Make a public comment about BHP Mitsubishi Alliance's Saraji East coal mine
Australia’s environment ministers have failed to properly assess the climate impacts of new coal and gas projects – until now. Have your say about the devastating impacts of BHP Mitsubishi Alliance’s Saraji East coal mine for our climate and thousands of matters of national environmental significance by 24 November.
A step-by-step guide to making your comment
We suggest you draft your public comment on your computer in a Word document, then copy it onto the government webpage.
You can re-use your comment for all 18 projects currently being reassessed because the legal argument and information ECoCeQ has presented to Minister is the same for each one.
You can write as much – or as little – as you like. You don’t need to be a lawyer or scientist to write a comment. You can write a just few sentences, or a few hundred words, or attach a lengthy submission.
Step 1: Substantial new information
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:
- wasn’t available during the project’s first assessment, and
- 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.
Step 2: Substantial change in circumstances
This question asks:
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 project 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.
Step 3: Provide any other comments
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 Saraji East coal mine 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 Saraji East coal 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.
Finalise and submit
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.
More on BHP Mitsubishi Alliance's Saraji East coal mine plans
BHP Mitsubishi Alliance (BMA) proposes to develop and operate an underground coal mine to dig up to an additional 210 million tonnes of coal, fuelling over half a billion tonnes of carbon emissions.
The location: 167 kilometres south-west of Mackay, in the Bowen Basin, Queensland.
The company: The Saraji coal mine is owned by BMA, the 50:50 joint venture between BHP and Mitsubishi Development. In addition to Saraji East, BMA has an additional 6 mines located in Central Queensland’s Bowen Basin and is Australia’s largest exporter of metallurgical coal.
Their proposal: To develop and operate an underground coal mine, a Coal Handling and Preparation Plant and associated Mine Industrial Area. The proposal will involve the extraction of up to 7 million tonnes per annum (Mtpa) of metallurgical product coal for the export market over a life of 25 to 30 years.
The legal challenge: Environmental Justice Australia lawyers, on behalf of their client Environment Centre of Central Queensland (ECoCeQ), submitted a reconsideration request to Tanya Plibersek, asking her to reconsider the first stage of the assessment of the Saraji East coal mine proposal. Read more about this legal intervention.
What’s happening now: The Minister must consider significant new information and account for the detrimental effect of climate change on several thousand matters of environmental significance.
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Environmental Justice Australia is ECoCeQ’s legal team.
We’re a public interest legal organisation – and we’re passionate about empowering people to participate in environmental decision making.
We believe together, we can create a world that works for all of us (and not just some of us).