Making A Submission on New Acland Coal’s Proposed Amendment to Jondaryan Rail Dump
New Acland Coal (NAC) currently operate a large coal dump and rail load-out facility at the township of Jondaryan. The local community has been concerned about the dust, noise and traffic from it for many years. NAC had promised to shift the dump away from the town, but now they are reneging on that and intend to keep it going for up to 5 years. Stand with the people of Jondaryan who are concerned for their health and wellbeing.
The change currently being considered by the Coordinator General from NAC will allow them to continue operating the coal dump and train load-out facility at Jondaryan for up to five more years. The current Stage 3 approval requires the load-out facility to be removed prior to the commencement of mining at Stage 3.
You can read the full application to amend the approval here. Submissions are due by the 21st July.
How to Make a Submission
Make sure you provide your name and address at the bottom of your submission. That is needed for it to be a properly made submission.
Submit to: [email protected]
Or by Post: Attention: Coordinator-General
C/- Project Manager – New Acland Coal Mine Stage 3 project
Office of the Coordinator-General
PO Box 15517
City East QLD 4002 Australia
State that this is a submission on the New Acland Coal Mine Stage 3 Project Change Application 2 (Train load-out facility)
Let the Coordinator General know that you object to the proposal and ask him to refuse it, whilst making some of the following points in your own words:
- It would be wrong to allow a change now which was considered unacceptable in 2012 and was not been subject to environmental impact assessment in Stage 3. Allowing this change makes the current Acland Stage 3 proposal look much more like the original Stage 3 proposal which was rejected by the Queensland Government. The dust, noise, disturbance and traffic from the coal dump and load-out facility at Jondaryan township was one of the key reasons why the original Stage 3 was rejected. In the revised project overview provided by NAC in November 2012, which formed the basis on which the Qld Government agreed to consideration of a revised Stage 3 proposal, New Acland describe shifting the rail loop as a ‘key element’ and ‘key difference’ from the previous proposal.
- NAC’s claim in the application that 'no new environmental impacts will be created by the proposed amendment' is demonstrably untrue. There will be new environmental impacts from emissions of dust and noise from the JRLF for as many as 5 years longer than was set to occur under the original Stage 3 approval that was provided by the Coordinator General. These are new impacts that were not considered in any form in the Stage 3 EIS. NAC should be required to assess the full scale of those impacts, and particularly, the predicted load of dust and emissions, and their modelled distribution, as well as the health consequences of these emissions on local people, along with traffic impacts. Even if just comparing this proposal to the current situation at Jondaryan it will still be an increase in impacts, because coal production is set to increase from 5.2Mtpa to 7.5Mtpa, so the impacts of the load-out facility in terms of traffic, dust, noise and disturbance are likely to be even greater than they are now.
- The Land Court in its consideration of the case proceeded on the understanding that the rail facility would be moved, and there was no opportunity for objectors to raise the issue because it was not part of the proposal. The Land Court made two references to the facility being moved, stating that:
o ‘NAC has the infrastructure to conduct the Stage 3 mining operations, which are to be supplemented by a rail spur to the mine site from Jondaryan to remove the impacts of transporting coal to Jondaryan via large haul trucks.’ [22]
o ‘I note of course that creation of the rail loop is consistent with increasing road safety by the removal of haulage trucks, and the retention of railway jobs.’ [1832]
- The reasons put forward by NAC as to why it needs the extension are spurious. One claim made is they have been set back by changes to the Water Act 2000 requiring an Associated Water Licence for groundwater take. However, prior to the law change, NAC were required to obtain a Water Licence for groundwater take which has almost identical provisions to those which now apply to Associated Water Licences. In fact, NAC themselves acknowledged in the court of appeal that an Associated Water Licence is simply a water licence by any other name.
- NAC should be required to do a proper Social Impact Assessment on the proposal. There is a very strong argument that NAC should be required to conduct a full Social Impact Assessment for the proposed delay in shifting the JRLF. In 2017, the Strong and Sustainable Resource Communities Act was passed which required resource companies to conduct social impact assessments of their projects. Given this amendment is a very significant amendment, with major impacts for the local Jondaryan community, it should be subject to the new requirements for full social impact assessment.