter
acceptable to the CG.
A mine water discharge
strategy is not presented. The
mine water balance is
inadequate and overburden
material needs further analysis
to identify acidification
potential.
The CG considers that Adani has provided adequate
information to support a full set of EA conditions for the
mine including discharge limits, a monitoring and
reporting program and location and design of regulated
storage structures.
Since the IESC advice, Adani has provided further
information on waste rock analysis and management, and
a revised water balance acceptable to the CG. This
information has clarified the acidification potential of the
overburden and clarified water usage and discharge
rates.

Extraction of water from the
Belyando River to supplement
water requirements for the
mine will have downstream
impacts
The CG does not consider that the amount of water being
removed from the Carmichael or Belyando River systems
will have noticeable impact downstream given the
amount of water in the river system. The water allocation
for the mines purpose will be provided from the State
reserve in this river system, and will not affect the water
volumes considered necessary to provide for
environmental flows.