Gippsland Environment Group Inc

​​Four Sydney Harbours Worth of Water

The proposals to divert up to 2,800 gigalitres (GL) of water from the Latrobe River system to fill the three Yallourn mine voids, (equivalent to more than four Sydney Harbours), would further reduce flows into the internationally recognised Gippsland Lakes Ramsar Site. RAMSAR wetlands carry both irreplaceable ecological functions and legal obligations which must be adhered to by Federal and State governments. Flow decisions must uphold these obligations.

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The Victorian Government Must Uphold Its Water Promises

Gunaikurnai peoples ‘connection to water runs deep. It shapes our culture, identity, and how we care for Country.’ The Victorian government has committed to returning water to Traditional Owners through the Water is Life Roadmap. The Victorian government must respect those commitments.

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The True Costs of Filling Toxic Mine Voids with Fresh River Water

If the Victorian government is proposing to use economic mechanisms (pricing fresh water), the Minister must explain:​

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• What is the value of the Gippsland Lakes to the state of Victoria?

• What is the real cost of filling these massive, unstable, toxic mine voids with fresh river water and precious groundwater?

• What are the volumes to be taken from environmental and Cultural flows?

• How is the state government intending on selling the advantages of this proposal as against the losses to the environment, First Nations water rights and to other local communities – farmers, fishers, tourism operators etc?

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Premature Consultation Undermines Environmental Integrity

Pre-emptively asking for public opinion on the price of fresh river water to fill the mine voids before environmental assessments (EES, EPBC Water Trigger, LVRRS) are complete, is simply unacceptable, and risks normalising this ominous and irresponsible idea. Considering licensing vast amounts of freshwater allocations to mining companies, without understanding (or recognising) the environmental consequences is clearly wrong.​

Increased water extraction risks serious harm ​

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:​

• Ongoing declines in fish, frog, turtle, and waterbird populations

• Degradation of wetland vegetation and aquatic habitat

• Increased salinity that disrupts wetland productivity and ecological balance

 

Latrobe Valley Regional Water Study –Ecological Effects Assessment: Authors - Paul Boone & Jen Hale, November 2020

 

The key conclusions of the Ecological Effects Assessment are that:

• If water from the Latrobe River system continues to be taken and used at current rates, under a drier future climate this would lead to a decline in the environmental values of the Latrobe system and a loss of biodiversity.

• These declines would be exacerbated if there was an increase in the amount of water extracted from the system.

• Decreases in water availability in the Latrobe River system from increased extraction and/or reduction in return flows from power stations would lead to the emergence of multiple and interconnected threats, resulting in loss of the environmental, Aboriginal cultural and social values of the Latrobe River, its estuary and the Ramsar-listed Gippsland Lakes.” (DEWLP Cover Note)

 

Minister’s Obligation to ensure sustainablilty

Under Section 40 of the Water Act 1989, the Minister must consider environmental impacts and ensure sustainability. The precautionary principle should apply – no water should be allocated unless environmental and Cultural flow deficits are met first.

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Fresh river water is cheap or free for mining companies

Gippsland Environment Group is extremely concerned that recycled and manufactured water sources and other rehabilitation options appear to have been summarily ruled out by mining companies and the Victorian government. This appears to be simply because fresh river water is artificially cheap (or free) – for mining companies. The comparatively low price of $200-$260 proposed by the Minister in this consultation seems to be guided by what mining companies might be willing to pay – and brazenly doesn’t account for the actual costs!

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“…in the absence of specific and relevant data, the opportunity cost of water for Traditional Owners and the environment has not influenced the indicative price range discussed above.” See: Expert report - Surface water for Latrobe Valley Mine Rehabilitation P5​

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Minister Must Assess All Alternatives to Diverting Rivers

The Minister must undertake a complete analysis of all alternative options to diverting rivers into the massive mine pits, including:

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• Treatment of the Latrobe Valley outfall sewage, post treatment at Dutson Downs to high quality Class A water for return pumping to mine pit sites

• RO (Reverse Osmosis) treatment of ETP (Effluent Treatment Plant) water and transfer to the mine pits via pumping

• Provision of treated water from the Wonthaggi Desalination Plant and pumping transfer to the mine voids.

• Removing toxic coal ash dump and using solid fill (as well as recycled, waste or manufactured water).

• Current academic and scientific research must be considered in any future proposals – or decision making.

 

GEG Will Not Be Co-Opted by a Flawed Consultation Process

Gippsland Environment Group is a respected environment group renowned for scrupulousness in all its dealings. We are not prepared to be co-opted by this consultation process, by discussing a price on fresh river water.  

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Public Concerns Ignored, Water Pricing Fast-Tracked

We have read the Minister’s What We Heard report, and the corresponding submissions. Pricing of fresh water for mining companies was clearly not the primary concern of the majority of respondents.

 

Yet the Minister ignored the multitude of serious environmental concerns, submitted in good faith, and stated “This consultation is in respect of a specific matter raised in submissions – being the economic value of the water entitlement sought by AGL…” (para 10). This follow up consultation was narrowly framed as “Surface Water Pricing for Mine Rehabilitation in the Latrobe Valley” (until the name changed the day before the original deadline, 22 July 2025).

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Gippsland Environment Group does not support any misleading attempts to frame the bulk use of fresh river water to fill mine voids as a fait accompli, by government or by mining companies. Alternatives must be found.

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Real Rehab, Not River Theft — Don’t Solve One Disaster by Creating Another

Mining companies who have polluted and profited for so long, must now achieve genuine and safe rehabilitation – and they must pay for it. The cheap option (flood with river water and hope) is the highest environmental and social risk. Mining companies cannot be allowed to put the Latrobe River system, the Gippsland Lakes and the communities who depend on them in worse peril.