Frogs and the Impacts of Coal Mining

Link below to a 6 minute YouTube clip made by James O’Connor and myself in an upland swamp in the Royal National Park.

https://www.youtube.com/watch?v=w5AdbMqvxL8

Submission to the IPC on Russell Vale UEP 2020

Tom Kristensen, Maianbar NSW

This written submission presents additional material to that put before the IPC via the electronic public hearing. I spoke about frogs and the need for independent scientific studies.

I am writing to oppose the proposal for expanding operations at the Russell Vale colliery. I am concerned that mining subsidence will continue to impact the ecology of the lease area through the draining of surface water and drawdown of groundwater in the upper slopes. These changes will have an adverse effect on Endangered Ecological Communities and raise the risk of catastrophic fire. I am further concerned that the planning process does not allow for adequate investigation of these impacts and that a Special Area set aside for the protection of water quality has now become a place where mining damage is concealed from independent scientific scrutiny.

I am aware that this proposal before the commission is for bordand pillar extraction rather than longwall mining, and that the predicted subsidence and ecological effects are said to be negligible. I have two concerns about the prediction of “negligible effects”. First, it is made despite the acknowledgment that there is more settlement yet to come from the previous longwall mining operations. Second, despite recording subsidence of 1.7 metres under upland swamps, the proponents have been unable to identify ANY previous effect on swamp ecology, guessing instead that changes observed are within natural variation. An alternative interpretation is that the monitoring methodology was insufficient to detect effects.

I have studied the recommendations of the IEPMC and I am not satisfied that the DPIE have paid sufficient regard to ecological issues as addressed in the Planning Secretary’s Final Assessment Report. I am not convinced the Revised UEP will result in only “imperceptible subsidence” as the Department assures us. Nonetheless the department has also recommended an increase in groundwater monitoring with the drilling of extra bores and placement of extra piezometers, recognising an inadequacy of past sampling. This engineering solution is but a single blunt tool to measure ecological outcomes, and it has failed in the past. The pattern of drying after subsidence covers the broader landscape and selective monitoring of sites will only tell a fraction of the story. The proponent has a poor history of identifying changes in the environment and there is no reason to expect a change in outlook; coal-miningcompanies are not in the business of identifying ecological problems.

There are various ways of investigating ecological change in the landscape. I have a belief in field research; carefully tracking the abundance and distribution of plants and animals while noting environmental changes. 

I live in Maianbar inside the Royal National Park south of Sydney, on Dharawal country. I have a degree in ecology from the University of Sydney. I work on a citizen science project,studying frogs by pooling data from recordings made using a smart phone app. Two endangered frogs grab my attention most, the giant burrowing frog and the red-crowned toadlet. One is as large as an apple and the other is as small as a grape. One is a solitary creature filling an entire valley with a wailing trill on a rainy night, while the other is gregarious and chatty whenever there is water to enjoy. The giant burrowing frog has a larger southern range and is listed by both State and Federalgovernments as a threatened species, while the red-crowned toadlet exists in greater numbers; its range is tightly constricted to Sydney sandstone country and it has a State listing as a threatened species. Both frogs are dependent on upland water supplies; but both live principally outside of swamps, both also live within the lease area of the Russell Vale colliery. There is a possible third endangered frog, Littlejohn’s tree frog and a large faunal assemblage including the Giant dragonfly – also a threatened species, but for now I will concentrate on the one frog.

The red crowned toadlet, Psuedophryne australis is a tough little frog that might help us monitor the drying of the environment. It doesn’t cope with urbanization, but left alone, it does very well, coping with the adversity of drought and fire. Similar to the iconic alpine Corroboree frog, also in the genus Psuedophryne, a small dark frog with vivid yellow marking resembling body paint, the red-crowned toadlet wears striking red markings most obvious on the top of head.

After the recent drought ended, the local frogs started calling again, and some have been calling ever since. Red-crowns call day and night, continually advertising the presence of free water. As that water disappears, the calls dial down. The calling is done by the mature males, alerting widely dispersed females and sub adults to the availability of water, essential for reproduction. 

The life cycle of a frog begins in water with an egg mass and then tadpoles start a race against time to produce legs and venture onto land. Red-crowns live in rudimentary burrows, which makes them a little cocky; unlike other more common frogs that fall silent as you approach, the red-crowns keep calling. Living in a burrow affords protection from predators and also protects them from desiccation. They also lay their eggs under shelter, giving their tadpoles that same protection. This ability to inhabit a burrow means these frogs can live in drier conditions, but it also means they need to site the breeding nests in a place that will be occasionally wet, so the common location is upstream where the water flow is not too heavy after rain. Red crowns are mostly found in the drainage lines that go on to form the creeks downstream.

If you were thirsty and looking for water you could do worse than listen out for red-crowns calling; the more reliable the water hole, the louder and more animated the calling will be. Ina large group, each frog takes a slightly different part and helpsbuild a distinct orchestral piece. As the water dries out after rain, only the most enduring water holes remain audible in the landscape. Usually these water holes will have a solid rock bottom; and often they are covered over with fallen debris and quite hidden from view.

Because they croak so readily, red-crowns are easily surveyed.Their changing calling patterns may provide valuable insight into the availability of water to a wider range of animals. Other frogs, small mammals, birds and reptiles will also drink and hunt from these hidden water holes. While the sound of frogs calling might reveal hidden water in the landscape, the lack of calls may reveal missing water. If frogs are unable to complete their breeding cycle due to insufficient surface water they will no longer be able to persist in the long-term. Mining related cracking depletes surface water and increases the rate at which ponds go dry. If rainfall no longer brings on the croaking of toadlets, that might reveal something of the condition of a landscape that is no longer periodically wet enough to support these hardy frogs.

Mining-induced cracking may be simulating drought conditions for our Endangered Ecological Communities; we may be running an unmonitored experiment. Cracking in upland sections of bush is off the radar compared to cracking of open creek beds. Cracking under the soil can go unnoticed. Disruptions in upland drainage lines may not be obvious sincewater is not normally visible in this environment. Monitoring of groundwater in swamps will miss effects that are felt in the drier slopes surrounding the swamps. The lack of water is not just a problem for the persistence of threatened species; it is an existential problem for people.

As a member of the Rural Fire Service I have seen the consequences of uncontrolled wildfire first hand. These extreme fire events, as witnessed only last summer, are not of the same class as bushfires; crown fires exceed tree canopy heights by multiples, fire propagates in unforeseen directions, and unique cloud formations draw winds in that feed the conflagration. After the fire has finished, the recovery response of vegetation is often crippled; stands of gum trees that would once have sprouted with vivid epi-cormic growth remain dead, shrubs that would have re-sprouted from the base remain dead, and seeds that would have germinated have been incinerated. Animals are likewise obliterated. This catastrophic damage does not account for the entire fire ground, there are still islands of green and larger burnt areas that will fully recover, but there are also the dead zones. The extent of these areas is determined by fuel factors and weather conditions. Where there is sufficient groundwater the vegetation will hold higher moisture content and burn with less intensity. Water retained in the environment is the best preventative for fire damage.

There are important questions to be answered about ecology and the disruption of water supply by coal mining in the protected Special Areas. I would ask the Panel to consider facilitating access to this lease area by ecologists other than those hired by the proponent. I propose further study of red-crowned toadlets as an indicator species for the drying environment. The protection afforded by Special Area status should not be used to shield mining operators who can make the unimpeachable claim that they are having a “negligible effect” on the environment. If we don’t look we wont see, and if we don’t listen for the frogs we wont hear them either.