We write to you collectively from Save Westernport, the Victorian National Parks Association,
Environment Victoria, Friends of the Earth, Westernport & Peninsula Protection Council, Blue Wedges, Phillip Island Conservation Society and Preserve Western Port Action Group regarding AGL’s proposal for a gas import facility at Crib Point and connecting pipeline to Pakenham
This project has raised significant concern both locally and throughout Victoria due to its likelihood of threatening Westernport Bay’s high natural values and increasing Victoria’s greenhouse gas emissions.
We believe the plan is inconsistent with Victoria’s legislated net zero emissions target and could stall efforts to transition towards renewable energy. Moreover, we believe that the project will likely lead to higher, not lower gas prices for Victorians. This view is supported by Macquarie Bank’s thorough analysis of the price impacts of gas import terminals which we have attached to this letter. In short Macquarie Bank concludes: “We believe that any import terminal will not lower prices on the East Coast of Australia, and could potentially set a higher floor price.”
In light of the above, we have been concerned by statements of support for AGL’s project by senior Government Ministers, particularly ahead of any formal environmental assessment of the project, and urge you to reconsider this premature support.
AGL has indicated that submission of their referral is imminent. Given the scale of this project and the sensitive environment it is located in, we would expect you to require a full EES for the Floating Storage and Regasification Unit and pipeline as has been required of much less damaging projects in recent times, for instance level crossing removals.
Further to the letter that Environment Victoria sent on 18 July, AGL has confirmed that the two aspects of its project will be submitted together for referral. It has been pleasing to see your “expectation of a combined EES referral” as reported in The Age on 26 July.2 In light of community expectations, we respectfully ask that you uphold this commitment.
The risk to Westernport’s unique tidal bay and Ramsar wetland is significant and any damage to this valuable ecosystem will affect many local businesses who rely on the health of the bay. It is essential that this project is assessed to the highest environment standard. We therefore urge you to require a full EES.
The potential impacts of the project are of such concern that they require a determination in favour of a full EES. We outline our areas of concern below:
AGL’s proposal will increase Victoria’s climate pollution. The carbon intensity of Victoria’s gas consumption will be greater because the gas being brought into Victoria will have been liquefied, transported long distances, re-gasified and then stored, with each step consuming energy and adding to fugitive emissions. AGL has confirmed that this gas is likely to be 20 percent more emissions-intensive than gas currently sourced from Victoria.
The project could import as much as 130-160 petajoules of gas per year into Victoria, almost doubling the amount of gas flowing into the state, likely reversing the shift of industry and households away from gas and weakening the move to renewable energy. This increase in emissions associated with the higher lifecycle emissions associated with imported LNG is not calculated in the documents available on AGL’s website, but is likely to increase global greenhouse emissions by more than 200,000 tonnes which is the threshold outlined in the Ministerial guidelines. The emissions that are considered in AGL’s Jacobs Greenhouse Gas Assessment dated 23 March 2018 models 4 scenarios, of which Scenario D also comes very close the 200,000 tonnes threshold for assessment (190,925 tonnes), taking into account only the local emissions from the project and not the emissions associated with the LNG’s production and transport, nor the emissions associated with the construction of the pipeline.
Furthermore, the project could also involve importing gas produced from fracking, a dangerous and destructive practice that has been proudly banned in Victoria. It would therefore be inconsistent with Victoria’s leadership in banning fracking to encourage fracking in other parts of the country or world by starting a new import market in fracked gas.
Impacts on nature in Westernport Bay:
Westernport Bay is an internationally listed ecosystem, recognised under the Ramsar Convention as a unique tidal bay and wetland with important ecological values. It also has a UNESCO biosphere reserve designation.
It is home to a number of threatened species listed under the Flora and Fauna Guarantee Act (Vic) 1988 and the Environment Protection and Biodiversity Conservation Act (Cth) 1999 such as Southern Right Whale; Humpback Whale; Far Eastern Curlew; Curlew Sandpiper; Fairy Tern; Orange-bellied Parrot; Swift Parrot; Great White Shark; Mangrove Goby; Australian Grayling; two species of Ghost Shrimp; Southern Brown Bandicoot and coastal saltmarsh. There are deep concerns over the threats to the habitat and welfare of these species caused by the construction and operation of the FSRU and pipeline.
Marine ecosystem impacts:
There are extremely concerning marine impacts associated with this project. These include:
The discharge of up to 450,000,000 litres per day of cold sea water into Westernport Bay;
The discharge of up to 450,000,000 litres per day of chlorinated water into Westernport Bay;
The risk to the ecosystem and small marine life from becoming sucked into the heat exchanger;
The possibility of the introduction of marine pests;
The impact on two species of Ghost Shrimp, both of which are considered likely to be present in low numbers in suitable habitat, about which there is extremely limited knowledge;
The significant increase in shipping through Westernport Bay, increasing the incidence of vessel strikes with marine mammals and marine noise;
The potential for fuel spills and the impact this may have on marine life.
VNPA has undertaken extensive shipping oil spill modelling which shows the complexities and trends in movement in the Bay in addition to the impacts on birds, mangroves, and seagrass.
It is noted that cumulatively these impacts are likely to trigger the referral criteria of ‘potential extensive or major effects on the health or biodiversity of aquatic, estuarine or marine ecosystems over the long term’.
Our groups believe the triggers for individual and combined referral criteria demonstrate the need for an in depth assessment process of the FSRU and pipeline such as can only be provided by an Environment Effects Statement. Until such an approvals process is complete we think it is inappropriate for the government to be voicing support for the project. We would also urge you to read the Macquarie Bank research which argues that this project would likely lead to higher gas prices for Victorians - a poor public policy outcome.
We are not satisfied that a Works Approval or a Licence under the Pipelines Act 2005 would be sufficient to properly investigate and assess all these concerns, so we urge you to use your discretion to determine in favour of requiring an EES.
We will also write to the federal Environment Minister to request a full assessment under the Environment Protection and Biodiversity Conservation Act 1999.
Representatives from the organisations listed below would like the opportunity to meet with
you to discuss the matter in person at your earliest convenience.
1 Macquarie Wealth Management, East Coast Gas and Infrastructure 6 July 2018
2 https://www.theage.com.au/politics/victoria/call-to-put-agl-gas-plant-proposal-under- environmental-microscope-20180726-p4ztt8.html
3 Email from Jasmine Doak to Environment Victoria on August 8 2018.