Floating storage regasification unit, Port of Rotterdam, 2017. Photo: Alf van Beem
By Catherine Watson
WITH only 40 days to respond to an 11,000-page report on AGL’s proposed gas plant at Crib Point, the Phillip Island Conservation Society faced an onerous task.
Fortunately, the small PICS team had plenty of recent experience to call on. Having only recently fought a three-year battle to stop a proposed container port at Hastings, they were able to call on many of the same technical reports to mount their argument that the AGL plant has no place in Western Port.
“You hope you don’t have to keep fighting the same battle,” a weary PICS president, Jeff Nottle, told the Post.
WITH only 40 days to respond to an 11,000-page report on AGL’s proposed gas plant at Crib Point, the Phillip Island Conservation Society faced an onerous task.
Fortunately, the small PICS team had plenty of recent experience to call on. Having only recently fought a three-year battle to stop a proposed container port at Hastings, they were able to call on many of the same technical reports to mount their argument that the AGL plant has no place in Western Port.
“You hope you don’t have to keep fighting the same battle,” a weary PICS president, Jeff Nottle, told the Post.
He says governments leave it to volunteer organisations such as PICS to do the hard work of calculating the unstated public costs of major developments driven by the commercial initiatives of governments and industry.
The PICS submission notes: “Such initiatives appear attractive to proponents who do not include the flow-on impacts and costs to our environment and economy when undertaking cost-benefit analysis as part of their business cases. This approach seeks to privatise the gains from exploiting the natural world at minimal cost to the proponent.”
The PICS submission notes: “Such initiatives appear attractive to proponents who do not include the flow-on impacts and costs to our environment and economy when undertaking cost-benefit analysis as part of their business cases. This approach seeks to privatise the gains from exploiting the natural world at minimal cost to the proponent.”
| PICS worked in alliance with other conservation groups around the bay, including Environment Victoria, the Victorian National parks Association and Westernport and Peninsula Protection Council, to divide up the work and meet the deadline for submissions on the AGL plan. With PICS concentrating on the marine impacts, they identified several serious errors and shortcomings in the EES report, including an under-estimation of ship movements required to deliver the gas to Crib Point. | 6000 submissions The panel set up to consider the EES received around 6000 submissions. Hearings begin on October 10 and are expected to continue for 10 weeks. The EES panel is expected to report to the Minister for Planning on February 23, 2021 and the Minister is scheduled to make a decision by march 30. |
The EES reports annual averages of ship visits ranging from approximately 100 to 150. In fact, the PICS submission notes, the average of the past five years is 97.4. Since the EES states that up to 40 LNG carriers would visit Crib Point per year to deliver cargo to the FSRU, the increase is more than 40 per cent.
However, depending on carrier capacity, PICS estimates up to 51 LNG carriers could be required in a year, ie. a 50 per cent increase and an extra two ship movements a week.
“Increased use of the anchorage off Cowes and Rhyll raises the risk of impacts on the environment and amenity, e.g. from shipping accidents and safety incidents, dragging anchors, light spill, and noise pollution.”
In its 20-page submission on the environment effects statement (EES) for the project, PICS leaves open the question of whether the error is deliberate or just sloppy.
“The EES portrays Western Port as a busy, dredged, degraded port, perhaps to create the false impression that the additional environmental effects of the Crib Point gas import project will be insignificant,” PICS states. “It overstates existing ship traffic, understates the magnitude of project impacts relative to those of existing human activities in Western Port, and downplays the likely cumulative environmental effects.”
The PICS submission expresses concern at the failure of the EES to include the baseline studies, investigations, literature reviews, and up-to- date data required to fully assess environmental effects.
“Western Port’s value as a nursery area for fish is one of the reasons for its listing as a Ramsar site.28 The FSRU (Floating Storage Regasification Unit) would take in up to 450 million litres of seawater per day to run its heat exchange system.”
It says the project should not proceed without knowledge of the impact on fish larvae and mature fish. There are also concerns about the prospect of importing marine pests with the gas shipments and the impact of noise and lights from ship movements and plants.
“The risk of ships striking whales in Western Port’s channel is of concern, particularly for the Southern Right Whale. The channel is narrow, so even if a whale had been sighted, it would be difficult for an LNG carrier to respond and avoid collision.”
The submission points out that AGL has a history of pollution events, safety incidents and non- compliance with regulations, resulting in fines of more than $7 million since 2003. This record should be disclosed fully in the EES, rather than hidden behind three web links to annual and sustainability performance reports.
While PICS opposes the gas project on principle, it calls on the government/company to investigate alternative sites, notably Corio, which already has much of the infrastructure required for such a project.
The EES states that Corio and some other sites were not shortlisted as alternatives for the project based on initial screening criteria. It provides no assessment against these criteria.
Recently, however, Viva Energy announced a competing FSRU proposal to be sited at Corio, with claims that the site is more suitable than Crib Point.
However, depending on carrier capacity, PICS estimates up to 51 LNG carriers could be required in a year, ie. a 50 per cent increase and an extra two ship movements a week.
“Increased use of the anchorage off Cowes and Rhyll raises the risk of impacts on the environment and amenity, e.g. from shipping accidents and safety incidents, dragging anchors, light spill, and noise pollution.”
In its 20-page submission on the environment effects statement (EES) for the project, PICS leaves open the question of whether the error is deliberate or just sloppy.
“The EES portrays Western Port as a busy, dredged, degraded port, perhaps to create the false impression that the additional environmental effects of the Crib Point gas import project will be insignificant,” PICS states. “It overstates existing ship traffic, understates the magnitude of project impacts relative to those of existing human activities in Western Port, and downplays the likely cumulative environmental effects.”
The PICS submission expresses concern at the failure of the EES to include the baseline studies, investigations, literature reviews, and up-to- date data required to fully assess environmental effects.
“Western Port’s value as a nursery area for fish is one of the reasons for its listing as a Ramsar site.28 The FSRU (Floating Storage Regasification Unit) would take in up to 450 million litres of seawater per day to run its heat exchange system.”
It says the project should not proceed without knowledge of the impact on fish larvae and mature fish. There are also concerns about the prospect of importing marine pests with the gas shipments and the impact of noise and lights from ship movements and plants.
“The risk of ships striking whales in Western Port’s channel is of concern, particularly for the Southern Right Whale. The channel is narrow, so even if a whale had been sighted, it would be difficult for an LNG carrier to respond and avoid collision.”
The submission points out that AGL has a history of pollution events, safety incidents and non- compliance with regulations, resulting in fines of more than $7 million since 2003. This record should be disclosed fully in the EES, rather than hidden behind three web links to annual and sustainability performance reports.
While PICS opposes the gas project on principle, it calls on the government/company to investigate alternative sites, notably Corio, which already has much of the infrastructure required for such a project.
The EES states that Corio and some other sites were not shortlisted as alternatives for the project based on initial screening criteria. It provides no assessment against these criteria.
Recently, however, Viva Energy announced a competing FSRU proposal to be sited at Corio, with claims that the site is more suitable than Crib Point.