The Galilee Basin Shell Game Continues

Matt Rose from the Australian Conservation Foundation kindly sent me their latest report which was independently prepared by ACIL Allen for submission to the upcoming senate NAIF inquiry.
The authors of the report assume that the 1 billion NAIF loan is for the North Galilee Basin Rail Project which is mentioned 19 times. This assumption is not supported by any citations, but in my opinion the assumption is correct.
The distance of the proposed rail link corridor is listed by the Australian Marine Conservation Society as 388 kms, the recent television spots by Adani have also listed the distance as 388 kms, and a media statement by Matt Canavan in December last year lists the distance as 388 kms. The following passage in the ACF report prepared by ACIL Allen shows where that 388 km figure comes from.
“The rail link comprises the 78-km Carmichael rail project from the mining and processing operation to Mistake Creek, and the 310-km North Galilee Basin Rail (NGBR) project from Mistake Creek to Abbot Point. The NGBR facility will be accessible by other enterprises. The rail link would have an initial capacity of 40 million tonnes per year and an ultimate designed capacity of 100 million tonnes per year. The cost of the Carmichael and NGBR rail projects is estimated to total of the order of $2.75 billion (based on the $2.2 billion reported cost of the NGBR), and the total cost of the mine, rail and port facilities and other associated infrastructure has been reported to be around $21.7 billion.”
This is how it breaks down. The North Galilee Basin Rail Project (NGBR) is 310 kms, you can confirm that distance here. The rail component of the Carmichael Coal Mine and Rail Project (CCMR) must be 78 kms, but the authors don’t provide a source or explanation for this assumption. The whole figure of 388 km represents a fusion of two separate and easily conflated projects. Indeed that was the substance of the explanation offered to me today when I spoke with Matt Rose and asked about the lack of primary sources, and the invisibility of the NGBR to most people.
My question is: Is the CCMR component of the 388 km corridor a part of the NAIF application by Adani?
The North Galilee Basin Rail Project has all the land use agreements it needs, biodiversity offsets have been arranged, and the CEO of Adani Australia is reported to have said that 100 workers will be employed to do geotechnical work on the NGBR over the next 6 months. The Carmichael Mine and Rail Project is another matter entirely. Could it be severable? Could the North Galilee Basin Rail Project get built and begin servicing other north Galilee Basin mines and incentivising the further opening of the Galilee Basin while we are distracted by the Carmichael mine and unnecessary conflations?
For further reading check out my blog post: Compromised Primary Sources and the Galilee Basin Shell Game
Also, check out this report by Mark Kenny in today’s Sydney Morning Herald. It contains not a single reference to the North Galilee Basin Rail Project.