Gippsland Environment Group Inc
Lobbying against environmental threats on the unceded lands of the GunaiKurnai, Yaitmathang, Ngarigo and Bidwell Peoples
Comment for Hazelwood Rehabilitation Project Inquiry
Gippsland Environment Group
02 November 2026
Gippsland Environment Group Inc. (GEG) has been advocating for better utilization of water resources on GunaiKurnai lands and waters, since GEG’s formation in 2005. Over 20 years, GEG has participated in numerous stakeholder forums, lobbied federal and state governments regarding the condition of the Gippsland Lakes and engaged in multiple consultations with Victorian authorities over the Gippsland Sustainable Water Strategy (SWS) and the Central and Gippsland SWS.
GunaiKurnai lands, air and waters were sacrificed to power Victoria
GLaWAC’s vision calls for: “Respecting water sustainability: safeguarding the health of the Durt’Yowan (Latrobe River), and Gippsland Lakes, and upholding Gunaikurnai water sovereignty... In the places where mine voids are now exposed, our Old Ancestors once walked, fished, gathered and lived. These scars are a wound in Wurruk itself, a wound that cannot simply be filled in and forgotten.” https://gunaikurnai.org/healing-wurruk-after-coal/
Gippsland Environment Group wholly supports GunaiKurnai Peoples and their aims.
The Latrobe Valley suffers now from pollution caused by coal mining that powered the state's electricity for many decades. The residents of Gippsland, particularly Morwell and Moe are some of the most disadvantaged in the state despite generating much wealth for Victoria. We must not allow the current major industries in Gippsland – farming and tourism, which rely on healthy waterways – to be jeopardized to let international ENGIE off the hook.
Victoria is about to inherit a massive long-term costly liability
There has to be an awakening, that the mines can not ever be satisfactorily “rehabilitated” after the devastation of brown coal mining in the Latrobe Valley. Fairy tales from Engie PR about a lovely clean lake, a tourist attraction for boating and fishing are absurdly misleading and very unfair to hopeful locals.
Below: Engie PR video stills
Above: Hazelwood mine will be the first mine rehabilitated in Victoria. Photo: ABC NEWS Robert French
Engie’s EES does not demonstrate that the proposed pit lake will be genuinely sustainable and non-polluting. The EES’s own modelling predicts multiple metals will breach water safety guidelines over time – with aluminium and copper breaching limits from the first year. The EES doesn’t make any serious attempt to show that the pit lake will ever be safe to use, or that downstream impacts will be properly managed. In fact, it’s probable that proposed lake water will not be fit for tertiary contact for humans and will not sustain consumable fish.
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A Hazelwood mine pit lake is liable to have major water quality issues due to contaminants leaching from the coal mine pit - as well as contaminant leaching from the poorly capped Ash Ponds.
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At a maximum depth of over 140m, the lower depths are likely to be anaerobic, unlikely to support many life forms at all - and the whole lake is likely to have poor mixing characteristics.
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Eutrophication is likely if catchment runoff - with contaminants nickel and mercury plus nutrients, herbicides and insecticides - is used to fill the mine void. This will cause toxic algal blooms. No one is swimming or fishing in that!
Increased diversion of freshwater from the Lakes’ catchment will directly impact downstream users
Engie proposes to take up to 30 gigalitres a year of fresh river water for around ten years, longer in drought, then keep topping up the lake forever. That’s about three times what the power station used.
DEECA’s Latrobe Valley Regional Water Study warns that continued or increased extractions under a drying climate will cause serious harm to the Latrobe River, the Lower Latrobe Wetlands, and the Gippsland Lakes Ramsar Site.
Risks include:
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Ongoing declines in fish, frog, turtle, and waterbird populations
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Degradation of wetland vegetation and aquatic habitat
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Increased salinity that disrupts wetland productivity and ecological balance
Below: Eastern long-necked turtle. Photo by Danny Fog
The Gippsland Lakes are reliant on the discharges from its river system and in particular the seasonal wetting of the surrounding Ramsar wetlands of Sale Common, Hearts Morass, Dowds Morass etc. The Gippsland Lakes Ramsar Site is internationally protected and the state government has strict obligations to protect the system.
The government must go back to the drawing board and examine alternatives to river extraction
Gippsland Environment Group is extremely concerned that in this process, recycled and manufactured water sources and other rehabilitation options seem to have been ruled out by mining companies and by the Victorian government — and that this analysis has relied on fresh river water being artificially cheap.
The mine rehabilitation water-access price is now $230 per megalitre for Loy Yang and Yallourn. Melbourne Water's 2026–27 bulk drinking-water usage is $832.75 per megalitre, and its bulk raw-water usage is $638.27 per megalitre. So the mines are getting the best and cheapest water that would require minimum treatment for human consumption. This is outrageous.
Options like fit-for-purpose treated wastewater, stormwater harvesting, or staged rehabilitation requiring less water must be prioritised over surface or groundwater.
The Minister must undertake a complete analysis of all alternative options to external catchment water filling the mine sites including:
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Treatment of the Latrobe Valley outfall sewage to high quality Class A water for return pumping to mine pit sites
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RO (Reverse Osmosis) treatment of ETP (Effluent Treatment Plant) water and transfer to the mine pits via pumping.
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Provision of treated water from the Wonthaggi Desalination Plant and pumping transfer to the mine voids.
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Partial fill of the mine pit potentially avoiding contaminated outflow into the Latrobe River, including the +16 m and +29 m reference levels identified in the Mine Land Rehabilitation Authority’s 2022 investigation
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Using solid fill must be investigated and results made available to the public.
Connecting the pit lake to Morwell River adds risk and solves nothing
Connecting the pit lake to the Morwell river brings serious risks to the river and its wildlife, and requires ongoing management, without offering any compelling benefits.
If partial filling with water is deemed necessary, it should not be the potable water from the Morwell River, which is one of the last unregulated rivers feeding the Latrobe system and is a precious resource.
All 3 mines must be addressed as one single water demand
In Engie’s EES, long-term maintenance remains uncosted beyond ten years. Without clear, measurable targets and named responsibility, there’s no way to tell when the job is done, or to hold anyone to it.
Engie’s proposed pit lake option (including cumulative impacts with all 3 mines being flooded) will affect water security and expose the Gippsland region to increased water contamination and loss of flows for the Gippsland Lakes. Hazelwood is the only Latrobe Valley mine that would take river water with no cap, no drought rules and no end date. This is a terrible precedent. The 3 mines should not be addressed on a project-by- project basis.
Summary
GEG still does not support any additional fresh water being extracted from the Latrobe River and diverted from the Gippsland Lakes to fill massive toxic mine voids. The Ramsar listed Gippsland Lakes are already seriously in trouble.
“Rehabilitation” water should not come from already overstressed water systems. This is a moral hazard. It would be transferring one environmental crisis to another.
Engie has not set out a realistic or even believable vision for rehabilitation. Engie’s EES contains few references to leading practice and science on the analysis and management of pit lakes, including water balance, quality, stratification and mixing, and resulting interpretation and management recommendations.
The community does not have to accept a second-rate proposal for a massive, contaminated unusable lake that severely compromises the already suffering Latrobe river and the Ramsar listed Gippsland Lakes system downstream.
“The Latrobe Valley powered Victoria. Now its mines need a responsible clean-up. Hazelwood’s proposed pit lake would use huge amounts of water and last centuries. It could set the standard for Yallourn and Loy Yang. Our rivers already need more water, not less.” https://gunaikurnai.org/healing-wurruk-after-coal/
Gippsland Environment Group Inc
02 November 2026
Photo: ABC NEWS Robert French
