Submission Cover Sheet Golden Beach Gas Project Inquiry - EES 6 Request to be heard and participate in No - but please email me a copy of the the submitter conference?: Agenda and any Directions Full Name: Jane Hildebrant Organisation: Affected property: Attachment 1: https://engage.vic Attachment 2: Attachment 3: Comments: See attached submission Submission to Golden Beach Energy Environmental Effects Statement December 3, 2020 Preamble Please regard this submission as an objection to the GB Energy (GBE) proposal as outlined in the Environmental Effects Statement documentation.1 GBE’s claim that Victoria’s EES process is ‘rigorous and transparent” is quite contrary to the reality for lay persons who have a mere thirty (30) business days to analyse the extensive material put before them. Consequently, the matters discussed in this submission are by no means exhaustive. The EES documentation is not “user-friendly”, the technical reports complex, making its evaluation an arduous process even for expert professionals and extremely daunting for lay persons. The Victorian Farmers’ Federation (VFF) Mining and Petroleum Policy Principles holds that the onus should be on the mining or gas company to prove that their activities will not contaminate, land, air, or water. But, given the EES reports are prepared on behalf of, and paid for by, the company, the information is inevitably biased towards the project. They invariably claim impacts are negligible, insignificant, or able to be mitigated or managed, but never avoided. The conflict of interest is clear. The requirement for lay citizens to demonstrate why this project will have adverse consequences places them at a distinct disadvantage. Yet, people feel compelled to take time out from their normal activities to write submissions for fear that if they do not, the project will be approved unopposed. This process is contrary to the rules of Natural Justice. Project Evaluation The Ninety Mile Beach (at 94 miles or 151 kms) is the longest stretch of uninterrupted sandy beach in the world. It is one of Victoria’s key tourist attractions based on the natural land and marine environment, including activities such as whale watching, surfing, fishing, camping, walking, swimming and bird watching. Lake Reeve, across which GBE plans to drill a pipeline, is part of the Gippsland Lakes RAMSAR wetlands. Large sections of the Ninety Mile Beach are managed by Parks Victoria. In the 1970’s, the State Government declared this land unsuitable for development due to its location on the narrow sandy dunes between Bass Strait and the RAMSAR-listed Lake Reeve. Large amounts of taxpayers’ money have been devoted to restoring and protecting environmental assets, like the Gippsland Lakes, waterways, freshwater wetlands and flora and fauna habitat. Furthermore, it is incomprehensible that the State Government and the Wellington Shire Council would spend millions of taxpayers’ dollars to repossess the 25km stretch of “inappropriate subdivisions” made during the 1950s and 1960s but now approve an industrial facility at Delray Beach, 4 kms approx. south of Golden Beach township (Ch4, p6). Legislative Framework I hope that the Panel will closely scrutinise how the Offshore Petroleum and Greenhouse Storage Act 2010 (OPGS) intersects or conflicts with other Acts and key strategic policy, e.g. Marine and Coastal Act and Policy, Environment Protection and Biodiversity Conservation Act 1999, Catchment and Land Protection Act 1994, Water Act 1989, Environment Protection Act 2018, Climate Change Act 2017, Safe Drinking Water Act 2003, Public Health and Wellbeing Act 2008, Charter of Human Rights and Responsibilities Act 2006, and obligations under international law, such as RAMSAR, Japan Australia Migratory Bird Agreement (JAMBA), China– Australia Migratory Bird Agreement (CAMBA), Republic of Korea-Australia Migratory Bird Agreement (ROKAMBA) and the Bonn Convention (See OPGS Act, Section 69). Sustainable Development Notwithstanding the provisions of OPGS Act, Section 64, Section 61 states that regard must be given to the principles of sustainable development which invokes the provisions of the other Acts listed in the paragraph above. These include: (a) individual and community wellbeing and welfare should be enhanced by following a path of economic development that safeguards the welfare of future generations; (b) biological diversity should be protected and ecological integrity maintained; (c) both long-term and short-term economic, environmental, social and equity considerations should be effectively integrated into decision-making; (d) if there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation; 1 Please note: GB Energy has authorised the information in the EES documents. So, where the EES report might state something, I have used the noun “GBE” rather than the consultant’s name for the sake of simplicity. 1 OFFICIAL The pipeline and infrastructure will intrude into Rural Conservation and Farming zoned land, marine and coastal environments. The Wellington Planning Scheme outlines numerous policies and strategies pertaining to the protection of environmental, landscape, flora and fauna habitat and cultural heritage, coastal and agricultural assets. Although this project may not be subject to the same planning requirements as other developments (Ch 16, p6), Sections 61 and 69 (OPGS Act) do require GBE to apply the precautionary principle and to consider the project’s impacts on communities, future generations, equity issues, biodiversity and ecosystems. However, the words such as sustainable development, equity, future generations and precautionary principle are absent from Chapter 5 Legislative Framework. The Crown retains the rights to underground greenhouse gas and its storage facility if a licence is cancelled or surrendered (Sections 66 and 67), so it is important for the Minister to ensure these matters are fully considered in the interests of local rural communities. Social Impacts The citizens of Gippsland are fed up with having to defend their rights to live peacefully in a clean and healthy environment; to defend their homes, businesses, health and wellbeing from the predation of alien companies only interested in profit for themselves with absolutely no interest in local people. We Gippslanders are under constant onslaught from inappropriate developments, such the Hazelwood mine fire, onshore gas, a gold licence stretching from Toongabbie to the high country, the Kalbar mine, and now this. In March 2020, following the lengthy Inquiry into Onshore Unconventional Gas, the Andrews Government decided to permit onshore exploration but banned fracking. Haunted by the spectre of renewed onshore gas exploration affected residents and farmers are in an ongoing state of anxiety and psychological distress. Although GBE plans to drill two offshore wells to extract offshore gas and then use them for future gas storage, the plant and pipeline infrastructure will be onshore. The project’s impacts will be felt onshore as well as in the marine environment. The endless voicing of objections and submission-writing takes a heavy toll on people’s mental health, exacerbated by the Covid19 pandemic. “Rural Australians experience a range of health inequities—including higher rates of suicide—when compared to the general population”2. Yet, mental health impacts are never factored into decision-making. The exponential effect on health and morale inside rural communities, already classified as disadvantaged, exceeds ANY perceived economic benefits. It is extremely galling that any benefits are inevitably bestowed on others living far away, while all the environmental and socioeconomic disbenefits fall on country people. We pay the same tax rate as city folk and pay much higher council rates; in return we receive a lower level of services. Should we now expect a degraded quality of life as the norm? It seems country people just don’t count. Companies facilitated by our governments are free to ride roughshod over us. Even our local politicians let us down. And whatever Nationals’ politicians like Barnaby Joyce or the VFF say, no amount of money can compensate for the loss of a lifetime’s labour of love in building a property, a business, or for the right to the peaceful enjoyment of one’s home. And above all, to feel safe. Amenity Impacts GBE considers that the project’s potential to generate negative social impacts is limited and rates all negative impacts as “minor negative”. This includes noise from the compressor station on “one nearby dwelling” and “irritation and stress” caused by “an impost on their personal time and energies of a small number of farming families” (Social Impact Assessment, Technical Report, p4). “There may be amenity impacts to surrounding potentially sensitive receptors during construction, operation and decommissioning including those related to accessibility, air quality, noise and vibration and visual impact” (Ch 16, p4). Noise The Gippsland Water site for the gas compressor station was rejected because the “Victorian Government Land Transactions Policy … would likely cause Project delays in obtaining tenure” (CH 3, p22). So instead, “a midline compressor station [is to be located] on private freehold land, immediately adjacent to Gippsland Water land (accessed from Sandy Camp Road). Its footprint would be 25 hectares (500m x 500m). The construction of the onshore