WRITE A PUBLIC SUMBISSION

Help shape rehabilitation at Hazelwood

Until 10th May, you can have a say on plans to turn the Hazelwood mine into a toxic pit lake.

The mine’s operator, Engie, plans to flood the former mine site with vital groundwater, by diverting enormous amounts of water from the Morwell River.

We have serious concerns that Engie wants to dodge its responsibility and cut corners on properly rehabilitating the Hazelwood mine.

But we all have an opportunity to ensure better scrutiny for Engie’s plans, better outcomes for the environment, and better consideration of community concerns.

Until 10th May, government decision makers are taking feedback from the community on what we believe Engie should do to properly assess the environmental impacts of its pit lake plan.

Your feedback will help shape the ‘scoping requirements’ – or, what the government requires Engie to include in its assessment.

This is a critical opportunity to shape Hazelwood’s rehabilitation. It’s your chance to share your concerns about Engie’s rehab plans so far, and call on Engie to thoroughly assess all likely impacts of their plans.

We’ve put together this easy-to-follow submission guide outlining our concerns about Engie’s plans, and how you can have your say to ensure government decision makers thoroughly scrutinise Engie’s plans.

The work isn’t done when the coal mine closes; the work is done when all of us have clean air to breathe, a thriving environment, and healthy communities.

This public submission window has closed. Thanks for your interest!

WHY THIS MATTERS

We all deserve to have a say on decisions that impact us.

The Victorian government is accepting submissions from the community until 10th May. You must make a submission through the Engage Victoria portal for the project.

To write your submission, you can draft it directly in the Engage Victoria portal. Alternatively you may like to draft into a blank word document and copy your answers across. On the Engage Victoria portal, you will find a survey. This is where you provide your responses. You can use this guide to help you respond to the survey questions.

The first three survey questions ask for some basic information about your submissions.

The first question asks whether you are submitting as an individual, on behalf of a community group, or as an anonymous individual. It also asks you to enter your contact details.

The second questions asks you to select whether you want to make your submission using the online form, or by completing a version of the form in a Word template. We think the online form is easier, but if you’d like to complete the Word template, you can download it from under the ‘Documents’ heading on this page of the Engage Victoria Portal.

The third questions asks you to check all of the listed topics you think your submission covers. There’s no right or wrong answers here – just select the ones you think fit with your submission.

The next question in the survey is an open text field that asks: What is your issue or concern with the draft EES scoping requirements?

You’ll notice that the form doesn’t explicitly ask you to introduce yourself or why you’re making a submission, but we think it’s really important to give decision-makers a picture of the community interest in this project.

In answer to this question, we encourage you to include your introduction AND the summary of your concerns.

INTRODUCING YOURSELF

Your introduction can include who you are, why you care about our environment and the local community, and why this issue matters to you.

Your introduction is about your personal experience. You might be a member of the Latrobe Valley community, or have family or friends who worked at Hazelwood. You might be a scientist with deep understanding of the issues posed by rehabilitation, or member of a local environment group.

Perhaps you’ve recently moved to the Latrobe Valley, and want to make sure your family has a thriving future there. Or you might not live in the Latrobe Valley, but value taking action in solidarity with communities affected by coal and mining.

Any reason is an important reason – what matters is that it’s your experience.

You don’t have to get into all of the details of your submission here. Instead, share your story and paint a picture of who you are and why this matters to you; it’s important that government decision makers understand the people who will be impacted by their decisions.

SUMMARISING YOUR CONCERNS

This is where you can raise your concerns with Engie’s plans and the draft scoping requirements. All projects must undergo a process of assessing their proposed environmental impacts; this is called an environmental effects statement (EES). At the end of an EES, the community and the government should have a good idea about the impacts of the project.

When reading the scoping requirements, if you think something could be added, or that a study or issue is missing that would help you understand the impacts of the project, you should raise it in your submission.

Friends of Latrobe Water, Environmental Justice Australia, and Environment Victoria have consulted with multiple experts and have reviewed the draft scoping requirements. We have identified the issues below; you can use one, some or all of these in your submission.

Water

Engie’s plans could see millions of litres of water taken from the Latrobe River to flood the Hazelwood mine pits. Water is essential to the health of ecosystems in the Latrobe Valley, to the local community, and to other local industries such as agriculture. The draft scoping requirements currently do not require Engie to investigate any other water sources for the plans to flood the mine pit.

First Nations cultural values

The draft scoping requirements require an assessment of Aboriginal cultural heritage under the Aboriginal Heritage Act. An assessment of impacts on Aboriginal interests and values beyond only the Aboriginal Heritage Act should also be included, including impacts on any affected native title rights and interests, interests arising under the Traditional Owner Settlement Act and joint management, interests in water, and on Aboriginal peoples’ rights to maintain their distinctive relationships to any affected lands and waters.

It’s also important this assessment extends to First Nations values beyond the mine licence boundary (or, where the mine sits); there are likely to be impacts further afield in the Morwell River, broader Latrobe River system, and Gippsland Lakes.

Long term impacts

Decades of brown coal mining has caused extensive damage to the area – and will take decades to properly clean up. Additionally, it isn’t just the immediate mine area that is impacted, but the surrounding environment, too.

We know the water quality of the pit lakes will deteriorate over time and a significant amount of water will be required to top up evaporation each year. Engie plans to release toxic pit lake water into the Latrobe River system, which is likely to negatively impact water flows and water quality downstream, harming local ecosystems.

The draft scoping requirements do not sufficiently mandate a long-term and broader assessment of potential impacts from Engie’s rehabilitation plans. They also do not include assessment of how climate change will exacerbate these impacts.

Investigating all options

The Hazelwood Mine Fire Inquiry included an analysis of rehabilitation options for the site, and provided six options. Flooding the site to turn it into a pit lake was only one of these options, however; the draft scoping requirements only require Engie to assess the pit lake option for the Hazelwood mine. It’s crucial the government and the community know what other options are out there so that Engie rehabilitates the mine with the best, long-term outcomes for the community and environment.

Community attitudes

The community must be able to have a meaningful say on Hazelwood’s rehabilitation – and this means being given all of the options. In addition to the point above, the community attitudes for all possible rehabilitation options must be assessed – so that the community is fully aware of the options and impacts of each.

Job creation and economic benefit

There is not enough analysis on the potential for job creation and economic benefits of all of the rehabilitation options. Other options might bring more local jobs, plus better outcomes for the environment and the community; only assessing the pit lake option means these more beneficial outcomes could be lost.

Regional impact

The impacts of rehabilitating the Hazelwood mine will extend far beyond the site’s boundary. Engie needs to do further assessment of the cumulative impacts of mine rehabilitation on the whole Latrobe Valley, including on the community, cultural values, the river system, groundwater and Gippsland Lakes, and other water uses.

The next question will ask: What changes would you like to see in the draft EES scoping requirements to cover your issue or concern?

Having outlined your concerns with Engie’s plans and the current draft scoping requirements, this is where you can make clear recommendations for how the requirements can be strengthened. Below are the recommendations we have identified that will help ensure Engie’s environmental assessment is rigorous, thorough and wide-ranging.

  1. An Options Analysis, which assesses the technical feasibility of all other rehabilitation options apart from the pit lake option.
  2. An assessment of community attitudes to all possible rehabilitation options identified in the Options Analysis, in order to meaningfully gauge community views about the pit lake project.
  3. An analysis of the potential for job creation, the economic benefits and the potential future uses of each rehabilitation option. Other options might bring more local jobs, plus better outcomes for the environment and the community.
  4. Amend the scoping requirements to make it clearer that the potential impacts of the project extend both well beyond the mine licence boundary, and well into the future.
  5. An investigation into existing and potential future alternative water sources, not just the Latrobe River.
  6. An assessment of impacts on Aboriginal interests and values beyond only the Aboriginal Heritage Act, to include impacts on any affected native title rights and interests, interests arising under the Traditional Owner Settlement Act and joint management, interests in water, and on Aboriginal peoples’ rights to maintain their distinctive relationships to any affected lands and waters.
  7. A Regional Impacts Study which assesses the cumulative impacts of mine rehabilitation at all three Latrobe Valley coal mines on both the environment including the river system, groundwater and Gippsland Lakes, other water users, the community and cultural values.

This is the final step, and is important to make sure your submission is counted and reviewed. All submissions must be made through the Engage Victoria portal.

You must make your submission by midnight on 10 May 2023 for it to be counted.

Once you have answered the previous survey questions, all you need to do is follow the portal’s instructions to answer the privacy and consent questions, then hit submit.

Thank you for making a submission on the Hazelwood draft scoping requirements!

What’s happening at Hazelwood?

The Latrobe Valley has powered our state for decades. But brown coal mining has left the Latrobe Valley with a toxic mess and enormous, unstable mine pits that need to be cleaned up.

Six years after Hazelwood power station closed in 2017, the company that operates the mine, Engie, is still working on plans to rehabilitate the mine site.

What are Engie’s plans so far?

Engie proposes to flood the mine pit – full of toxic coal ash left behind from the mine – with freshwater taken from the Latrobe River.

Filling such a huge hole would take more water than Sydney Harbour, and brings serious consequences for the Latrobe River system, Traditional Owners, the local community, and other industries in the region such as agriculture.

Why does this matter?

Hazelwood is the first mine to be rehabilitated in the Latrobe Valley, and its rehabilitation will set a precedent for the remaining mines in the Valley – which means we need to make sure it’s done right.

What are the draft scoping requirements?

Any plans Engie puts forward about rehabilitating the mine site must be assessed by the Victorian government. As part of this process, Engie must prepare an Environmental Effects Statement to outline the environmental impacts of its plan, and how those impacts could be mitigated.

Right now, the Victorian government is taking submissions on the ‘Draft Scoping Requirements’, which will outline the requirements Engie must follow when completing its assessment of environmental impacts.

That means until 10th May, we have a critical window to share our concerns about Engie’s plans, and make sure all rehab plans are thorough, the best options are considered, and the best outcomes for the community and environment are prioritised.