Carmichael Coal Mine (Adani Mining Pty Ltd, trading as Bravus Mining and Resources)
Background
The Carmichael Coal Mine is located 160km north-west of Clermont in central Queensland.
Before being approved, the project underwent an Environmental Impact Statement (EIS) process, which included rigorous evaluation (including public consultation) about the project’s potential environmental, economic and social impacts.
The EIS was approved to proceed by the Coordinator-General in May 2014.
Following this process and a hearing before the Land Court, as Queensland’s environmental regulator, the department issued the first Environmental Authority (EA) EPML01470513 to Adani Mining Pty Ltd (trading as Bravus Mining and Resources) on 2 February 2016.
Requirements of Bravus’ EA included developing two environmental management plans, the Groundwater Dependent Ecosystems Management Plan (GDEMP) and the Black-Throated Finch Management Plan (BTFMP). These plans needed to be approved before Bravus could begin significant mining activities. These plans were approved in 2019.
Bravus commenced open cut mining in 2020.
As the environmental regulator, the department’s role is to ensure Bravus complies with its environmental obligations in its EA and under the Environmental Protection Act 1994.
The department reviews monitoring data, scrutinises management plans and conducts compliance and enforcement where appropriate.
Related information
- Environmental Authority EPML01470513.
Black-throated finch
The Carmichael Coal Mine site represents Australia’s most significant population of the Black-throated finch (southern subspecies). The bird is listed as endangered under Queensland’s Nature Conservation Act 1992 and the Federal Government’s Environment Protection and Biodiversity Conservation Act 1999.
On 31 May 2019, the department first approved Bravus’ Black-Throated Finch Management Plan (BTFMP). This plan has since been updated to incorporate improvements.
The development of the BTFMP has been a condition of the mine’s approvals since the Coordinator-General approved the EIS in 2014. Its ongoing implementation is a condition of Bravus’ EA.
Assessment of this plan was a rigorous process, informed by the best available science. The department met regularly with Bravus to ensure that the plan is robust and is well-placed to deliver the best outcomes for the protection of the black-throated finch. This process included an independent expert panel review.
Bravus must continue to implement the BTFMP throughout the life of the mine and take action to monitor, mitigate and manage their impacts on the finch population and its habitat.
The department reviews the monitoring data and the management actions regularly to ensure the BTF population and habitat are maintained.
Related information
Groundwater dependent ecosystems
There are a number of groundwater dependent ecosystems near the Carmichael Coal Mine site including the Doongmabulla Springs Complex, the Mellaluka Springs Complex, the Carmichael River and associated Waxy Cabbage Tree palm population.
On 13 June 2019, the department first approved Bravus’ Groundwater Dependent Ecosystem Management Plan (GDEMP). This plan has since been updated to incorporate improvements.
The GDEMP’s assessment was rigorous and based on the best available science. The department and Bravus met regularly to ensure the plan is robust and provides the maximum environmental protection.
In assessing the plan, Bravus and the department considered advice from CSIRO and Geoscience Australia. CSIRO and Geoscience Australia also confirmed that some level of uncertainty in geological and groundwater conceptual models always exists, and that is why it is important for Bravus to regularly refine their groundwater modelling (see below section).
Bravus must continue to implement the GDEMP throughout the life of the mine and take action to monitor the ecological condition of the groundwater dependent ecosystems (GDEs), including the Doongmabulla Springs Complex, and mitigate and manage impacts.
The department reviews the monitoring data and the management actions regularly to ensure the ecological condition of the GDEs are maintained.
Related information
Groundwater monitoring
Bravus’ EA requires a comprehensive, ongoing groundwater monitoring program.
In 2019, the department first approved the Groundwater Management and Monitoring Program (GMMP). This program has been updated since then to incorporate improvements.
The information from the program is used to evaluate and monitor potential impacts that may result from the mine on local groundwater resources, local landholder bores, aquifers of the Great Artesian Basin (GAB), GDEs, overlying alluvium and Tertiary sediments groundwater resources, and surface water resources (Carmichael River baseflow, Doongmabulla Springs Complex, and Mellaluka Springs Complex).
Bravus is required to undertake a comprehensive program of groundwater monitoring across the entire mining lease area as well as outside the mine boundary.
The department reviews the monitoring results to ensure that groundwater impacts are not greater than those authorised, particularly in relation to any drawdown of groundwater levels or change in groundwater quality.
Related information
Groundwater model
In addition to the GMMP, which requires comprehensive, ongoing monitoring in the area, Bravus’ EA also required the company to undertake a review of the groundwater modelling for the Carmichael Coal Mine two years after commencement of mining.
The model is required to be regularly re-run over the life of the project and refined using additional data, improving the accuracy of its predictions. This helps to ensure the early detection and prevention of any unauthorised groundwater impacts, including to the Doongmabulla Springs Complex, due to mining operations.
This adaptive management approach provides the opportunity for an operator to modify its mining activities, where necessary, to mitigate potential impacts. Bravus’ EA requires it to undertake model re-runs every five years, at a minimum, and to provide a report of the findings.
In early 2023, Bravus submitted its report about the first groundwater model re-run to the department. The department’s preliminary review of Bravus’ report identified concerns relating to predicted drawdown from underground mining, planned to commence after 2034.
On 2 March 2023, as a result of the department’s preliminary review, the department issued Bravus with an environmental protection order (EPO), which included a requirement for Bravus to provide a new model report to demonstrate that predicted drawdown would not exceed approved limits. This EPO was varied in April 2023 following an internal review application by Bravus.
In May 2023, after careful consideration, the department decided not to approve Bravus’ first groundwater model re-run report. The decision came after the department undertook a comprehensive review of Bravus' report, comprising the expert scientific advice from CSIRO and Geoscience Australia, which supported the department’s decision.
In evaluating Bravus’ report, CSIRO and Geoscience Australia concluded “the groundwater model is unable to support a robust uncertainty analysis and therefore confidence in the range of predicted impacts is low.”
The EPO also requires that the second groundwater model review addresses the feedback from CSIRO and Geoscience Australia.
The report must be approved by the department and includes a requirement that underground mining must not commence until impacts are consistent with those approved.
Bravus has filed an appeal against the EPO, which is currently before the Planning and Environment Court.
As part of the appeal, Bravus also sought a stay of the EPO requirement that the new Groundwater Model Review Report be provided by the end of May 2024. In granting the stay, the Court considered the schedule of works provided by Bravus which outlines the steps and timeframes it says are necessary to complete the Groundwater Model Review Report. The Court ordered:
- Bravus continue to complete the work required for the Groundwater Model Review Report, as detailed in its schedule of works; and
- The Groundwater Model Review Report must be provided to the department by 22 December 2025.
The EPO otherwise remains in effect, and therefore Bravus must not commence underground mining until the report is approved by the department.
The appeal remains before the Planning and Environment Court.
As part of its EA, Bravus is required to monitor groundwater levels and quality. The department has no concerns about current impacts to groundwater based on monitoring data submitted to date.
However, Bravus has now committed to DESI to undertake additional modelling work to demonstrate that impacts to the Doongmabulla Springs Complex will not occur while they complete the second model report.
The department recognises the significant cultural and environmental value of the Doongmabulla Springs Complex and is committed to ensuring the highest protection is afforded to the spring.
Undertaking this additional groundwater modelling will provide greater certainty around predictions and avoid any potential impacts to the springs.