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ns about the responsibility of the ocg to communicate the actual functions it performs under the sdpwo act i highlighted that the water technology wt report produced under instruction by the ocg was of particular concern i would ask that you be mindful of the project names for projects for which the ocg is responsible for coordinating under the sdpwo act i would ask that you consider how the ocg may have framed their instructions to water technology for their investigation and the impact those instructions may have had on the naming and identification of relevant proponents under the sdpwo act on may 27 i received correspondence from the assistant coordinator general in response to some of my unanswered questions they were able to confirm that i had my facts right about the relevant proponents and provided me with links to code of conduct documents i was also provided with a perplexing explanation for the erroneous and misleading title of the wt report the report was prepared in response to a review of parts of both the north galilee basin rail project and the carmichael coal mine and rail project the title of the report reflects the name of the joint proponents the reason this explanation perplexes me is that the title of the report contains the name of the mine proponent not the rail proponent the assistant cg does not even attend to that issue in their response bravus and crn are joint proponents for the ccmr crn were enjoined as a proponent to deliver the rail component of the mine project which connects with the ngbr to make things absolutely clear in regard to the ocg s published statements regarding bravus and crn as joint proponents here is a quote from the ccmr project overview page that is published under the direction of the ocg proponent adani mining pty ltd and carmichael rail network pty ltd joint proponents both wholly owned subsidiaries of adani australia part of the adani group https www statedevelopment qld gov au coordinator general assessments and approvals coordinated projects completed projects carmichael coal mine and rail project bravus and crn are not joint proponents of the carmichael rail network crn are the sole proponent for the ngbr and joint proponent of the ccmr for the purposes of rail here is a succinct description from a reliable source a supreme court of queensland document from proceedings brought against ben pennings co founder of galilee blockade carmichael rail network pty ltd carmichael rail is the proponent and developer of a railway approximately 200 kilometres long which would connect the mine with the existing rail network in central queensland https archive sclqld org au qjudgment 2020 qsc20 275 pdf the water technology investigation it needs to be understood that the wt investigation was primarily concerned with the allegations of environmental breaches along the ngbr corridor made by the mackay conservation group who also urged that other similar sites be investigated wt have investigated the sites identified by the mackay conservation group and other sites identified in the desktop review https drive google com file d 1m_o9mmityexb7brkzopd1b0 _ekzgw2u view the mackay conservation group put out a media release on may 19 you can follow the links to all the important documents from here https www mackayconservationgroup org au calls_to_strengthen_environmental_protection_adani in the wt report the responsibility for adherence to environmental conditions imposed by the ocg was repeatedly attributed to bravus the introductory paragraph of the report titled erosion and sediment management investigation carmichael rail network bravus mining and resources asserts that the ocg engaged wt to investigate alleged breaches by bravus water technology wt were engaged by the office of the coordinator general ocg to investigate alleged breaches of legal obligations by bravus at three locations on the carmichael rail network corridor to determine if a breach of conditions had occurred this report details the nature of the alleged breaches and the results of our investigation https drive google com file d 1m_o9mmityexb7brkzopd1b0 _ekzgw2u view the mcg identified 3 locations within the ngbr corridor therefore it is clear that the desktop review added the other locations this would suggest that all or some of the locations identified in the desktop review were located on the ccmr separable portion 1 sp1 of the combined rail corridor but the chainages listed that identify the additional locations for on site inspections are found along the ngbr corridor the site observations were completed on the 23rd and 24th march 2021 and included the three locations identified for investigation by mcg and also two additional pre selected locations by wt and one further location identified during the visit additional casual observations of the site works outside of the six specific locations were made during the course of the two day site observations https drive google com file d 1m_o9mmityexb7brkzopd1b0 _ekzgw2u view it is likely that the scope of the investigation was widened to include locations along sp1 through the desktop review process the green section in the map below which was supplied by wt in their report is the sp1 section of the ccmr as you can see no inspections by the wt team ocg staff adani staff or contractors contractors were made outside of the blue and purple sections which represent the ngbr corridor it s important to note that the mcg incident report titled environmental pollution incident report adani carmichael coal mine and rail project february 2021 does not identify the proponent for the north galilee basin rail project it identifies the wrong project name in the report title and uses the old name for adani s mine proponent in the text indeed the document is so inaccurate that while preparing for my previous blog post i mistook it for a document relating to alleged breaches from 2019 the opening line in the mcg incident report wrongly identifies the project name this report by mackay conservation group mcg aims to inform a formal complaint about erosion and sediment controls failing at the site of the adani carmichael coal mine and rail project in central queensland during december 2020 https d3n8a8pro7vhmx cloudfront net dudgeonpointorg pages 2311 attachments original 1613606970 environmental_pollution_incident_report_ january_2021_ _adani_ 28final 29 pdf 1613606970 this paragraph suggests that the author is not aware that the contiguous rail corridor known since mid 2018 as carmichael rail network is a combination of the ngbr corridor and separable portion 1 of the carmichael mine rail corridor after it was shortened by approximately 110 km some time in 2015 16 these locations are in the whitsunday regional council area but sediment and erosion control management failings may have occurred across the whole of the adani carmichael coal and rail project other similar sites should be investigated including parts of the project in the isaac regional council area https d3n8a8pro7vhmx cloudfront net dudgeonpointorg pages 2311 attachments original 1613606970 environmental_pollution_incident_report_ january_2021_ _adani_ 28final 29 pdf 1613606970 the wt report contains a summary of the mackay conservation group incident report as i mentioned the mcg report wrongly identifies the relevant proponent but instead of substituting the actual proponent for the ngbr crn with the incorrectly alleged proponent adani mining the wt authors substituted the new name for the incorrectly reported proponent bravus it s hard to imagine how the ocg s instructions and briefings lead to that substitution decision but it had the effect of the wt report text not contradicting the media statements made by ocg spokespeople under the principle that crn is a bravus entity here s an exemplar of the inaccurate substitutions that wt authors may have been instructed caused to make by the ocg prosecute of bravus for breaching their legal obligations in this case https drive google com file d 1m_o9mmityexb7brkzopd1b0 _ekzgw2u view it s utterly clear to me that the intent of the mcg incident report and the accompanying letter from the eja lawyer was that the queensland government through it s relevant departments conduct an investigation and make enforceable decisions under the relevant legislation to compel the relevant legal entities responsible for projects coordinated under the sdpwo act to take the necessary measures to comply with existing or newly created environmental conditions in light of that clear intent would it not be in the interests of accountability and transparency that investigators are instructed to communicate the correct proponent even when the original incident report was in error the wt summary of the mcg incident report contained incorrect assertions of the responsibility of bravus for alleged breaches contrast that against the summary of the eja letter to meaghan scanlon carmichael rail network pty ltd is specified as the ngbr proponent the eja letter but this is not mentioned in the summary the eja summary also includes reference to the riverine protection permit exemption approved entity number assigned to carmichael rail network pty ltd in 2017 but without mentioning their name the only reference to the actual proponent responsible for the allegations that prompted the investigation was made in the wt authors response section we note that the carmichael rail network pty ltd were added as approved entity for the purposes of the exemption requirements for a riverine protection permit version 1 03 on the 19th of september 2017 https drive google com file d 1m_o9mmityexb7brkzopd1b0 _ekzgw2u view the wt report authors made one reference to the body responsible for adani s rail corridor under coordination by the ocg while making dozens of references to the mine proponent bravus in a report about breaches on a project for which the mine proponent are not responsible under the law something seems to be very wrong some analysis it looks to me that the ocg have consistently made every effort taken the necessary steps to keep the name of the adani rail proponent out of the frame to the extent that they are capable of causing the name to be published i ve been provided 2 perplexing statements for why the rail proponent name didn t appear where statements and investigations regarding alleged environmental breaches related to the projects for which crn are responsible under the sdpwo act a clue to the ocg s consistency could lie in the phrase crn is a bravus entity it may be that the cg has nominated bravus as the entity responsible for particular imposed environmental conditions under section 54 of the sdpwo act i would direct the reader to section 54a application of div 8 if section 54a can be satisfied and section 54b 3 is applied then section 54v jurisdiction for conditions may allow the coordinator general to nominate an entity that is to have jurisdiction for the condition s my investigations thus far have revealed that carmichael rail network pty ltd acquired significant queensland government approvals and accreditations prior to the ocg changing the listed adani proponent for the ngbr and rail component of the ccmr in june 2018 crn made the aecom contract changed ultimate holding companies and were mentioned in the north galilee water scheme application documents as the adani proponent for rail all while the naif controversy raged my working theory is that the coordinator general permitted adani to install a new proponent without generating a public notice of any kind i have checked my interpretation of the sdpwo act with a staffer at the ocg and it is highly likely that with a single email to adani mining pty ltd the cg was able to facilitate change request 1 under sections 27ae and 35g of the sdpwo act to put it in plain language under the act if the cg decides that a request for a project change is unproblematic they need not add anything to the public record with a single email the cg was able to give adani mining pty ltd unlimited time operating with an unannounced proponent before causing information confirming a change of proponent to appear the working theory that i outlined in the last 2 paragraphs is based not only on research and right to information disclosures but also on a conversation i had with senior project managers within the ocg in september 2018 upon my discovering the change of listed proponent i received a conference call from karen oakley and heather lopez both project managers from the ocg they asked me about my blog and mentioned that the cg had made a statutory decision giving adani unlimited time controversies and conclusions with the recent federal court decision on the north galilee water scheme ngws there is likely to be a high level of scrutiny applied to the water trigger carmichael rail network pty ltd as the mine rail proponent are responsible for separable portion 1 which is also the ngws stage b pipeline corridor crn are currently listed as a prescribed entity in the queensland water amendment regulation no 1 2020 for the purposes of obtaining a water licence to add to their extensive accreditations and approvals crn are enmeshed into the scheme having been included in ngws application documents and identified as the adani rail proponent 18 months before their existence as the adani rail proponent was ever acknowledged publicly the federal environment department is currently investigating a complaint regarding borrow pit 7 a quarry used to support the building of the rail corridor no party involved in the making the complaint conducting the investigation or reporting on it have been prepared to explicitly name the proponent responsible as usual the media reports suggest bravus is responsible with journalists like ben smee continuing to assert that adani became bravus which is an inaccurate simplification of the re branding of adani mining pty ltd after it had parcelled off it s rail corridor to the former shell company carmichael rail network pty ltd as this giant coordinated project gets built and the environmental complaints roll in agencies like the office of the coordinator general will continue in their patterns of apparent prevarication young journalists will obey their chiefs of staff and write what is expected and efficient and ngo operatives will continue to labour under the capacity constraints and narratives that are assigned and reinforced by the philanthropically funded members of the stopadani alliance this is not the time to serve a narrative it s the time to speak the truth forcefully michael swifte activism biggreen discourse climate activism frontline action native title 2 comments may 29 2021 14 minutes the office of the coordinator general and adani masking the rail proponent i spent a good chunk of last week pestering the slow moving media officer at the queensland office of the coordinator general to explain why they were three ...