Make a public comment about Whitehaven Coal's Narrabri coal mine expansion

The first question will ask a yes or no question, with space beneath for you to share your thoughts. The question is: 

Do you consider there is substantial new information available about the impacts the action has, will have or is likely to have on a matter protected under Part 3* of the Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act)? 

Under our Federal environmental laws, the material ECoCeQ has lodged with the Minister must meet the threshold of “substantial new information”. This basically just means that the information: 

1. wasn’t available during the project’s first assessment, and 

1. is real and not trivial, and a form of factual evidence. 

ECoCeQ and their Environmental Justice Australia legal team assert there is substantial new information about the climate harm from this project. See the evidence ECoCeQ provided to the Minister here.

Select Yes if you agree with ECoCeQ. If you’re unsure, you can ignore the Yes/No and move to the comment box below to share your thoughts. 

You could share why you believe this material is substantial – for example, because it outlines the vast and irreversible climate risks to thousands of nationally protected animals, places and plants. 

You can write a sentence or two, or up to 500 words. For example: 

• ECoCeQ’s information shows this project would have a significant impact on nationally protected animals, plants, ecosystems and places (which are “matters of national environmental significance” protected under the EPBC Act). This research includes authoritative reports, for example the 2021 and 2022 IPCC reports, the 2021 State of the Environment Report, as well as many, many documents authored by environmental scientists working for state and federal governments. 
• ECoCeQ’s information includes powerful new research, including fire maps which show the impacts of the climate change-fuelled 2019-2020 bushfire season on endangered animals and plants, and nationally protected areas. This information was not available when the project was first assessed. 
• ECoCeQ’s information about the climate impacts of the project is substantial and new because this information did not exist when the first decision was made or was not before the decision maker when the first decision was made. 

Do you consider there has been a substantial change in circumstances that was not foreseen at the time of the first referral decision and that relates to the impacts the action has, or will have or is likely to have on a matter protected under Part 3* of the EPBC Act? 

ECoCeQ is not relying on this argument for their legal intervention. As explained above, ECoCeQ is arguing that the Minister should reconsider the environmental assessment of the Narrabri expansion based on “substantial new information” and so this question is irrelevant. 

We suggest you mark this question “No” and type “N/A” in the comment. 

This question asks: 

If applicable, provide any other comments on whether you consider there are reasons to revoke the first referral decision and substitute a new decision. This may include any other comments on whether a matter referred to in any of paragraphs 78(1)(a) to (ca) of the EPBC Act applies in relation to the action. 

The most important part of this section is to share your views on whether the Minister should make a new decision about the coal mine. 

This is where you can make the submission unique to you, and share your personal concerns about the living wonders that matter to you. 

You could start with whether you believe the Minister should make a new decision about the mine that takes account of the whole picture of its impact, including from climate harms. 

Then, you could write a few lines about who you are, and why you’re concerned about the climate impacts of this proposal, and the consequences for Australia’s Living Wonders that are special to you – such as the Great Barrier Reef, Commonwealth Marine Areas, threatened animals, plants and ecosystems, marine and migratory species and marine environments and World and National Heritage places. 

If you’re looking for key species and places to highlight, learn more about the impacts on living wonders like the Australian Alpine ecosystems, Great Barrier Reef and koalas. We’ve also highlighted some here. 

You could write about how the ‘substantial new information’ submitted by EcoCeQ demonstrates the Narrabri expansion is having, will have or is likely to have a ‘significant impact’ on our Living Wonders.  

• What does ‘significant impact’ mean? Here, it means the materials show the Narrabri expansion mine had or will have, or is likely to have a significant impact on Matters of National Environmental Significance. An impact does not need to be direct, an impact which occurs later in time or across the country is still an impact.  
• Importantly, ECoCeQ argues the impacts are ‘significant’. According to our federal environmental law, this means an impact that is important or notable.  
• Remember too – an ‘impact’ includes a likely impact. A significant impact is “likely” if it is a real or not remote chance or possibility.  

You might also like to write about the ‘precautionary principle’ which the Minister is required to take into account when assessing fossil fuel projects. The ‘precautionary principle’ means that lack of full scientific certainty should not be used as a reason for postponing steps to prevent degradation of harm to the environment where there are threats of serious or irreversible environmental damage.  

But you don’t have to be an expert – you can also just ask the Minister to look at the 3000 scientific documents provided by ECoCeQ and accept that the only conclusion the evidence leads to is that she should change the original decision, and recognise the likely climate harms of this new coal proposal. 

If you’ve typed your submission into a Word document, don’t forget to copy and paste your answers into the EPBC Portal form. Alternatively, you can save your document as a PDF and upload it at the bottom of the EPBC Portal form.

Tick the Yes/No box to indicate whether your comment is confidential and read the privacy statement and declaration.

Then – the most important step: click “Submit your comment”!

And you’re done!

Thanks so much for registering your concerns about this project – and for speaking up for our climate, our communities and our living wonders.

Can you write another quick comment?

After you’ve done one, the next comments are much easier. You can even copy and paste the submission you’ve just made into the comment section for every other project, as the Minister has to consider them all individually.

How did you go?

Once you’ve finished making your public comment(s), we’d love to know how many you did, which ones, and if you have any feedback on the submission process. This makes it easier to track our impact, and make these processes easier and better for next time.