Submissions to government enquiries

CCBR makes formal submissions on a range of political issues, at both state and federal level. In addition we write to local State and Federal MPs and ministers, on relevant issues. We encourage individual members to do the same.

2018

Jun: CCBR's submission on Adani's proposed 330% expansion of dam

Mar: CCBR's submission on the National Energy Guarantee (NEG)

2017

Nov: CCBR's letter to CMEC about its proposed financing of Adani mine 

Oct : CCBR's letter to NAIF requesting them not to make a loan to Adani

Jul :  CCBR's submission to ATO review of Deductible Grant Recipient rules 

May: CCBR's submission to IPART's review of NSW PV feed-in tariffs

May: CCBR's submission to the Federal Review of Climate Policy Discussion Paper

Mar: CCBR's submission to the Greater Sydney Commission's Draft Central District Plan

Mar: CCBR's submission to Finkel review of NEM

2016

Nov: CCBR's submission to the Senate Inquiry into Coal Plant Closure

Oct: CCBR's submission to the NSW Rocky Hill Coal Project

Oct: CCBR's submission to Standing C'tee re ratification of the Paris Agreement

Aug: To NSW Energy Minister re upcoming COAG

Mar: CCBR's submission to Mark Butler on Labor's climate policy

Feb: CCBR's submission to NSW EPA on Container Deposit Scheme

2015

Nov: CCBR's submission to M4 East Environmental Impact Statement

Sep: To PM calling for stronger commitments on emissions (208 signatures)

May: CCBR's review of Leichhardt Council's Sustainability Strategy

Apr: CCBR's submission on Post-2020 Emissions Targets

Mar: Response from Mathias Cormann, agreeing Hunt lied 

Jan : To Greg Hunt regarding cost of abatement under the Carbon Tax

2014

Apr: CCBR's submission on Modelling Assumptions for RET review

Feb: CCBR's submission on the Emissions Reduction Fund Green Paper

2013

Feb: CCBR's submission on Leichhardt Municipal Council's Climate Change plan

2012

Oct: CCBR member's submission on NSW Draft Renewable Energy Action Plan

Mar: CCBR's Submission on Draft NSW Planning Guidelines: Wind Farms

Mar: CCBR's Submission on Draft Energy White Paper

Jan: CCBR's Submission on IPART's Draft Report re Solar Feed-in Tariff for NSW

2011

Dec: CCBR's Submission on the CEFC's Mandate

Sep: CCBR's Submission on a Fair Solar Feed-in Tariff for NSW

Aug: CCBR's Submission on Draft Exposure of Clean Energy Bill

April: CCBR's submission to NSW Planning and Infrastructure's 2011 Proposed Coal & Gas Strategy (no longer online).

Feb: CCBR's Submission to Senate Inquiry on The Social and Economic Impact of Rural Wind Farms is number 310 (a PDF file)

2010

Jan: Submission on The Treatment of 'Solar Credits' Renewable Energy Certificates under the RET is here.

2009

Apr: Submission to Department of Climate Change's Exposure draft of the Carbon Pollution Reduction Scheme legislation

Oct: Submission to NSW State Government's Major Infrastructure Planning, Bayswater B Power Station Proposal. The response can be found here.

Oct: Submission to NSW State Government's Major Infrastructure Planning, Mount Piper Extension Power Station Proposal.The response can be found here.

2008

Sep: Submission to Federal Government's CPRS Green Paper

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Federal Submission on North Galilee Water Scheme (NGWS) proposed by Adani Infrastructure Pty Ltd, June 2018

Please accept this submission on behalf of Climate Change Balmain-Rozelle to the EPBC referral for the North Galilee Water Scheme (NGWS) proposed by Adani Infrastructure Pty Ltd (2018/8191) (Adani).

Referral EPBC # 2018/8191

Referral Title: North Galilee Water Scheme Project

Climate Change Balmain-Rozelle (CCBR) is a community group from Sydney’s Inner West working towards a world which relies less and less on fossil fuels, and more and more on clean renewable energy, reducing carbon emissions and heading off the damaging effects of global warming. It has 1000 supporters, and our members regularly review, research and make submissions to government enquiries.

We recommend that you declare the Scheme as a controlled action under s67 of Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) because it will have, or is likely to have an impact on matters of national environmental significance.

The "North Galilee Water Scheme Project" proposes to expand the existing 2.2 billion litre Belyando Junction Dam to 10 billion litres. Adani Infrastructure proposes to extract 12.5 gigalitres per annum from the Suttor River and Burdekin Basin.

As noted in the referral, the proposal includes a 110 km water pipeline to transport this water "...to the operators of the Carmichael Coal Project... ". The dam and pipeline are clearly intended for use in the proposed large Carmichael coal mine, and this proposal is clearly an action that involves “large coal mining development” as defined under s 24D of the EPBC Act.

We believe this will have a significant impact on water resources.

The EPBC Act states that it will protect "a water resource in relation to coal seam gas development and large coal mining development". The "water trigger" allows impacts to be "comprehensively assessed at a national level". We believe this means the EPBC should act to protect this water resource. At the very least, approval of this project should be conditional on the outcome of a comprehensive assessment that is evaluated at a national level. Licenses granted by State and local government authorities need not stand in the way of nationally significant environmental protection.

Disturbing 1,234 hectares of land, increasing the dam's capacity by 7.8 billion litres and removing 12.5 gigalitres of water a year through the pipeline, has potential negative impacts on the Suttor River, local wetlands and all landscapes crossed by the pipeline. The referral states that the pipeline will run through wetland areas protected by State legislation. We also believe this disturbance of land and loss of river water is likely to affect threatened wildlife species and ecological communities in the area. According to the Queensland Government's Wetlands database, threatened species in the area include the Bridled Nailtail Wallaby, Koala, Greater Glider, Northern Quoll, Black-throated Finch, Squatter Pigeon, Common Death Adder, and Estuarine Crocodile.

The impact of disposing of 2.5 gigalitres of water per year, after use in the coal mine should also potentially be assessed thoroughly at a national level. If large volumes of run-off containing silt and other pollutants reach the ocean, there could be impacts on the Great Barrier Reef Marine Park area. This is another resource protected by the EPBC.

We also question the veracity of two statements made in Adani’s referral:

"The Proponent has not been the subject of any environmental legal proceedings that have resulted in fines or prosecution "

"Both Adani Infrastructure and the Australian parent companies not been subject to any proceedings under a Commonwealth, State or Territory law."

This is not entirely factual. In August 2017 Adani were fined $12,000 for a stormwater breach at the Abbott Point coal terminal in Queensland. This is being appealed, but the fact remains that a legal proceeding against the Adani Group resulted in a fine. We note that it has been alleged that Adani altered a consultant's report submitted as part of the appeal.

The Adani Group's environmental credentials are concerning, due to many fines issued for international legal breaches. The Chief Executive of Adani Australia was in a senior position at a mining company found criminally liable for poisoning a river in Zambia. In India, Adani were fined $4.8m for illegally clearing mangroves at Mundra and at Hajira, destroying the livelihoods of fishermen. In Mumbai, the Adani Group delayed for five years before cleaning up after a coal ship sank. In view of their history, we feel there is a strong risk that the Adani Group will not exercise due environmental care in the delivery of this project.

We hope you will act to safeguard these matters of national environmental significance. A comprehensive assessment would be appropriate before considering approval of this proposal. We believe the assessment should be made at a national level.