Kimberley gas hub site - submit your public comment

The Kimberley region of northern WA is one of the most unique and intact natural and cultural environments in the world. It is a region that to date has been spared the worst of the industrial age and this is reflected in the fact that there have been no recorded plant or animal extinctions in the north Kimberley, in stark contrast to most of the rest of Australia.

Because it is unique and largely intact the Kimberley is of great social, cultural and economic importance to many people and businesses across the region, throughout Australia and around the world.

Site selection report released

LNG processing requires huge areas of land, major ports and other infrastructure. Photo: Remi Vignals

The Northern Development Taskforce (NDT) was set up by the previous WA State government to evaluate and select potential sites for a major industrial hub to process Browse basin gas into Liquid Natural Gas (LNG) for export. The NDT has released the site evaluation reports part A&B, identifying 4 sites in the Kimberley for further evaluation for a 28 day public comment period.

An alternative vision for the Kimberley

The Kimberley represents WA’s chance to avoid repeating the mistakes made elsewhere that have lead to polluted waters, degraded lands, species extinctions and loss of economic opportunities. Here we can still make informed and intelligent decisions regarding what kinds of development are compatible with maintaining the natural and cultural values of the region.

The frantic rush for fossil fuel dollars and development at all costs is only one of the options available. An alternative future for the Kimberley that provides for sustainable, long term development that is compatible with, and indeed relies on, a healthy and secure future for the Kimberley environment is a real possibility. This alternative future will contribute to long term wealth, security and human and ecological health to the region, the State, the Country, and the World. Business as usual will mean short term (30-50 year) profit at the expense of future generations and the environment they will rely on.

We call on all decision makers when considering these reports or other information regarding development in the Kimberley to weigh up the limited information available against the huge amount of research yet to be done and to weigh the short term gains with the long term environmental, social and economic risks and costs. The ‘development-at-all-costs’ approach must not be allowed to compromise the future of the Kimberley.

What you can do.

Please write a submission regarding this report and voice your opposition to locating this damaging development on the sensitive Kimberley coast. We have provided some suggestions regarding points you may wish to make in your submission below.

• Alternatively, download a suggested submission outline we have prepared for you >>
• NDT site selection reports A&B available at: http://www.doir.wa.gov.au/5649.aspx#5651
  
• The reports are also available on CD by contacting the Northern Development Taskforce on (08) 9222 0963 or (08) 9222 0568.

Submissions must be received by 5.00pm, Tuesday 11 November.

Email : ndt@doir.wa.gov.au

Mail: Site Evaluation Submissions
Northern Development Taskforce
Department of Industry and Resources
100 Plain Street
East Perth WA 6004

Summary of points you may wish to make in your submission:

• These reports fail to seriously consider potential non-Kimberley gas hub sites:– The government is obliged to assess non-Kimberley sites because, without the full range of options to consider, the process is compromised.
• The new government has undermined the integrity of the process for site selection by removing Traditional Owner rights to informed consent and by pre-empting public comment by announcing the government’s preferred site ahead of public comment and EPA recommendations.
• There is a lack of adequate scientific data on which to base a decision:– Good work has been done in the limited time available but there is no wet season data for the sites, nor enough information about the development’s impacts on Kimberley habitats and wildlife. The most important humpback whale breeding ground in the world, coral reefs, sea grass meadows, turtles and dugong are all at risk from the Kimberley onshore LNG processing proposal. The Natural and Cultural Heritage assessment that has recently commenced will be vital to the decision making process and must be finalised prior to hub site selection decisions.
• These reports have failed to properly address impacts of atmospheric pollution, including greenhouse gas emissions:– This development will produce huge amounts of greenhouse gasses and other airborne pollutants with far-reaching implications for surrounding communities and for meeting greenhouse gas emissions reduction targets.
• There are serious concerns regarding marine pollution and safety (both human and ecological):– The fossil fuel industry is known to be chronically polluting and subject to accidents that can be dangerous and harmful to the environment. The relatively unspoilt Kimberley is an unsuitable location to be needlessly exposed to these pressures and risks.
• The reports fail to fully recognize the unique character of the Kimberley:– this development will fundamentally change the nature of the Kimberley and impact negatively on established social, cultural and economic values and activities.
• There are alternatives to locating this development on the Kimberley coast:- The natural and cultural values of the Kimberley region, encompassing all of the sites recommended for further consideration in these reports, are not compatible with this form of industrial development. 
  

Recommendation

• In accordance with the application of the Precautionary Principle and the principles of ecologically sustainable development: The Environmental Protection Agency after assessing these and other reports should recommend that none of the sites selected can be considered suitable for development and that  no decisions be made on sites for a Kimberley LNG processing facility without full and complete knowledge being available on which to make this decision  . The required level of knowledge to make an informed decision will not be available before:

1. The Natural and Cultural Heritage assessment is complete;

2. Recommendations from this assessment and other scientific sources are implemented via a comprehensive and resourced management plan for the Kimberley natural and cultural environment and;

3. Scientists are given sufficient time and resources to gather and analyze site specific data over a reasonable, multi-season, timeframe.

More Detailed points you may wish to make in your submission:

Lack of consideration of potential non-Kimberley gas hub sites

• The NDT report has failed to consider, in any systematic or comprehensive manner, potential sites outside of the environmentally sensitive Kimberley region. This is despite consistent calls from members of the Environmental Working group to do this.
• This lack of proper assessment is despite such an assessment being required by the State and Commonwealth Joint Agreement and Terms of Reference for the strategic assessment.
• The consideration of sites within the Kimberley without looking at all of the available options, including sites in the Pilbara with existing industrial infrastructure, is logically, morally and environmentally irresponsible. Without access to the full picture comment on the sites selected in these reports is compromised.

Problems with process

• There is a very clear reality that the Northern Development Taskforce process that has negotiated with stakeholders and conducted and collated scientific knowledge regarding a number of potential sites for the LNG hub may not continue in its current form under the new State Government. To scuttle an established process that most stakeholders acknowledge is the best process of its kind seen in Western Australia sends a clear message that the views of the community are less important to this government than a reckless pro-development agenda.
• The announcement by the Premier of a preference for the North Head site pre-empts the public submission period and the proper consideration of this report and public submission by the EPA and other relevant bodies, including the Government.
• Another worrying announcement from the Premier was the removal of the requirement for the informed consent of Traditional Owners for this development. This negatively impacts on the ability of Indigenous people to negotiatiate outcomes that will protect them from the negative environmental and social impacts of LNG development and maximize the benefits to communities across the Kimberley region.
• This removal of the right of informed consent for Traditional Owners also is outside of the binding agreement between the State and the Commonwealth and increases fear and mistrust of this Government and the proposed developments.

Lack of comprehensive scientific data on which to base a decision

• While the scientists that have been engaged to undertake work on establishing baseline scientific data have undoubtedly done a good job given the limited resources and time available to them it is clear that not enough is yet known to make informed judgments about all of the environmental impacts of this proposed development.
• Wet season data is yet to be collected as part of this process for any of the sites and long term data, where available, is patchy and has in many cases been provided by mining companies.
• Data is lacking on the effects of Kimberley LNG processing on species such as the Humpback whale (the Kimberley is the nursery area for the most important Humpback whale population in the world), dugong, turtle, Australia’s own dolphin species – the Snubfin dolphin as well as important habitats such as coral reefs and seagrass beds.
• A two year Natural and Cultural Heritage assessment has been initiated and would be an obvious reference point for any decisions on major industrial developments proposed, however industry and other pressures seem determined to rush this through without proper consideration. This is likely to be because they are aware that this kind of industry is not compatible with protecting the important natural and cultural values of the region.

Climate change concerns

• The development of Browse basin gas will have serious climate change implications, including an estimated release of 18 mega tones per annum of greenhouse gas, that have not been adequately considered in this or any other report. This will make meeting WA’s greenhouse gas emission targets practically impossible.

Character of the Kimberley

• The Kimberley region is one of the last unspoilt large and naturally functioning ecosystems left on the planet. It is iconic to Western Australians and visitors from all over Australia and the World. An industrial development of this scale will severely impact on the character of the region with major undesirable implications for the environmental health, human health, visual amenity, social structures and the perception of the region.
• There are sustainable industries already established in the region, such as Indigenous and ecological based tourism, which will be negatively impacted by this development. The future potential for sustainable development will also be lost if this development goes ahead on the Kimberley coast.  

Pollution and Safety – human and ecological

• As we were recently reminded by the Varanus island gas explosion, accidents do happen in the oil and gas Industry. Location of a LNG processing facility in the environmentally sensitive and globally significant Kimberley region greatly increases the chance of major accidents further devastating the environment.
• Pollution is a day to day part of the oil and gas industry and the impacts on human and animal health are likely to be significant. Directing this development away from the Kimberley to already industrialised areas will minimize this environmental harm.

Recommendation

• In accordance with the application of the Precautionary Principle and the principles of ecologically sustainable development: The Environmental Protection Agency after assessing these and other reports should recommend that none of the sites selected can be considered suitable for development and that  no decisions be made on sites for a Kimberley LNG processing facility without full and complete knowledge being available on which to make this decision. The required level of knowledge to make an informed decision will not be available before:

1. The Natural and Cultural Heritage assessment is complete;

2. Recommendations from this assessment and other scientific sources are implemented via a comprehensive and resourced management plan for the Kimberley natural and cultural environment and;

3. Scientists are given sufficient time and resources to gather and analyze site specific data over a reasonable, multi-season, timeframe.