The Business Council of Australia has responded to the Department of Sustainability, Environment, Water, Population and Communities (SEWPAC) in relation to the draft Significant Impact Guidelines: Coal Seam Gas and Large Coal Mining Development – Impacts on Water Resources.

The BCA remains deeply concerned by the amendments to the Environment Protection and Biodiversity Conservation Act to make water resources a matter of national environmental significance, in relation to coal seam gas and large coal mining developments. This was done in the absence of proper process, including:

• without a Regulatory Impact Statement to assess the costs and benefits of the changes (including any identified environmental benefit)
  
  
• without genuine stakeholder consultation
  
• with a lack of recognition for the unnecessary duplication of existing state responsibilities regarding water resources
  
  
• with little regard for the uncertainty, delays and costs the changes are likely to cause for affected projects.

With respect to the guidelines themselves, the BCA is concerned:

• that as currently drafted, the guidelines are likely to result in all actions being referred creating a process that will add significant burden, delays and cost to a proponents operations for no commensurate environmental benefit
  
  
• the risk of retrospective application of the ‘water trigger’ to projects that have already been approved
  
  
• the need for better criteria, including thresholds and magnitude of change, which recognise natural variability of water resources
  
  
• the lack of recognition of state authorities existing work with respect to regional groundwater models, conditions of approval, and data already obtained in respect of currently approved projects
  
  
• that the difference between exploration activities and development activities needs to be more clearly defined to recognise the relatively lower impact of exploration activities
  
  
• that the advice of the Independent Expert Scientific Committee be called on only once during the process to avoid undue delays to the process.

Submission to SEWPAC on Draft Significant Impact Guidelines CSG and Large Coal Mining Developments