Attention: Bennett Resources Pty Ltd (Black Mountain Energy),
CC: Minister for the Environment, Senator Murray Watt, Department of Climate Change, Energy, Environment and Water (DCCEEW)
Re: Public comment on EPBC 2024/100006 Preliminary Documentation.
I believe the information provided by Black Mountain Energy in its ‘Preliminary documentation’ to support the proposal to frack the Kimberley is substandard and unreliable and in no way demonstrates that fracking is environmentally acceptable, for the reasons outlined below. Critical failures relating to the proponent’s assessment documentation for the ‘Valhalla’ proposal:
1. Failure to comply with the information requirements set out in the statutory, 15-page ‘Request for Further Information’ from DCCEEW, in relation to the risk of significant impacts to four ‘Matters of National Environmental Significance’ (MNES);2. Failure to provide the crucial aquifer and surface water connectivity information required by the Independent Expert Scientific Committee (IESC) in its formal advice to DCCEEW, which described Black Mountain’s assessment information as “limited”, “disjointed” and giving rise to conclusions that are “largely unsupported”;
3. Failure to provide adequate information, including targeted surveys, upon which to assess impacts and risks to multiple EPBC-listed threatened species including the Largetooth sawfish, Greater bilby, Northern blue-tongue skink, Northern brushtail possum, Northern quoll, Purple-crowned fairy wren and Gouldian finch;
4. Failure to survey or assess impacts to subterranean fauna despite potential presence of rare, unique and undescribed species;
5. Failure to conduct a biological survey of Mount Hardman Creek, a major tributary of the National Heritage-listed Martuwarra Fitzroy River connecting the Oscar Range (Devonian Reef) to the River and potentially providing critical habitat for many of the above threatened species, despite the Creek flowing through the middle of the project area and being within 1.5km of proposed frack wells;
Image: Mount Hardman Creek fills from the Oscar Range and flows into the Martuwarra Fitzroy River - passing within 1.5km of proposed frack wells.
6. Failure to consult with Traditional Owners and Native Title holders whose lands are close to and surround the project area, despite multiple directions from DCCEEW to consult with those groups and despite the fact that some planned frack wells are within 2km of the Native Title boundaries of groups who have not been consulted;
7. Failure to consult with Traditional Owners and Native Title holders upstream and downstream of the proposal area who are the shared custodians of the Rainbow Serpent tradition that forms the basis for the listing of Martuwarra Fitzroy River as a National Heritage place;
8. Failure to provide adequate information in relation to the risks to communities from the use of hundreds of different fracking chemicals, many known to be extremely toxic to people and aquatic life, risking contamination of aquifers, surface waters and drinking water;
9. Failure to adequately assess the impacts on communities from a huge increase in heavy truck movements carrying thousands of tonnes of chemicals and frack sand (proppant) along dirt roads servicing isolated communities;
10. Failure to adequately consider the increasing risk of extreme weather events, such as the record floods in the area in 2023, and resultant fracking wastewater contamination risks to communities, Mount Hardman Creek and National Heritage-listed Martuwarra Fitzroy River;
Image: Martuwarra Fitzroy River: Record rainfall and floods, 2023
11. Failure to document and consider risks to numerous surface water features, ephemeral wetlands and groundwater dependent ecosystems (GDEs) in close proximity to well sites - whose existence the proponent has completely ignored;
12. Failure to conduct essential and required hydrological and hydrogeological studies of local aquifers and surface water features to clearly identify connectivity, faults and fissures, extent of ‘aquifer seals’ and resulting risks of contamination to creeks, rivers, aquifers and drinking water;
13. Failure to provide reliable groundwater drawdown modelling to assess impacts of proposed extraction of 2 BILLION litres of groundwater (100 ML per well). The modelling upon which Black Mountain relies for its claims of ‘no credible impact pathway’, has been comprehensively debunked by Fitzroy catchment hydrology/hydrogeology experts HydroGeoEnviro Pty Ltd (2026). Black Mountain has never responded to this report or its findings, including:
Shallow deep connectivity potential between aquifers was not adequately addressed, and vertical connectivity was not included in the groundwater modelling. Vertical connectivity exists broadly across the area particularly in the Fitzroy Valley (Taylor et al. 2021) and there is clear evidence of deep groundwater discharge at Mt Wynne Seep (Currell 2022) based on gas content. The groundwater model hydraulic parameters were highly uncertain and based on non-site specific literature values. The groundwater model presented by INTERA was highly non-unique and was not calibrated against a meaningful dataset. (‘Review of EPA’s assessment of the Valhalla Gas Exploration and Appraisal Program’. HydroGeoEnviro Ltd, 2026)
The proponent has wholly failed to provide required and reliable information to allow an informed decision that the project could proceed in compliance with the objects and requirements of the EPBC Act.
I am calling on Black Mountain to withdraw the ‘Valhalla’ fracking proposal as a result of the extensive failures listed above and the threat of serious and irreversible environmental degradation this proposal poses to the Kimberley and its communities. Fossil fuel industrialisation of the world-renowned Kimberley is totally unacceptable.
I am calling on the Minister for the Environment, Senator Murray Watt, to use his Ministerial powers to reject the ‘Valhalla’ fracking proposal for the reasons set out above.
I request acknowledgement that my comment has been received.
Yours Sincerely,
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