Unpacking the flaws in Adani’s water management plan


Matthew Currell, RMIT University and Adrian Werner, Flinders University

Adani’s groundwater dependent ecosystem management plan for its proposed Carmichael coal mine was recently approved by federal Environment Minister Melissa Price, despite a review from CSIRO and Geoscience Australia that points out major problems with the modelling.

According to the minister, approval was granted only after the company made commitments to fully address these issues (a claim later called into question).




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However, when we look closely at the flaws in Adani’s plan it’s not clear they can credibly be remedied. There’s a very real chance the mine could cause irreversible harm to the nationally significant Doongmabulla Springs.

What a groundwater model is supposed to do

The primary purpose of the model – as is the case for most groundwater models used in mining impact studies – is to determine the likely effect of mining on groundwater levels and flows of water to and from key areas.

One important goal of the model is to estimate the drawdown (decrease in groundwater levels) in aquifers around the mine as it pumps water and digs through aquifers to reach the coal.

Drawdown may cause groundwater levels to decline below thresholds critical to the function of whole ecosystems, such as (in this case) the Doongmabulla Springs.

Groundwater models can also be used to assess changes in flows of water to and from springs and streams, such as the Carmichael River, which crosses the mine site.

What flaws in Adani’s modelling were identified?

CSIRO and Geoscience Australia’s review pointed out three major flaws:

1. Over-prediction of flow from the Carmichael River to groundwater

Groundwater and surface water are intimately connected in the water cycle. For example, in some areas surface water can “recharge” aquifers, while in others aquifers provide water that keeps rivers flowing.

According to the review, Adani has overestimated how much water would flow from the Carmichael River into the aquifers below. This means there is in reality less water available to replenish the groundwater system below the river, which in turn means that the mine will likely cause greater groundwater drawdown than predicted.

2. The hydraulic parameters chosen for key geological units

A fundamental part of any groundwater model is the hydraulic properties selected for each geological layer through which groundwater moves. The most important is hydraulic conductivity: a measure of how much water can be transmitted through an aquifer over time. The review found that Adani’s model uses hydraulic conductivity values significantly different from the values estimated by previous testing of the geological layers at the mine site.

For example, Adani’s model assigned one key layer (the Rewan Formation) much lower hydraulic conductivity values than actually indicated when consultants tested this layer.

This is critically important, as it is the main layer separating the coals that will be mined from shallower aquifers. CSIRO and GA’s conclusion was that this also caused the model to predict less drawdown at the Doongmabulla Springs than is likely in reality.




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3. Bore heights used to calibrate the model were incorrect

According to the Australian Groundwater Modelling Guidelines, groundwater models should be calibrated. This involves comparing predictions made by the model with already measured water levels and other field data.

Calibration fine-tunes models, ensuring they are capable of replicating known behaviour, before predicting future behaviour. Correcting errors identified in the heights of some bores used in the model resulted in a lower overall match between modelled and observed water levels from the site.

The Carmichael River will be affected by Adani’s mine.
Lock The Gate Alliance/flickr, CC BY

Significance of these issues

These flaws are of major significance. If the model is corrected to address them, the review points out that the drawdown at the Doongmabulla Springs will in all likelihood be higher than required under Adani’s federal approval conditions.

We have published peer-reviewed science pointing out additional problems, which the review also noted.

A key uncertainty yet to be resolved is determining the predominant aquifers contributing water flow to the Doongmabulla Springs. It’s possible there exists a deeper source aquifer (rather than, or in addition to, the aquifer assumed by Adani). This has further implications for the level of impact the mine will have on the springs, and the effectiveness of the proposed monitoring program.

Adani was not required to address these problems prior to federal approval of its groundwater plans and is not required to do so until two years after mining activity begins (although, the Queensland government may yet require this).

This raises questions about the environmental approvals process, which currently allows major scientific issues to remain unresolved. Prior to approval, there are opportunities for scrutiny of a project’s impacts, which can result in major project modifications, strict operating conditions or even (in rare cases) rejection. Following approval, opportunities for independent scientific and public input and further modifications are far more limited.

‘Adaptive management’ will not protect the Doongmabulla Springs

In the decision reached by the Queensland Land Court following an objection to the mine in 2014-15, significant uncertainty about its future impacts was recognised. However, it was concluded “adaptive management” would nonetheless safeguard the Doongmabulla Springs. This argument was also the basis for federal approval under the then environment minister, Greg Hunt.

But what is “adaptive management” and can it be meaningfully used here? We would argue no.

The mine may cause the Doongmabulla Springs to cease flowing.
Lock The Gate Alliance/flickr, CC BY

Adaptive management is essentially when a company commits to flexibly changing its approach as it learns more about the environmental impact of its activities.




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However, there is a significant risk that the mine may cause the Doongmabulla Springs to irreversibly cease flowing. Adaptive management, as the US Department of the Interior points out, cannot be used if decisions cannot be meaningfully revisited and modified.

Indeed, Adani has not defined substantive corrective measures for reversing future spring-flow impacts from mining – an essential element of adaptive management. It’s critical Adani puts forward its plan for dealing with these very real risks. Without a credible plan, regulators cannot hope to make an informed decision about the risk the mine poses to the Doongmabulla Springs.The Conversation

Matthew Currell, Associate Professor in Environmental Engineering, School of Engineering, RMIT University and Adrian Werner, Professor of Hydrogeology, Flinders University

This article is republished from The Conversation under a Creative Commons license. Read the original article.

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Don’t forget our future climate when tightening up building codes



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Australia’s new National Construction Code doesn’t go far enough in preparing our built environment for climate change.
Sergey Molchenko/Shutterstock

Deo Prasad, UNSW

Too often it takes a crisis to trigger changes in legislation and behaviour, when forward thinking, cooperation and future planning could have negated the risk in the first place. Australia’s building and construction industry is under the microscope and changes in the law are in the wind, due to situations that could have been avoided. These include the evacuation of Sydney’s Opal building and the fires in Melbourne’s Lacrosse tower in 2014 and the Neo200 apartment building in February, both of which were fuelled by combustable cladding, as was the 2017 fire in London’s Grenfell Tower that killed 72 people.

The Shergold Weir report made 24 recommendations to improve the National Construction Code to ensure compliance, integrity and more. Commissioned by federal and state building ministers, the report was made public at the Australian Building Ministers Forum in April 2018. But implementation has been too slow to prevent the problems in the Opal and Neo200 apartment buildings. And it included no changes to climate-proof buildings.




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Australia has a new National Construction Code, but it’s still not good enough


A new National Construction Code comes into effect on May 1. Recent events have, however, exposed inadequate construction standards and increased public pressure for further change. This presents an opportunity to future-proof our cities as well as restore public confidence in our construction industry.

Construction codes were created to eliminate “worse practice”, but we are now in a position to make them “best practice”. Importantly, we must prepare for climate change. Australia is increasingly experiencing more extreme weather patterns, but are we ready?

The legislative overhaul must also include building sustainability and higher performance requirements. A low-to-zero-carbon future must be part of the picture.

Construction code changes are needed urgently, not just for increased safety, but to ensure future urban developments:

  • are ready for higher energy demands to cool and heat buildings
  • are designed to maximise sun and shade at the appropriate times to cool and warm both building and street
  • use materials that reflect heat for hot climates and absorb it for cooler ones
  • maximise insulation to reduce energy use
  • provide enough green space to give shade, produce oxygen and sustain a healthy environment
  • use water features to cool common and public areas
  • install smart technology to monitor and manage buildings and precincts.



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As climate changes, the way we build homes must change too


Many leading developers are taking the initiative to ensure projects include high-performance, zero-carbon, highly energy-efficient buildings, with top star ratings, but action needs to be across the board. This can only be done via tough legislation and enforced compliance.

The University of NSW’s Tyree Building is an excellent example of a high-performance building, as is One Central Park, Sydney, which features hanging gardens and an internal water recycling plant. But its most striking feature is its “heliostat”, a large array of mirrors that reflect sunlight to areas that would otherwise be in shadow.

One Central Park.
SAKARET/Shutterstock

Around the world, high-performance buildings are on the increase, such as 313@Somerset in the heart of Singapore, and the Sohrabji Godrej Green Business Centre in Hyderabad – India’s first Leadership in Energy and Environmental Design (LEED) platinum-rated building. There are many more.

Changing the law

New building standards and compliance are required to ensure high-performance buildings are the norm, not the exception. The construction industry should fulfil a “cradle to cradle” objective for materials. This means accounting for:

  • where materials come from
  • how materials are made
  • safety levels
  • carbon component
  • recyclability at demolition.

Laws covering low-carbon building design are imperative, setting standards for geography, maximising natural light, air flow, insulation and smart technology. Technology can monitor and run a building’s utilities to ensure it’s not only energy-efficient but also delivers a health standard that’s adaptable to the future pressures of climate change.




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Green buildings must do more to fix our climate emergency


Sustainable buildings are achievable now

Current know-how makes all this achievable. Over the past seven years the Cooperative Research Centre for Low Carbon Living and its industry partners have funded research into most low-to-zero-carbon aspects of the built environment. This has led to many recommendations in reports like Built to Perform, produced by the Australian Sustainable Built Environment Council.

The many research projects include:

  • 17 living laboratories providing cutting-edge data
  • creating low-carbon communities
  • developing tools to measure carbon outputs, from materials to services
  • studying the effects of heatwaves in Western Sydney and ways to cool cities
  • research into low-carbon concrete made of fly ash.

This plethora of data reveals that sustainable cities and precincts are achievable, while providing for a growing communities. Blockchain and solar technology, for example, is now proven for managing a precinct’s energy needs and can help turn energy users into providers.




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Although we are more global than ever, online and social media have in turn made us locally focused. We can know what’s going on in our street at a click and this technology is applicable to the operation of our future, sustainable cities.

We have the data, expertise, tools and knowledge to make safe, low-to-zero-carbon cities part of our future. But there’s much work to do. We still need to implement this knowledge, use the tools, change behaviour and instil 100% trust in the design and construction process. There’s no time to waste.The Conversation

Deo Prasad, Scientia Professor and CEO, Co-operative Research Centre for Low Carbon Living, UNSW

This article is republished from The Conversation under a Creative Commons license. Read the original article.