The Victorian Farmers Federation (VFF) welcomes the opportunity to provide comment on the Latrobe Valley Regional Rehabilitation Strategy.
The Hazelwood Coal Mine Fire in 2014 had a lasting impact on the Latrobe Valley Community. Ensuring a viable outcome is achieved following the mine’s closure is critical to the long term prosperity for the region.
A full pit lake for Hazelwood mine would require 640 gigalitres of water. This is a significant volume of water which will have a lasting impact on the regional community. The VFF questions the premise of the strategy by simply proposing pit lakes and not looking at other options.
The Regional Rehabilitation Strategy states:
“The Hazelwood Mine Fire Inquiry……found that using water to create ‘pit lakes’ in the excavated coal mine voids is likely to be the most viable water to achieve long- term safe and stable rehabilitation of the mines. However the inquiry recognised that significant knowledge gaps existed in relation to this rehabilitation option1. “ (Pg 3)
However, a careful examination of the Hazelwood Mine Fire Inquiry Report 2015-16 Volume IV – Mine Rehabilitation states:
“Given the evidence before the Board, it is not presently possible to provide a definitive evaluation of rehabilitation options, in particular the pit lake option……, (Pg 114)2
“Without reliable sources of water, the pit lake option will be unviable and unsustainable. The uncertainty in this area is a limitation of the option, particularly due to the volumes of water, the timeframes, and the potential for external factors to influence availability of water” (Pg 109) 3
The VFF is concerned that recommendations of a pit lake are coloured by the Government’s desire to avoid fire risks and therefore a pit lake is seen as the easiest solution. Other options have not been described or evaluated.
Availability of Water
While the Strategy points to ‘pit lakes’ as the most viable option, without sufficient water, this rehabilitation option is simply not possible. Other options are not described or evaluated.
This document seems at odds with comments made in the Gippsland Sustainable Water Strategy in November 2011 which stated:
“current rehabilitation plans for open-cut coal mines involve flooding them to create artificial lakes. However, this is not considered to be an entirely viable option any longer because there is insufficient water to fill most of the mines4”. (Pg 132)
Given a decline in water availability since 2011, the VFF questions how the Department of Environment, Land Water and Planning (DELWP) believes there is sufficient water to fill the Hazelwood mine or the other mines when they cease operation.
When a groundwater licence is issued to take and use groundwater for ‘purposes associated with an open cut coal mine’, the licence may be issued for a period of up to 30 years, subject to any special conditions. In other cases, groundwater licences are limited to a period of up to 15 years, but can be renewed by the Water Minister under Section 58 of the Water Act.
The Strategy is unclear regarding groundwater availability and whether mines will be able to access groundwater beyond 30 years to fill the pit lakes.
If these groundwater licenses are extinguished, the viability of a pit lake option becomes even more dubious.
Summary of Recommendations
Recommendation 1: The Regional Strategy clearly articulate water availability problems associated with a pit lake at Hazelwood and why they now believe this is possible given past positions in the Gippsland Sustainable Water Strategy.
Recommendation 2 : That DELWP assess what new knowledge is available and explore additional options to a pit lake.
Recommendation 3: A detailed cost benefit analysis of all options is included in the Regional Strategy.
Recommendation 4: That DELWP acknowledge the true value of water and its increased value in the future when considering rehabilitation options for the mines.
Recommendation 5: The Regional Strategy must explore regional impacts of a pit lake option.
Recommendation 6: Agriculture cannot experience higher water costs as a result of creating pit lakes and mine operators competing with farmers for water.
Recommendation 7: The Regional Strategy should not be adopted until the Mine Land Rehabilitation Authority has been established in July 2020.