Submission Cover Sheet Crib Point Inquiry and Advisory Committee EES 3104 Request to be heard?: No Full Name: Steph Miller Organisation: Address of affected property: Attachment 1: Attachment 2: Attachment 3: Submission: My name is Steph Miller and I care about the environment in Westernport Bay. Westernport bay is an area of considerable biodiversity and is listed on the Australia heritage registrar. We are rapidly destroying nature and cannot continue like this. Embrace renewable energy and give your kids a future. I thank the Crib Point Inquiry and Advisory Committee and the Minister for Planning for the opportunity to make a submission to the environment assessment of the Crib Point gas import jetty and gas pipeline project. There are a variety of issues which should deem this proposal unacceptable under its current form and that I will point to in my submission but the issue that concerns me most is the impact on our internationally recognised wetlands and wildlife. A new fossil fuel project like the gas import terminal which AGL is proposing would introduce new risks to the local community and visitors to the area. These risks include exposing people to toxic hydrocarbons which may leak from the facility and increased risk of accidental fire and explosion as noted in EES Technical Report K. The nearest homes to the import facility are about 1.5 kms away and Wooleys Beach is also close to the site. AGL have completed only preliminary quantitative risk assessments on these risks and have deemed the risk acceptable on that basis. It is not acceptable to present preliminary studies and the EES should not continue until we have an independent expert to provide final risk assessments. Phillip Island is the second most tourism-dependent region in all of Australia. People come to see the little penguins and the migrating Humpback and Southern Right whales as well as other incredible marine and wetland wildlife. The industrialisation of Westernport Bay in the form of huge gas tankers and a Floating Storage and Regasification Unit will undermine the beauty of the area and be inconsistent with the perception that it is a pristine and protected wetland. This could impact Phillip Island as a popular tourist destination. Australia has committed to promote the conservation and wise use of wetlands as a signatory of the Ramsar Convention on Wetlands of International Importance. This is understood as the maintenance of their ecological character and preventing their degradation. It is inappropriate to build and operate a gas import terminal in the middle of one of the most precious environments in Victoria and an internationally significant wetland. If the project is approved AGL could dump up to 468 million litres of chlorinated water into the Bay each day which could have a disastrous impact on marine wildlife. There is so much we do not know about how this cold chlorinated wastewater will affect marine life in Westernport. The impact modelling completed by AGL is not comprehensive and in some cases totally inappropriate. Furthermore, current Victorian laws prohibit the discharge of wastewater in high conservation value areas like Westernport Bay - clause 22 of the Submission Cover Sheet Crib Point Inquiry and Advisory Committee EES 3105 Request to be heard?: Yes Full Name: Bron Gwyther Organisation: Address of affected property: Attachment 1: Bron_Gwyther_A Attachment 2: Attachment 3: Submission: as attached 26 August 2020 Dear Minister Wynne, Re: Crib Point Gas Import Jetty and Gas Pipeline Project Environment Effects Statement I urge you to reject the application for approval of the Crib Point Gas Import Jetty and Gas Pipeline Project (the Project). I live on French Island in Western Port, and I am incredibly concerned about the impacts and risks posed by this project to the environment and to the people who live here. Western Port is a wetland of international significance and supports many native species, including threatened and migratory species. It is a wonderful place, and one that is recovering from past misuse to a healthier future. Many of the human inhabitants of the bay, its islands and surrounds are betting their economic futures on eco-tourism, an industry that benefits so many more, with far fewer impacts, than heavy industry. This Project would reduce that potential for decades and could destroy it forever if a major industrial accident were to occur. AGL’s record of breaching their environmental licences (as well as its failure to disclose political donations) does not fill me with confidence that they can be trusted to meet any environmental obligations placed on this Project if it were to be approved. While there are many direct impacts and risks to the ecology of the bay and the Mornington Peninsula from the Project, I have focused my objection on a few key areas due to time constraints and the enormity of critiquing the EES in its entirety. Surface water impacts Surface and ground water flows will be impacted by construction of the pipeline, given that it passes through large areas of low lying land, much of which was previous swamp land and very prone to flooding and crosses seven main waterways, fifty seven minor watercourses and three constructed drains (Biosis 2020, 12). In addition, groundwater is very close to the surface in much of this area. These waterways discharge into a wetland of international significance, Western Port Bay. Construction and operation of the Project will impact creeks, wetlands and the bay, and poses ongoing risks over the 60-year life of the pipeline for this project, associated with this and any subsequent use for the pipeline. The EES notes that waterways in the region and the receiving bay Western Port are already threatened by sedimentation due to historical and ongoing land management practices. Rather than demonstrating that the Project will not cause undue impacts due to the system’s ‘degraded’ state, this instead demonstrates that this ecosystem of international importance should be protected from large industrial development such as this Project. The EES also notes that maintaining low rates of sedimentation is critical to preventing the smothering of sea grass, a critical ecosystem in the Bay. If you wanted to design a project that impacts the bay through sedimentation in as many ways as possible, undertaking construction and operation of an asset through the middle of a significant portion of the waterways that drain to the bay (as this Project does) would be the way you would do it. This includes passing through areas of potential acid sulfate soil, which could lead to sulfuric acid entering the waterways, soils, and groundwater (given the proximity of the groundwater to the surface). 1 As well as excessive construction impacts due to this alignment across many waterways, this pipeline alignment also poses an enormous risk to the Bay if there were to be an asset failure or explosion, as there could be multiple waterways threatened, all draining contaminants to the Bay. The greatest impacts are likely to occur during construction of the pipeline and associated infrastructure. Construction is planned to occur over a period of 18-27 months (though, if other large construction projects are anything to go by, could take a much longer period due to weather, equipment, staff issues or unforeseen issues, given the perfunctory assessments undertaken). Many of the construction techniques are high risk, such as: • Open trenching through 46 of the 56 km of the pipeline • Stock piling soil along waterways and across the floodplain. • Stock piling of materials • Vegetation removal • Large areas of soil disturbance (including set down, access and storage sites) • Dewatering of trenches (pumping out and disposing of sediment-filled water to waterways). This is an incredibly risky period, given the nature of the area, with the potential for flooding to move tonnes of soil, piled up along waterways and across floodplains, directly into the waterway and the bay. Sediment plumes from such an event would impact water quality, smother sea grass beds and could be resuspended over and over again to have continued impacts long after the event. Controls proposed to put in place to prevent such an occurrence are standard construction controls, and do not reflect the increased likelihood of a flood posed by this low lying environment, nor the increased consequence due to the waterway and downstream values. The EES claims that risks to aquatic values would be minimised by trenching across waterways in dry periods, but flows in ephemeral waterways are possible any time of the year and threats to groundwater dependent ecosystems due to dewatering would be higher during dry periods, due to the increased reliance of these ecosystems on groundwater during periods of low inflow. These waterways, even the more degraded ones, can support significant aquatic fauna, and include known habitat for federally listed species in waterways proposed to be open trenched. Aquatic fauna that access both the fresh and marine waters of the bay (such as the Australian Grayling – EPBC Act listed as Vulnerable) also face threats from the operation of the FSRU. The considerable thermal changes associated with the marine discharge, as well as the potential for reduced oxygen and contamination due to disposal of by products from the FSRU operation, could combine to make a no-go zone for some species. This could effectively be a barrier to movement for migratory species, such as the Grayling. In addition, the aperture size for marine intake on the FSRU (100 x 100 mm) (Chapter 6, p. 119) could easily entrain eggs, juveniles and adult fish, as well as diving birds, with impacts all the way up the food chain to marine mammals. Impacts to the Southern Brown Bandicoot I believe that impacts to the Commonwealth listed threatened species, Southern Brown Bandicoot, have been understated and inadequately managed over the construction period and 60 year life of the Pipeline.