To: Department of Planning, Industry and Environment NSW 18 Dec 2019
From: Julie Marlow, Berkeley
SUBMISSION TO THE PORT KEMBLA GAS TERMINAL MOD 1 – CAPACITY INCREASE
While I am thankful for the opportunity to comment on AIE’s proposed modification for the development and operation of its Port Kembla Import Gas Terminal, I find the two week exhibition period inadequate and unfair, especially at this time of year. The report presents the proposed modification as having no significant impact beyond what has been already approved. I suspect this presentation of the modification may be an obfuscated one. Community members deserve a longer period to digest the report in detail, seek expert advice, etc., in order to make a satisfactory submission.
Despite the short exhibition period and the report’s lack of clarity, I object to the proposal without hesitation.
My main objection is to the adverse impact the proposal—the original proposal and thus more so the current modified proposal—will have on the climate crisis the world faces. Climate scientists insist that, to avoid catastrophic climate change, global warming must be limited to 1.5°C. To achieve this limit “The IPCC says gas should make up only 133 EJ (23.1%) of the global energy mix by 2020, 113 EJ (22.5%) by 2030, and 76 EJ (13%) by 2050 for a 1.5°C limit” and “Under IPCC scenarios for 1.5°C, natural gas use must decrease by 13– 62% from 2020 to 2050. The wide range is due to varying assumptions about the uptake of carbon capture and storage (CCS) technologies.” (https://www.marketforces.org.au/info/key-issues/keeping-global-warming-to-1-5-c/). As Market Forces and other reputable commentators have emphasised, total emissions from developed fossil fuel reserves already vastly exceed the carbon budget for the 1.5°C limit. “Given that the 942 Gt CO2 embedded in existing and under-construction fossil fuel projects is more than double the IPCC’s 1.5°C budget of 420 Gt CO2, it is absolutely clear there’s no room for new or expansionary fossil fuel supply projects.”
AIE does not and cannot defend its proposal against evidence such as this. This project should not go ahead. The proposed modification, which will more than double the quantity of gas to be imported, represents a wilful blindness to the urgency needed for companies and investors to accept their responsibilities in the face of the global climate crisis.
AIE continues to claim that gas causes significantly less CO2 pollution than coal, making gas acceptable as a ‘transition’ source of energy for the time it takes the world to decarbonise. This is a highly controversial claim. If the emissions resulting from extraction processes, transportation and production of LNG are taken into consideration, AIE’s claim is on very shakey grounds. For example, it is undeniable that methane gas emission makes unconventional gas production an unacceptable risk to the climate. I ask that the consent authority for this proposal give due weight to the Climate Council’s 2017 report “Pollution and Price: The Cost of investing in Gas” https://www.climatecouncil.org.au/uploads/d15f6fc35d779951e8893693efdbbc10.pdf
• The Illawarra is crying out for investment in sustainable manufacture. It has the expertise and skilled workforce, the port, and local source of steel, all of which should make such investment attractive. It is perverse of AIE to pour its resources into an environmentally unsustainable project, the development and operation of a gas terminal. Potentially, the availability of more gas will delay the development of a local renewable energy sector. There is also risk that the gas import terminal will prevent development of more sustainable uses of the port. The project’s economic sustainability is also under question. The prospect that the gas terminal could become a ‘stranded asset’ should also be seriously considered.
• Repeatedly, in the modification report, it is claimed that the modification will enable AIE to offer customers long term contracts. What is meant by long term? It was stipulated in the EIS that the project had a life of 10 to 15 years, and at an AIE’s information session, community members were told its operational life could be as short as 5 years.
• It seems extraordinary that both proponent and EIS author made such a major miscalculation of demand for gas in the original application. The estimated difference between summer and winter demands is substantial: 120 TJ a day in summer, 500 TJ a day in winter. We’re also told that throughput will be riddled with unpredictable variability. This begs questions such as ‘is the newly found demand profile reliable?’ and ‘what other miscalculations have been made’? Such a miscalculation surely warrants cancelation of the development’s approval and independent appointment of another consultant to produce a fresh EIS.
• The report fails to address how changes in demand will change their employment conditions. Will this condemn many AIE workers, if not most, to seasonal work? How will the company support its workers during their 6 month break? How will it maintain a skilled, experienced workforce? What impacts on safety will the seasonal regime impose? Will the workforce be necessarily casualised? Have the relevant unions been consulted?
• Many of the key objectives of the project (3.1) could be met, indeed better met, by investment in renewable energy sources. The project should be disbanded on this point alone. The claim that the project is expected to contribute to NSW’s Renewable Energy Plan and its emissions reduction target (3.7) cannot be justified.
• The report describes the 19% increase in the project’s annual operational GHG emissions resulting from the proposed modification to be “relatively modest”. This shows an unacceptable complacency in regard to the project’s effluent. It should also be noted that the proponent’s emissions accounting comprises Scopes 1 and 2 emissions only. On moral grounds (arguably on legal grounds as well), it is more than time industry was required to consider Scope 3.
• In the report, the environmental impacts of the yearly increase in LNG carriers using the port—from 26 to up to 52—as well as the operational intensity in winter are too easily dismissed. An estimate of how many of the 52 carrier visits will be concentrated to winter is not even given, as far as I can see. The claims that the increase does not significantly increase hazard risk, waste, traffic, noise, pollution defy commonsense. For example, the last paragraph of 5.3.5 exemplifies the attitude of indifference to environmental protection typical of the report and does not, and cannot be expected to, inspire confidence: In relation to sodium hypochlorite discharge, all reasonable and practicable actions have been taken to deliver an environmental outcome which is in line with ANZECC’s objectives and environmental values for ambient water, as well as reflective of the other land uses, existing water quality and marine ecology of the working harbour. As such, no further mitigation measures are considered necessary.
• The Wollongong City Council has recently committed the city to an aspirational target of ‘zero emissions’ at least by 2050. It should be the responsibility of all local industrial developments, whether in operation, already approved or proposed, to implement emission reduction plans that comply with this commitment.
• The degree of flexibility demanded of the modification simply has not been adequately addressed. Lifting the 72 hour yearly limit on FSRU use of marine diesel oil on the off-chance that technology will improve is certainly not acceptable. The conclusion arrived at in the modification report that “overall, the Port Kembla Gas Terminal will remain substantially the same development as approved under the original infrastructure approval” is staggeringly unconvincing.