Doctor John Black has given us permission to replicate his ‘Submission to the Western Australian Environmental Protection Authority in relation to Woodside Energy Ltd North West Shelf Project Extension Environment Review Document: EPA Assessment No. 2186′

His key dot points are below:

Woodside is proposing to obtain additional offshore gas to enable the North West Shelf Joint Venture (NWSJV) project to continue operation until 2070.

  • My major concern is that Woodside is proposing to continue to use existing emissions management systems and therefore current levels of chemical release into the atmosphere, while understating the damage inflicted on the world-unique petroglyphs, on public health and the impacts of greenhouse gas release.
  • There is strong scientific evidence that emissions from the Woodside plant are already dissolving the outer patina of rocks close to the Woodside site. Observations on Murujuga show clearly that the petroglyphs will be lost once the patina is destroyed. The impacts of emissions on the rock art are cumulative over time. Allowing continued high emissions will almost certainly damage Australia’s unique heritage.
  • There has been ongoing concern from health authorities around the world that there is no safe level of exposure for humans to pollutants such as ozone, nitrogen dioxide or PM2.5 particles. Ozone is a product of the Woodside operation emissions. Recent analyses of world data show impacts on human health with concentrations of ozone as low as 31ppb. Ozone concentrations at Karratha and Dampier exceeded or were close to 30 ppb for 10 days in every 100 days.
  • Doctors for the Environment in Australia now believe the maximum exposure for nitrogen dioxide should be less than 9 ppb. Nitrogen dioxide concentration in Karratha exceeded 9 ppb at least one day in 100 days and, for some years on Murujuga, exceeded the concentration on 10 days in every 100 days.
  •  There is strong evidence these emissions are affecting the health of people living in the area. Results from the Pilbara Health Profile Planning and Evaluation Unit report in November 2018 show children aged between 0 and 14 years, are hospitalised for lung disorders of asthma and bronchiectasis, which is damage and widening of the airways, 1.7 and 11.5 times more, respectively, than the Western Australian State average.
  • Continuation of emissions from Woodside at the current level will exacerbate the health issues of local residents. It is irresponsible for the Government to put the public and workers on Murujuga and in the towns of Karratha and Dampier at such continuing risk.
  • The adverse effects of climate change caused by an increase in atmospheric carbon dioxide from pre-world-industrialisation is clearly evident in this year’s Australian bushfire season. Woodside is a significant contributor to Australia’s greenhouse gas production, with 7.7 mt/year from scope 1-2 emissions and 80.2 mt/year in scope 3 emissions. The world is close to the ‘tipping point’, when the arctic tundra’s melt and release entrapped methane, which is 25 times more potent as a greenhouse gas. Humanity is in serious threat of catastrophe through large sea level rise, droughts, failed crops, fires and cyclones. For the sake of humankind, this project extension should not be approved.
  • Woodside’s claim that natural gas is important for the transfer from coal is outdated. The whole of the Australian Capital Territory is 100% renewables for electricity production and technology is currently available to replace all uses of gas.
  • Current technology is available to reduce nitrogen oxide and volatile organic compound emissions from industry to near zero and for greenhouse gas release to be carbon neutral. The Government must change the relevant Ministerial Statements and regulations to include emissions limits for the Woodside operation to be close to zero. A strict and rapid timetable must be imposed for installation of the relevant emission reduction technology for all existing operations.
  • Meaningful penalties for breaches of licence conditions must be introduced. Australian Governments appear to be weak on ensuring compliance with licences and prosecuting for breaches. For example, in the 2016 Financial Year, 462 Commonwealth EPBC Act projects were monitored and 96 were found to be non-compliant. No company was prosecuted. Instead, the Department ‘relied on administrative measures such as variations to conditions of approval, revisions to management plans, conservation agreements and warnings.’ Such a conciliatory approach to non-compliance will not ensure the health of citizen on Murujuga or preservation of the petroglyphs.
  • I am astonished at the ‘spin’ and dishonesty of the Proposal documentation. I am reminded of the tactics used by the tobacco industry in its campaign to downplay the impact of tobacco smoke on public health. The document casts doubt on current scientific evidence, presents erroneous conclusions about Woodsides own data and continually seeks more research to further delay action.

Read his full submission: John Black’s Submission to WA EPA Woodside Energy Ltd NSW Project Extension Proposal