ALPHA COAL PROJECT & Société Générale Environmental and Social General Guidelines
April 2014 l Les Amis de la Terre1 By Lucie Pinson – Private banks and ECA campaigner2 lucie.pinson@amisdelaterre.org 1
Illustration: Alpha Coal Project - Test Pit – By Hancock Coal
Analysis of the Alpha Coal Project against Société Générale's Environmental and Social general guidelines
The Alpha Coal Project comprises a mine, rail line and port development. The Alpha Coal project mine site would cover 64,769 ha3 hectares of primarily woodland and non-remnant grassland, and would require the clearing of 22,500 ha of woodlands4. The project would also result into construction impacting coastal wetland, and create ongoing industrial noise and coal dust pollution adjacent to areas known to support nesting of migratory and threatened marine turtles, feeding for dugongs and habitat for migratory Humpback whales. The development of the Alpha Coal Project export terminal at Abbot Point would take place in the Great Barrier Reef World Heritage Area, and be facilitated by the dredging of millions of tonnes of cubic metres of seabed, which is planned to be dumped in the World Heritage area, posing threats to coral reefs and other acquatic ecosystems. Société Générale highlights its social and environmental responsibility and asserts its commitment to financing activities that have a positive impact on the needs of the population, environment and economic development. Thus « the bank has set environmental and social general guidelines5 and monitors their implementation in all the projects it supports. These principles are set out in sectorial policies, including those on mining projects (Metals and Mining Sector Policy)6 and those that take into account impacts on biodiversity (Biodiversity Cross-sectorial Policy section)7» 8. These principles as well as cross-sectorial and sectorial policies aim to control the impact of its activities and those of its customers. In an e-mail to Friends of the Earth November 15th, 2013 , Société Générale said that « Société Générale will get involve in the actual launch of the Alpha Coal Project in compliance with these principles and conditions set by the State of Queensland and Australia, especially those aimed at preserving the Great Barrier Reef9 »10 2 3
4
5
6
7
8
9
10
Thanks to Climate and Reef Campaigner – FoE Australia for his great contributions and careful re-reading Draft Environmental Authority Issued EA MIN101017310 [OCCA0045.012.001](13.12), p.44, table 26: « Final land use and rehabilitation approval schedule ». http://www.ehp.qld.gov.au/land/mining/pdf/draft-ea-hancock-coal.pdf Coordinator General's Evaluation Report, p.27, para 5.1.2, http://www.dsdip.qld.gov.au/resources/project/alpha-coal-project/alphareport-summary.pdf Société Générale, Environmental and Social general guidelines, Septembre 2012, http://csr.societegenerale.com/sites/default/files/documents/Document%20RSE/Finance%20responsable/Environmental %20%26%20Social%20General%20Guidelines%20for%20Business%20Engagement_September%202012.pdf Société Générale, Mining and Metals Sector Policy, September 2012, http://csr.societegenerale.com/sites/default/files/documents/Document%20RSE/Finance%20responsable/Mining%20and%20Metals %20Sector%20Policy_September%202012.pdf Société Générale, Biodiversity Cross-Sectorial Policy, September 2012, https://www.societegenerale.com/sites/default/files/documents/Document%20RSE/Finance%20responsable/Biodiversity%20crosssectorial%20Policy_September%202012.pdf Société Générale, Mail to Amis de la Terre, 15th of November 2013, http://www.amisdelaterre.org/IMG/pdf/societegenerale_mail_aux_at_15_11_2013.pdf Both Queensland and Australia governments are determined to support the coal industry in Queensland. The Queensland Government has declared its intentions to minimise environmental assessment to expedite coal project approvals; the Queensland Premier declared in June 2012 that the state is “in the coal business” (http://www.couriermail.com.au/news/queensland/premiercampbell-newman-will-not-halt-port-and-industry-development-on-queenslands-coast-to-protect-great-barrier-reef/story-e6freoof1226381294353), the Queensland Minister for Environment and Heritage Protection declared ecological associations as extremists (http://statements.qld.gov.au/Statement/2014/3/4/greater-certainty-delivered-for-industry-and-landholders) and Queensland Environment Minister has confessed he’s not convinced that human-made greenhouse pollution is driving climate change ( http://www.abc.net.au/worldtoday/content/2012/s3517410.htm). Société Générale, Mail to Amis de la Terre, op.cit.
Finally, as a member of the Equator Principles11, Société Générale commits to meet the performance standards on social and environmental sustainability of the International Finance Corporation (IFC)12.In their overview, it is written that « when host country regulations differ from the levels and measures presented in the EHS Guidelines [IFC's Environmental, Health, and Safety Guidelines], projects are expected to achieve whichever is more stringent ».13 For all the following reasons, Alpha Coal Project is not consistent with Societe Generale principles.
Illustration 1: Schooling fairy basslets, Great Barrier Reef. Credit: Beyond Coal and Gas (Creative Commons)
11 12
13
E quator Principles, http://equator-principles.com/resources/equator_principles_iii.pdf International Financial Corporation, Performance Standards on Environmental and Social Sustainability, http://www.ifc.org/wps/wcm/connect/c8f524004a73daeca09afdf998895a12/IFC_Performance_Standards.pdf?MOD=AJPERES id., p.3
Impacts on water resources and populations Société Générale's Mining and Metals Sector Policy as well as Biodiversity cross-sectorial Policy states that impacts on water resources and "hydrological changes"14 are specifically considered when evaluating clients' activity or transactions: •
Société Générale specifically considered « use of large volumes of water for beneficiation which could reduce the availability and/or quality of water for danwstream users and fisheries »15.
Alpha Coal Project raises major risks in this area:
The mine would sit within the Galilee Basin and the Burdekin River Catchment, which flows into wetlands and the Great Barrier Reef.
Over a 30-year lifespan, the mine would permanently remove 176 billion litres of water the equivalent of 70,400 olympic pools - that would have flowed into the Burdekin River Basin, maintaining environmental flows, ecosystems and farming communitiesf16.
47 km waterways are to be diverted and two natural springs, as well as the Degulla Lagoon will be depleted17.
At the end of the mine's life the remaining «final void», 24km in length18, would permanently intercept a substantial amount, if not a majority, of the region's groundwater. This water would evaporate and its salinity level would increase dramatically19.
Illustration 2: Bee Creek within the Burdekin River catchment. By FoE Australia
14 15 16 17 18 19 20
21
There is concern about dewatering of the land around the mine, as surrounding groundwater may lower by up to 5m for a 20 km radius20. Groundwater is the main water resource for the local population, with some families and agricultural communities totally dependent on it for their water21.The Queensland Land Court has acknowledged that the
Société Générale, Biodiversity Cross-Sectorial Policy, p.2. Société Générale, Mining and Metals Sector Policy, p.1. Dr Webb, Expert Report to the Land court of Queensland, Groundwater, p.19 para.52, http://www.landcourt.qld.gov.au/ GVK Hancock, op.cit., vol. 1, section 1 « Introduction », para. 1.3.2; and Coordinator General Evaluation Report p.3 para.2.2. GVK Hancock, op.cit., vol.2, section 1, « Introduction », p.10, para.1.7.3. Dr Webb, op.cit., p.68, para.24; and p.8, para.23 GVK Hancock, Alpha Coal project EIS, 2010, vol.5, appendix P, « Environmental Management Plan », p.42, para.2, http://gvkhancockcoal.com/publications/24-environmental-impact-statements/99-alpha-coal-project-eis-2010 Dr Webb, op.cit., p.17, para.43
mine would have significant impacts on offsite groundwater and approval of the mine was not in the public interest22.
Illustration 3: Farm shed located on the mining site. By FOE Australia
Société Générale's Biodiversity cross-sectorial Policy also states that: •
« When evaluating clients' activity or transactions with a potential material impact on/dependency to biodiversity, [...] dependency to ecosystem services emerging as a major potential issue for some economic sectors including agribusiness, fisheries, water utilities or tourism” are specifically considered »23.
The Alpha Coal Project raises many risks relating to these aspects:
22
23 24 25 26
The Alpha Coal Project, through its impact to hydrological systems within the Burdekin River Catchment, threatens the Great Barrier Reef World Heritage Area (see below), which provides 60,000 jobs in Queensland24.
The marine tourism industry is the largest commercial activity in the Great Barrier Reef region and a major contributor to the local and Australian economy generating over $5 billion per annum25.
Australia has just come out from a mining boom peak which pushed the Australian dollar to record highs, placing pressure on other export-oriented sectors such as manufacturing,
Fishing communities have already closed due to the long term impact of coal port dredging operations in regions such as Gladstone, also in the Great Barrier Reef World Heritage Area. Similar capital dredging, annual maintenance dredging, and sea spoil dumping is planned at the site of the Alpha Coal Project export port - Terminal 3 project at Abbot Point26.
Land Court of Queensland, files MRA082-13 and EPA083-13, http://www.landcourt.qld.gov.au/documents/decisions/MRA082-13etc-4-12.pdf Société Générale, Biodiversity Cross-Sectorial Policy, op.cit., p.2. Queensland Government, Minister Media Statement: http://statements.qld.gov.au/Statement/Id/78896 id. Envoyé spécial, « Menace sur la Grande Barrière de corail », broacast reportage, 29/08/2013, http://www.france2.fr/emissions/envoye-special/menace-sur-la-grande-barriere-de-corail_122256
Habitat, critical habitat and biodiversity impacts of the Alpha Coal project Both the Biodiversity Cross-sectorial Policy and Mining and Metal Sector Policy state that « impacts on critical habitats, and areas protected for biodiversity or cultural considerations »27 are specifically considered when evaluating the clients' activity or transactions.
Biodiversity cross-sectorial policy specifies which aspects related to habitats are concerned by specific consideration: •
« Habitat loss28 through destruction or conversion (eg by activities entailing significant conversion of land use, projects sited in or close to areas identifies as important for biodiversity, or developments in remote or pristine locations)
•
Habitat degradation and fragmentation »29
Illustration 4: Bimblebox Natural Reserve. Credit: lockthegate (Creative Commons)
The Alpha Coal Project raises many risks relating to these aspects:
27 28
29 30 31 32 33 34
35
The mine site is located roughly 10km from the Bimblebox Natural Refuge, a site listed within the State of Queensland and Australian legislation as a Protected Area, and is home to over 160 vertebrate fauna species: 94 birds including 24 migratory species, 36 mammals, 27 reptiles and 10 amphibiens30
The Alpha Coal Project mine site would require the clearing of 22,500 ha of woodland likely to provide habitat for the nationally listed as endangered Black-throated Finch31 - which is also on the UICN Red List32 - along with a range of other protected and threatened species - Star Finch, the vulnerable Red Goshawk, Southern Squatter Pigeon, Australian Painted Snipe, Greater Long-eared Bat33.
The rail line to the Abbot Point export terminal would end at the nationally listed ''Important Wetlands in Australia''34 Caley Valley Wetlands which is one of the largest inatct wetland systems of Central Queensland connected to the waters of the Great Barrier Reef World Heritage Area in Curlewis Bay35. Migratory and threatened marine species such as Humpback whale, dugong and Green turtle are known to uses these waters for resting, feeding and mating, respectively.
Société Générale, Mining and Metals Sector Policy, op.cit., p.1. Société Générale biodiversity cross-sectorial policy defines an « habitat » as « an ecological area that is inhabited by a particular species. When a habitat is destroyed or degraded, the organisms which previously used the site are deisplaced or disappear, reducing biodiversity ». Société Générale, Biodiversity Cross-Sectorial Policy, op.cit., p. 2. id., p.2. GVK Hancock, op.cit., vol.5, appendix E1, « Flora and Fauna Assessment ». Australian Government, http://www.environment.gov.au/cgi-bin/sprat/public/publicspecies.pl?taxon_id=64447 International Union for Conservation of Nature website, IUCN Red list of threatened species, http://www.iucnredlist.org/search GVK Hancock, op.cit., vol.5, appendix E1, « Flora and Fauna Assessment ». Directory of Important Wetlands in Australia (DIWA) , http://www.environment.gov.au/topics/water/water-ourenvironment/wetlands/australian-wetlands-database/directory-important ; and http://wetlandinfo.ehp.qld.gov.au/wetlands/ecology/statistics/wetland-extent/diwa-wetland.html Information about the ecological values of the wetlands and waters around Abbot Point is summarised in the Alpha Coal Project EPBC Act Report June 2012.
Illustration 5: Whale tail. Credit: Beyond coal and Gas. (Creative Commons)
Paragraphs 16-18 of Performance Standard 6 deals with critical habitat. Reviewing these standards against the Alpha Coal Project reveals that the Alpha Coal Project would lead to the permanent loss of alteration of more than one area fitting the Equator Principles' definition of critical habitat. •
Paragraph 17 stipulates that the client will not implement any project activities in critical habitat unless he/she has demonstrated that « the project does not lead to measurable adverse impacts on those biodiversity values for which the critical habitat was designated, and on the ecological processes supporting those biodiversity values; the project does not lead to a net reduction in the global and/or national/regional population36 of any Critically Endangered or Endangered species over a reasonable period of time »37
This would not be the case of Alpha Coal Project:
36
37 38 39 40
The Alpha Coal Project mine site would require the clearing of roughly 22,500ha of woodland likely to provide for the nationally listed endangered Black-throated Finch38, along with a range of other protected and threatened species.
The Black Throated Finch is an endangered species listed in the International Union for Conservation of Nature Red list of threatened species39 and under both the Australian Government Environment Protection and Biodiversity Conservation Act 1999, and the Queensland Nature Conservation Act 1992.
In one of its comments40 on the assessment, the Australian Government Department of Sustainability, Environment, Water, Population and Communities (SEWPAC) stated that «if present, any population of Black-throated Finch would be considered important. While further discussion does relate to potential impacts to habitat for this species, it should be noted that if the species is found or believed to be present, the estimated 7,154 hectares of largely contiguous habitat on the proposed mine site would almost certainly be considered «habitat critical to the survival of a species ».
« The scale of the potential net reduction is determined based on the species's listing on either the (global) IUCN Red List and /or on regional/national lists. For species listed on both the (global) IUCN Red List and the national/regional lists, the net reduction will be based on the national/regional population ». International Financial Corporation, Performance Standards on Environmental and Social Sustainability, p.44. id., pp.43-44. Australian Government, http://www.environment.gov.au/cgi-bin/sprat/public/publicspecies.pl?taxon_id=64447 International Union for Conservation of Nature website, op.cit. The document from which these comments are drawn is not publicly available. It was obtained by Greenpeace in the course of our research. We can provide a copy of this document if needed.
Illustration 6: Black-throated finch. Credit: Seabamirum (Creative Commons)
The proponent of the mine (GVK Hancock) fauna and flora assessment has been challenged in the Land Court of Queensland. The two parties challenged the quality of the assessment, providing expert evidence regarding protected and threatened species, including the back-thraoted finch. The judge was concerned that much of the flora and flauna assessment was based on ground water modelling and assumptions by the company - which he did not agree with. But while he was in a difficult decision to know what to do about the impact on flora and flauna, he decided in favor of the proposed use of biodiversity offsets « subject to his reservations as to the evidence relating to groundwater and the resulting impact of the evidence on ecology »41, a decision not supported by two independent experts.
Société Générale also states in its Biodiversity Cross-sectorial Policy : project assessment is to be guided by several initiatives when assessing its clients' approach to managing their impacts on biodiversity, including the International Union for Conservation of Nature (IUCN) Red List of Threatened Species that « identifies and documents those species most in need of conservation attention »42.
Illustration 7: Red Goshawk. Credit: Aviceda (Creative Commons)
41
42 43
The project would require the clearing of thousands of hectares of high value land critcial for some threatened birds species listed on the Red List of the IUCN as being near threatened – as the Red Goshawk – or even as endangered species – as the Australian Painted Snipe.43
Land Court of Queensland, files MRA082-13 and EPA083-13, http://www.landcourt.qld.gov.au/documents/decisions/MRA082-13etc-4-12.pdf Société Générale, Biodiversity Cross-Sectorial Policy, September 2012, p. 2. International Union for Conservation of Nature, op.cit.
Impacts on wetlands and migratory species Paragraph 16 of the Performance Standards states that a «habitat supporting globally significant concentrations of migratory species and/or congregatory species»44 constitutes a critical habitat. Wetlands support migratory species45. Société Générale states to be guided by several international conventions when assessing its clients' approach to managing their impacts on biodiversity, including the Convention on Wetlands of International Importance (Ramsar Convention, 1971) and the Convention on the Conservation of Migratory Species of Wild Animals (CMS or Bonn Convention, 1979). The Alpha Coal Project raises many risks for migratory species:
The rail loop for the Alpha Coal Project at Abbot Point would enclose 99ha of the Caley Valley Wetlands (CVW), and will clear a further 16ha of this wetland, which is described a « wetland of high ecological significance in a Great Barrier Reef catchment » on the national Directory of Important Wetlands46.
CVW provides habitat for migratory shorebirds that are protected under the Japan–Australia Migratory Bird Agreement (JAMBA) and China–Australia Migratory Bird Agreement (CAMBA) international migratory bird agreements47.
Curlewis Bay is within the Great Barrier Reef World Heritage Area (GBRWHA)48 and provides habitat for migratory and threatened marine species such as the Humpback whale, dugong and Green turtle known to use these waters for resting, feeding and mating. Such sites are described as « habitat of important (and potentially critical) to the survival of humpback whales » in the Federal Government's Humpback Whale Recovery Plan 20052010.49
Illustration 8: Green turtle. Credit: Trodel (Creative Commons)
44 45
International Financial Corporation, op.cit., p. 43. Convention on the Conservation of Migratory Species of Wild Animals website, http://www.cms.int/
46
Australian Government. 2001. A Directory of Important Wetlands in Australia. Third Edition. Chapter 8: Queensland, http://www.environment.gov.au/water/publications/environmental/wetlands/pubs/directory-ch8.pdf
47
http://www.environment.gov.au/node/14280 United Nations Educational, Scientific and Cultural Organization website; listing and map, http://whc.unesco.org/download.cfm? id_document=119876 Department of Environment and Heritage (Cth), Humpback Whale Recovery Plan 2005-2010. http://www.environment.gov.au/biodiversity/threatened/publications/recovery/manovaeangliae/pubs/m-novaeabgliae.pdf; Nota: this federal department does not longer exist.
48
49
Mpreover, migratory species on the site would be directly impacted by the destruction or altération of their habitat and would also be threatened by the impacts from climate change, including storm serge and sea level rise caused by the exploitation and combustion of the mined product coal. •
The Bonn convention states that «being biologically dependant on more than one habitat, migratory species are among the worst affected by climate change».50.
Alpha Coal Project would deepen the climate crisis.
Over the 30-year lifespan of the project, the burning of coal from the Alpha Coal Project would result in 1.804 billion tonnes of CO2 emissions (roughly 60 million tonnes of CO2 emissions annually).
The annual carbon emissions from the burnt coal mined at the Alpha Coal Project would be equivalent to 10.91% of Australia's annual emissions.
The annual emissions would be greater than the total annual emissions of each of the following nations in 2010: Finland, Portugal, Hungary, Denmark, Hong Kong, Singapore, Switzerland, Sweden, Ireland and Norway51.
Operation of the mine would produce up to 11,036,093 tonnes CO2 equivalent52, with an additional 17,582,321 tonnes CO2 equivalent to be produced by the rail link to Abbot Point53.
Both Société Générale Mines and Metals Sector Policy and Biodiversity Cross-sectorial Policy state that climate change impacts are taken into account when evaluating clients' activity or transactions. •
Société Générale specifically considered «climate change impacts of methane emissions from deep mines and of the burning of coal for power generation»54.
•
Société Générale specifically considered «all types of pollution of the ecosystems (including impacts on climate change) »55
The Great Barrier Reef would also be impacted by climate changes reinforced by the Alpha Coal project.
50 51
52 53 54 55
Convention on the Conservation of Migratory Species of Wild Animals website, op.cit. USA Energy Information Administration website, Total Carbon Dioxide Emissions from the Consumption of Energy (Million MetricTons), http://www.eia.gov/cfapps/ipdbproject/iedindex3.cfm? tid=90&pid=44&aid=8&cid=all,&syid=2011&eyid=2011&unit=MMTCD GVK Hancock, op.cit., vol.2, section 14, « GHG & Climate Change ». ib. Société Générale, Mining and Metals Sector Policy, op.cit., pp.1-2. Société Générale, Biodiversity Cross-Sectorial Policy, op.cit., p.2.
Impacts on the Great Barrier Reef World Heritage Area Société Générale Biodiversity Cross-sectorial Policy states that: •
«When evaluating clients' activity or transactions with a potential material impact on/dependency to biodiversity [...] impacts on specific values attached by local communities to biodiversity and ecosystem services»56 are specifically considered.
The environmental value, and notably cultural significance of the site, listed by UNESCO World Heritage Committee, where 1.8 million people go every year57, and is said to be «a globally outstanding and significant entity»58 is widely recognised.
Illustration 9: Coral and fish, Great Barrier Reef. Credit: Beyond Coal and Gas (Creative commons)
In its Biodiversity Cross-sectorial Policy, Société Générale also states to be guided by the UNESCO Convention concerning the Protection of the World Cultural and Natural Heritage (1972) when evaluating clients' activity or transactions. The Alpha Coal Project would contribute to factors that seriously threaten the Great Barrier Reef UNESCO World Heritage site.
56 57
58 59
60
Coral is extremely sensitive to even short periods of increased sea temperatures, resulting in coral bleaching.59
Ocean acidification, a result of oceans absorbing increasing amounts of carbon dioxide that humans are releasing into the atmosphere, is reducing the ability of corals to produce skeletons and transforming the Reef into a seaweed bed60.
id.p.2. Luc Vacher, « La construction de l’espace touristique de la Grande Barrière de Corail : entre protection de l’environnement et modifications de l’accessibilité au récif », in Études caribéennes, avril-août 2008, http://etudescaribeennes.revues.org/1152#tocto1n1 United Nations Educational, Scientific and Cultural Organization website, http://whc.unesco.org/fr/list/154 Lough, J. 2007, « Climate and climate change on the Great Barrier Reef », in Climate change and the Great Barrier Reef: avulnerability assessment. Eds J.E. Johnson & P.A. Marshall, Great Barrier Reef Marine Park Authority and Australian Greenhouse Office, Townsville, Australia, pp.15-50. Great Barrier Reef Marine Park Authority. 2009. Great Barrier Reef Outlook Report 2009, Great Barrier Reef Marine Park Authority, ISBN 978 1 876945 89 3 (pbk.), http://www.gbrmpa.gov.au/__data/assets/pdf_file/0018/3843/OutlookReport_Full.pdf
The Abbot Point Terminal 3, a 60 million tonne per year coal export terminal, developed for the Alpha Coal Project, would result in an additional 508 coal ships passing through the Great Barrier Reef each year61.
The Abbot Port expansion would dredge sand and silt in Great Barrier Reef waters, and thus also lead to runoff pollution and a blom of crown-of-thorns starfish that is choking out other species62.
It is important to note, the proposed coal export terminal development of Abbot Point and Caley Valley Wetland is now under review with two legal challengers in the Australian Government Federal Court; it is expected the determination may be finalised within 12 to 18 months63.
Following several other warnings from international scientific and public institutions, The UNESCO World Heritage Committee (WHC) warned in January 2014 that the Great Barrier Reef could be inscribed on the List of World Heritage in Danger by June 2014 without urgent management improvements, including restrictions on new port developments64
Illustration 10: Satellite Image of the Great Barrier Reef. Credit: Nasa (Creative Commons)
61
62
63
64
Hancock Coal Infrastructure Pty Ltd 2011 Abbot Point Coal, Terminal 3 Referral Reference 2008/4468 Section 156A , request to vary a proposal to take an action, letter dated 15 July 2011, appendix A, http://www.environment.gov.au/epbc/notices/assessments/2008/4468/2008-4468-variation2-request.pdf Brian Handwerk, Australia to Dump Dredged Sand in Great Barrier Reef Waters, Adding to Site's Mounting Woes, National Geographic, 2014/01/14, http://news.nationalgeographic.com/news/2014/01/140131-great-barrier-reef-dredge-unesco-science-coalaustralia/ Kathleen Calderwood, Legal challenge to Abbot Point dredging project, Rural, 2014/03/24, http://www.abc.net.au/news/2014-0324/nrn-abbot-point/5341642 Brian Handwerk, id.