Submission on BHP Caval Ridge Mine Horse Pit Coal Extension in the Bowen Basin: an additional lifetime 440 megatonnes of CO2

Aerial view: existing Caval Ridge mine in the Bowen Basin, Queensland

Submissions for this coal mine extension closed 29 September 2023. The Labor Federal government has already approved 10 new coal or gas projects since coming to power in May 2022. The BHP Caval Ridge Mine Horse Pit Coal Extension is in the approval queue with about 100 other coal and gas projects. 

The Labor Government has promised a refresh of Australia's environmental laws in the Environment Protection and Biodiversity Conservation Act (EPBC), but those reforms continue  to be deferred. During the Howard government in 2005 Anthony Albanese proposed a Climate Trigger be inserted in the EPBC Act. It failed of course. Labor did not revisit a Climate Trigger amnedment in 2007-2013 when in power with the Rudd and Gillard governments, and has not raised it as a priority in the current term of the Albanese Government.

BHP Mitsubishi Alliance’s proposes to extend the Caval Ridge Coal Mine and operate it for more than three decades, to 2056. The mine is located  approximately 5 km south west of Moranbah in the Bowen Basin, Queensland. It is an open cut mining operation that supplies hard coking coal product for the export market.

The Proposed Project will extend one of the two pits and will involve extraction and combustion of approximately 15 million tonnes per annum (Mtpa) of coal.

The proposal aims to commence in 2025 and extend to 2055. The mining schedule indicates extraction of approximately 158.3 million tonnes of coal over the life of the Proposed Project. The total combustion CO2 emissions for the product coal of the Proposed Project is estimated to be 440.64 million tonnes of CO2 added to the atmosphere that will exacerbate global warming.

My submission was one of 147 submissions co-ordinated by the Mackay Conservation Group.

Minister Plibersek and her department are now reviewing public comments about this proposal, alongside the large volume of scientific evidence that  Environment Council of Central Queensland Inc (ECoCeQ)  submitted with its reconsideration request. 

EPBC Submissions

BMA Alliance Coal Operations Pty Limited
GPO Box 1389, Brisbane QLD 4001

Dear BHP Mitsubishi Alliance

Thank you for the opportunity to make a submission on the proposed extension of the Horse Pit at the Caval Ridge Coal Mine (the Project).

I have significant concerns about how any new and expanding coal mines can be consistent with meeting legislated environmental and emission reduction targets.  I believe this Project should be refused as it provides a significant threat to the environment which cannot be mitigated and no offsets will make up for the damage the mine will cause.  I have concerns relating to the impacts of Climate Change, Impacts to threatened species and communities,  Impacts on Ground and Surface Water & the Impacts on the Final Landform. I have outlined my concerns in more detail below:

Climate Change

- The Project is estimated to result in over 440 million tonnes of CO2.  This is a significant contribution to current emissions from Queensland’s fossil fuel, energy and industry sectors and it will lead to accelerated climate change at a time when the world is committed to trying to halt any further global warming.
- There is no assessment of the impacts of the greenhouse gas emissions or the impacts of the emissions on how these align with national emission reduction targets or BMA’s operational emission reduction targets. 

The science on fossil fuel extraction and climate targets is clear, and this mine extension is inconsistent with reducing emissions in line with international treaty: the UNFCCC Paris Agreement.

See: IEA (2023), Net Zero Roadmap: A Global Pathway to Keep the 1.5 °C Goal in Reach, IEA, Paris https://www.iea.org/reports/net-zero-roadmap-a-global-pathway-to-keep-the-15-0c-goal-in-reach,  which reiterates its finding that there is no room for new oil, gas, and coal beyond operating fields and mines for 1.5ºC

See also:
Welsby, D., Price, J., Pye, S. et al. Unextractable fossil fuels in a 1.5 °C world. Nature 597, 230–234 (2021). https://doi.org/10.1038/s41586-021-03821-8, https://www.nature.com/articles/s41586-021-03821-8

Nogrady, Bianca, Nature, 8 September 2021, Most fossil-fuel reserves must remain untapped to hit 1.5 °C warming goal https://www.nature.com/articles/d41586-021-02444-3

Kelly Trout et al (17 May 2022), Existing fossil fuel extraction would warm the world beyond 1.5 °C , Environ. Res. Lett. 17 064010, DOI 10.1088/1748-9326/ac6228, https://iopscience.iop.org/article/10.1088/1748-9326/ac6228

Threatened species and communities

- The project will impact on the threatened ornamental snake, squatter pigeon, king bluegrass and brigalow vegetation communities.  These are threatened species that have already been significantly impacted by coal mines in the Bowen Basin.
- Significant populations of koalas and greater gliders have been recorded in previous surveys in the Project area, but they were not recorded in the recent surveys.  It seems that they have become locally extinct due to the expansion of coal mines in the Moranbah area.
- The koala and greater glider have recently been reclassified as endangered due to ongoing habitat clearing and the impacts of climate change.  The approval of new and expanding coal mines will only see more fauna species be added to the endangered list unless appropriate controls are implemented to prevent the loss of habitat and ensure that emissions are rapidly reduced.

Impacts on Ground and Surface Water

- The Project proposes to release mine-affected water into Cherwell Creek.
- During significant rainfall events uncontrolled spills from dams containing mine-affected water into Horse, Caval, Cherwell and Nine Mile creeks may also occur.
- These releases will change water quality in the receiving environment which may impact on environmentally significant aquatic species such as the white-throated snapping turtle and the Fitzroy River turtle.  The Isaac River alluvium stygofauna are also likely to be impacted.
- The Project lies within the Fitzroy River Basin - the largest catchment of water entering the Great Barrier Reef World Heritage Area. 
- The cumulative impacts of mine-affected water from the growing area of coal mines on water quality entering the Reef must be considered.

The Final Landform

- The Project proposes to leave a final mine void of approximately 545 hectares, representing over half of the proposed disturbance area.
- Given the mine will impact on large areas of threatened species habitat, I consider that this level of rehabilitation is unacceptable.
- Your modelling also suggests that there will be a significant increase in water salinity in this huge mine void which is likely to lead to the water in the void being unsuitable for livestock or agriculture.
- This does not meet best practice or even leading practice in mine rehabilitation and it is clear that you have placed economic gain as more important than the protection of the local environment, water quality in the Great Barrier Reef catchment and inter-generational equity.

I urge you to demonstrate how this project aligns with environmental and climate legislation, particularly in relation to the matters raised in this submission.


Yours sincerely,
John Englart

27 September 2023