I think suggesting that to meet the requirements of the EPBC...

I think suggesting that to meet the requirements of the EPBC would add 3 years to an EIS approval time frame is probably a little excessive. Typically for an EIS there would be atleast 1 year of sampling already. Also, there potentially be publicly available data.

I think a clever consultant would be able to justify most coal mine EIS projects in a timely manner, even with the updated EPBC water trigger.

In my opinion, the new assessment provides some more rigor but would hardly be a show stopper.