19. SUBMISSION RESPONSES - Arrow Energy

658 Pages·2013·3.86 MB·English

Supplementary Report to the Surat Gas Project EIS
Surat Gas Project

19. SUBMISSION RESPONSES
This chapter presents Arrow’s response to issues raised in public submissions on the Surat Gas
Project Environmental Impact Statement (EIS). Issues and responses are presented in tables
according to the following:
• Table 19.1, Project approvals
• Table 19.2, Project need
• Table 19.3, Project description
• Table 19.4, Consultation
• Table 19.5, Impact assessment methodology
• Table 19.6, Air quality
• Table 19.7, Greenhouse gas emissions
• Table 19.8, Climatic adaptation
• Table 19.9, Geology, landform and soils
• Table 19.10, Agriculture
• Table 19.11, Groundwater
• Table 19.12, Surface water
• Table 19.13, Aquatic ecology
• Table 19.14, Terrestrial ecology
• Table 19.15, Landscape and visual amenity
• Table 19.16, Roads and transport
• Table 19.17, Noise and vibration
• Table 19.18, Economics
• Table 19.19, Social
• Table 19.20, Indigenous cultural heritage
• Table 19.21, Non-Indigenous cultural heritage
• Table 19.22, Preliminary hazard and risk
• Table 19.23, Waste
• Table 19.24, Environmental management plan
• Table 19.25, Ecologically sustainable development
• Table 19.26, Coal seam gas water and salt management strategy
Note that Arrow’s responses to the submission made by the Queensland Government
Department of Environment and Resource Management (Submission S132) and Australian
Government Department of Sustainability, Environment, Population and Communities
(Submission S127) are provided in Chapter 20, Response to DERM Submission and Chapter 21,
Response to SEWPaC Submission, respectively.

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Table 19.1 Approvals
Issue No. Submission No. Issue Reference Responses
R1001 S003, S009, S018, If this project is to be approved, conditions will EIS Section 804 of the Petroleum and Gas (Production and Safety) Act 2004(Qld)
S020, S032, S037, need to set that ensure section 804 of the Chapter 13, Section 13.6.1 requires that a petroleum authority holder carry out its activities in a way that
S039, S053, S055, Petroleum and Gas Act is upheld. Many of the SREIS does not unreasonably interfere with others conducting lawful activities.
S059, S064, S065, potential activities proposed in the EIS will present Chapter 8, Section 7.6 Where infrastructure is proposed on private property, Arrow will consult and
S070, S076, S085, an unreasonable interference to landholder’s lawful agree with landholder on the appropriate location for infrastructure and
S088, S095, S096, conduct of their farming activities. access routes (Commitment C084) with terms set out in conduct and
S097, S098, S108, compensation agreements with affected landholders. Arrow aims to
S114, S139, S140, accommodate landholders’ requirements and undertake activities considering
S152, S154, S167 existing and future land uses. Where possible, Arrow will be flexible in the
location of wells and infrastructure. Impacts will be addressed through
compensation.
R1002 S157 Exploration activities are excluded from the EIS, EIS Exploration activities are not included in the EIS as Arrow already has the
and yet Arrow is seeking a single Environmental Chapter 2, Section 2.2.5 and authority to conduct exploration activities under granted authorities to
authority for the entire project. If exploration Chapter 5, Section 5.3.1 prospect (ATPs), including ATP 683. Separate EAs specific to petroleum
activities in ATP 683 are not covered by the EIS, SREIS explorationactivities have been granted under the Environmental Protection
then why is ATP 683 included in the development Chapter 1, Figure 1.1, Act 1994(Qld)(EP Act) for these ATPs.
area? Also, operation under a single project Chapter 2, Section 2.3 and An authority to prospect must be converted into a petroleum lease (PL) before
environmental authority (EA) will mean that Arrow Chapter 3, Section 3.4 production activities can be undertaken. The Surat Gas Project will require a
may avoid the scrutiny that transitioning from site-specific environmental authority (formerly a Level 1 environmental
exploration to production activities would ordinarily authority) under the EP Act. The preparation of an EIS is the preliminary
require. They will be able to amend existing EAs, assessment process for identifying potential impacts and mitigation measures
and if approvals are based on the EIS as it stands, for resource activities.
insufficient detailed information will not be Following the completion of the EIS process, further approvals are required,
available. including the amendment of Arrow’s existing project EA or application for new
EAs. This is envisaged to be a staged process over the life of the project. As
each new stage of gas field development or facility is planned, progressive
EA or EA amendment applications will be made to encompass these activities
(SREIS Chapter 2, Project Approvals, Section 2.3).
Specific conditions relating to individual facilities and locations (e.g., streams)
will also be prescribed as the administering authority deems necessary. Site
specific environmental assessment will be undertaken as required prior to
each EA or EA amendment application in order to provide the level of detail
required by legislation to support amendment the applications.
Arrow’s existing ATPs and PLs are shown on SREIS Chapter 1, Introduction,
Figure 1.1. At the time the EIS was published, progressive development of
five development regions (Wandoan, Chinchilla, Dalby, Millmerran and
Goondiwindi) was proposed (EIS Chapter 5, Project Description, Section
5.3.1). The development sequence has been revised to the progressive
development of eleven drainage areas, identified by sequential numbering,
that correspond with the gas reserves that will be fed into each central gas
processing facility (CGPF) (SREIS Chapter 3, Project Description, Section
3.4).
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Table 19.1 Approvals
Issue No. Submission No. Issue Reference Responses
R1003 S088 Request that the regulator free the constraints on EIS Noted. Arrow will develop the gas resources in accordance with applicable
Arrow from developing coal seam gas activities on Chapter 8, Section 8.4 laws, including on land that can be accessed for petroleum development.
state land, in exchange for staying off the highly
valuable black soil floodplain until the resource is
expended on state land.
R1004 S081 Are petroleum activities exempt from State EIS Petroleum activities are exempt from State Planning Policy 1/92, however the
Planning Policy 1/92: Development and the Chapter 2, Table 2.3 and project has considered this and other key state planning policies in EIS
Conservation of Agricultural Land and Strategic Chapter 13, Section 13.4.7 Chapter 2, Project Approvals, Table 2.3. Further assessment of potential
Cropping Land (SCL) Legislation? SREIS impacts on good quality agricultural land is presented in EIS Chapter 13,
Chapter 2, Section 2.4.1 Agriculture, Section 13.4.7.
Petroleum activities are not exempt from the requirements of the Strategic
Cropping Land Act 2011(Qld). See SREIS Chapter 2, Project Approvals,
Section 2.4.1 for further information.
R1005 S081, S094 The chief executive should not allow the EIS to EIS Standard criteria are defined in Schedule 4 of the Environmental Protection
proceed until the EIS can conform to the standard Attachment 7 Act 1994(Qld)(EP Act). The standard criteria pertain to matters that the chief
criteria. If the EIS cannot satisfy the standard executive of the administering authority must consider when making decisions
criteria, then the project should be refused. under the EP Act. This includes determining whether an EIS is required for a
development and the regulatory requirements that must be addressed when
the chief executive prepares an EIS assessment report.
There is no requirement for an EIS to ‘satisfy the standard criteria’, however
the EIS and SREIS must address the prescribed EIS Terms of Reference
(TOR). The TOR require the EIS to ‘present a brief summary of the project’s
compatibility with the standard criteria as defined by the Environmental
Protection Act 1994, which include the principles of ESD and other relevant
policy instruments.’ This requirement has been addressed in EIS Attachment
7, Ecologically Sustainable Development, Section 6.
R1006 S094, S108, S117, The chief executive should not allow the EIS to EIS The SREIS presents changes to the project description that have occurred
S138, S142, S163 proceed until all the deficiencies of the EIS have Chapter 21, Section 21.6 since the publication of the EIS (SREIS Chapter 3, Project Description) and
been addressed and it can convincingly show a SREIS discusses any outstanding information requirements in accordance with the
significant net social, economic and environmental Chapter 3 prescribed terms of reference.
benefit. EIS Chapter 21, Economics, Section 21.6 presents a cost-benefit analysis for
the Surat Gas Project.
R1007 S157 Of particular concern to the submitter is the SREIS The EIS for the Surat Gas Project is being assessed in accordance with the
possibility of the Coordinator General being Chapter 2, Section 2.3 requirements of the Environmental Protection Act 1994(Qld)(EP Act). The
approached prior to the issuing of an EA for the decision maker under the EP Act is the chief executive. Completion of the EIS
project. There is concern that the flaws in the EIS process as set out under the EP Act does not negate the need for Arrow to
and the EMP will pollute decision making. obtain EA or EA amendments for the project; see SREIS Chapter 2, Project
Approvals, Section 2.3.
For further clarity, EIS Attachment 5, Environmental Management Plan
(EMP), which has been updated in SREIS Attachment 2, Strategic
Environmental Management Plan, is a preliminary document that will be
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Table 19.1 Approvals
Issue No. Submission No. Issue Reference Responses
R1007 S157 further developed to support the application for development approval of all of
the project components. The plan summarises the mitigation, inspection and
monitoring measures identified in the EIS developed to manage impacts and
reduce environmental risk. While representing a thorough summary of
Arrow’s commitments to avoid, minimise, mitigate and manage environmental
impacts it does not contain all the site-specific information required for formal
issuance of an EA or EA amendment. EA or EA amendment application(s)
will be lodged in accordance with the statutory requirements and will include
supporting technical information, as required. These requirements are
currently outlined in the EHP Guideline "Application requirements for
petroleum activities".
An alternative EIS process in the State of Queensland is that regulated under
the State Development and Public Works Organisation Act 1971 (Qld)
(SDPWO Act), The Coordinator-General is the decision maker under
SDPWO. This process is not applicable to the Surat Gas Project.
R1008 S014, S044 The administering authority should take into – Noted. Under the standard criteria as defined in Schedule 4 of the
account the Condamine Floodplain residents’ Environmental Protection Act 1994 (Qld), the chief executive is required to
public interest and lack of support for the project, consider all submissions made by the project proponent and submitters and
as it relates to the Environmental Protection Act the public interest.
1994 Standard Criteria used to assess the Surat
Gas Project.
R1009 S055 Prior to approval all environmental values within EIS EIS Chapters 9 to 26 describe the environmental values of the project area.
the project area must be properly described, Chapters 9 to 26 and Where applicable, environmental values within the project area have been
otherwise the nature and severity of impacts may Attachment 10 incorporated in constraints mapping presented in EIS Attachment 10,
be underestimated and environmental controls may SREIS Preliminary Constraints Maps and SREIS Attachment 8, Constraints Mapping
not be appropriate. Chapter 2, Section 2.3 and Update. The framework approach identifies constraints to coal seam gas
Attachment 8 development in the project development area, having regard to the sensitivity
of identified environmental values.
Site specific environmental assessment will be undertaken as required, prior
to each EA or EA amendment application in order to provide the level of detail
required by legislation to support these applications (see SREIS Chapter 2,
Project Approvals, Section 2.3).
R1010 S116 An EA must provide minimum conditions for – Environmental conditions considered relevant to the project will be set by the
minimising: administering authority.
• Traffic movements
• Noise Pollution
• Light Pollution
R1011 S130 Western Downs Regional Council requests that the EIS Unlike the other LNG projects in Queensland, at the time the EIS processes
project be assessed under the ‘significant’ project Chapter 1, sections 1.1 and for the Surat Gas Project, Arrow Surat Pipeline (formerly the Surat Gladstone
legislation, in line with other similar projects 1.4 Pipeline), and Arrow LNG Plant (formerly the Shell Australia LNG Project)
including QCLNG and APLNG. commenced in 2009, each project was proposed by a different proponent. On
this basis, separate approvals processes commenced under the
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Table 19.1 Approvals
Issue No. Submission No. Issue Reference Responses
R1011 S130 Environmental Protection Act 1994(EP Act) (Arrow Surat Pipeline and Surat
Gas Project) and the State Development and Public Works Organisation Act
1971(SDPWO Act)(Arrow LNG Plant). In the case of the Arrow Surat
Pipeline, the EIS process was completed in January 2010 and an EA and
pipeline license have since been issued.
On 23 August 2010, a 50:50 joint venture between a subsidiary of Royal
Dutch Shell plc and a subsidiary of PetroChina Company Limited
(PetroChina) acquired ownership of Arrow Energy (EIS Chapter 1,
Introduction, Section 1.4). Under this new ownership structure, the above
projects together with the Bowen Gas Project and Arrow Bowen Pipeline have
come to comprise the larger Arrow LNG Project (EIS Chapter 1, Section 1.4).
Existing EIS processes, which were well advanced at the time of the Royal
Dutch Shell and PetroChina acquisition of Arrow Energy, have continued.
Each project must address comprehensive terms of reference under either
the EP Act or the SDPWO Act and there is no benefit to be gained from
recommencing a consolidated EIS process under the SDPWO Act, especially
as two components of the larger Arrow LNG Project (Arrow Surat Pipeline and
the Arrow Bowen) have already been approved.
R1012 S150 The EIS must provide information on whether – The reinjection of gas is not proposed as part of the Surat Gas Project.
Arrow intends to reinject gas as a means of
safeguarding the domestic gas supply. The
submitter has been informed by DERM that other
companies perform gas reinjection. The submitter
makes the following recommendations:
• That all gas reinjection pilot trials or operational
activities require a full and accurate assessment of
all minor and major risks to environment and
human health and well-being including sustainable
economic development of the region.
• That Arrow be required to produce independently
peer-reviewed scientific data to support all future
applications to trial reinjection of gas whether it be
a pilot study or any other gas reinjection activity.
• That a fully explained business case which
includes a full cost analysis around the gas
management practices that cause the need for
storing excess gas in the first instance is provided
by Arrow.
• That EHP (formerly DERM) make publically
available information outlining where gas
reinjection activities are currently occurring or are
proposed to occur and all conditions associated
with those gas reinjection activities or trials.
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Table 19.1 Approvals
Issue No. Submission No. Issue Reference Responses
R1013 S150 The Queensland Murray Darling Committee is EIS Noted. Arrow will be required to hold all relevant permits and approvals under
concerned by the number of additional key permits Chapter 2, sections 2.2.5 applicable legislation. Arrow will use and/or establish processes and
and approvals required and the compliance and 2.3 procedures under the company’s HSEMS to achieve compliance with
obligations attached them. How will the level of environmental conditions.
monitoring be resourced considering the number of
additional permits and approvals required?
R1014 S150 The Queensland Murray Darling Committee Mining EIS Noted. Reference to this planning document has been included in SREIS
and Energy Policy has been updated since 2009 Chapter 2, Section 2.5.1 Attachment 7, Legislation and Policy.
(October 2011). There are a number of key SREIS
changes that would require Arrow to revisit if they Attachment 7
are serious in their consideration of key planning
policies.
R1015 S150 The Regional National Resource Management Plan EIS Noted. Reference to this planning document has been included in SREIS
was not considered by Arrow and is missing from Chapter 2, Section 2.5.1 Chapter 9, Surface Water, Section 9.3.
Table 2.3. Suggests that this Plan is an invaluable SREIS
tool for Arrow to consider. Chapter 9, Section 9.3.
R1016 S011 Appendix K, Section 4.5.2 (Approach to Impact – The administering authority will consider the proposed mitigation and
Significance Developments) makes conclusions management measures (commitments) in setting conditions of approval for
regarding the significance of impacts based on the the project.
assumption that proven mitigation measures will be
utilised and applied successfully. Therefore, any
project approval or conditions which are based on
this assessment of significance must be contingent
on proven mitigation measures being utilised and
applied successfully.
R1017 S157 The terms of reference also recommend that the EIS For further clarity, EIS Attachment 5, Environmental Management Plan
Environmental Management Plan make an Attachment 5 (EMP), which has been updated in SREIS Attachment 2, Strategic
assessment of the project’s compatibility with the SREIS Environmental Management Plan, is a preliminary document that will be
standard criteria as defined by the Environmental Chapter 2, Section 2.3.2 and further developed to support the application for an environmental authority
Protection Agency, which require consideration of Attachment 2 (EA) or EA amendment for all of the project components.
the “character, resilience and values of the The plan summarises the mitigation, inspection and monitoring measures
receiving environment”. The Environmental identified in the EIS developed to manage impacts and reduce environmental
Management Plan is deficient in relation to these risk.
topics, and does not support the underlying intent While representing a thorough summary of Arrow’s commitments to avoid,
of the terms of reference to enable the “potential for minimise, mitigate and manage environmental impacts it does not contain all
petroleum activities to occur on any individual lot of the site-specific information required for formal issuance of an EA or EA
land in the project area”. Arrow therefore fails to amendment.
fulfil the requirements of Section 5 of the terms of For further clarity, the EMP updated for the purposes of the SREIS has been
reference. termed a Strategic EMP. The purpose of the Strategic EMP and subsequent
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Table 19.1 Approvals
Issue No. Submission No. Issue Reference Responses
R1017 S157 plans that may be developed as the project progresses are presented in
Section 1.3 of the Strategic EMP (SREIS Attachment 2).
The EA or EA amendment application(s) will be lodged in accordance with
statutory requirements and will include supporting technical information as
outlined in the EHP Guideline "Application requirements for petroleum
activities".
R1018 S157 Landholders can apply under Section 537DB to the – Arrow is not in a position to offer legal advice. The circumstances of each
Land Court for orders that no activities be case would need to be considered individually by a legal professional. A
undertaken on their land. However, without minimum buffer distance of 200 m has been developed by Arrow to address a
understanding the separation distances for all range of issues including community concerns over proximity of infrastructure
infrastructure and land uses etc., landholders are to people’s homes. Arrow has committed to ensuring that emissions from
not sure if they are able to apply for a similar order Surat Gas Project activities comply with established air quality (EIS Chapter
based on activities on neighbouring land. 9, Air Quality, Section 9.6). In the case of noise, site-specific, detailed noise
modelling of production facilities and the application of acoustic treatments
will be undertaken where the modelled noise from facilities exceeds the
established noise criteria at one or more sensitive receptors. Consideration of
intrinsically quieter equipment or design of acoustic treatments such as
hospital-grade exhaust systems and mufflers, or barriers and equipment
housing will be given (Commitment C310). In December 2012, Arrow
commenced a process of Area Wide Planning with landholder groups
throughout the Surat. This process aims to enable Arrow and landholders to
understand the potential impacts gas field infrastructure may have on farming
operations, overland flow on the wider floodplain and address how these
impacts can be mitigated or minimised, on both individual and neighbouring
properties.
R1019 S157 Even if more location specific information is being EIS The Surat Gas Project is a progressively staged development in eleven
provided by Arrow confidentially to the regulator, Chapter 5, Chapter 8 drainage basins over the estimated 35 year project life (SREIS Chapter 3,
Arrow still fails to meet the requirements of the SREIS Project Description, Section 3.5).
terms of reference specifically section 3.1.2, Local Chapter 3, Section 3.5 and EIS Chapter 5, Project Description, Section 5.2 described the various project
Context. Even though the terms of reference Attachment 8 components and identified that development may occur on any parcel of land
recognise that the exact location of infrastructure within the project development area, except urban areas, ‘no go’ areas, and
will not be able to be presented in the EIS (Section areas subject to other environmental constraints as discussed in EIS Chapter
4.14), the submitter indicates that this is 8, Framework Approach.
contradictory to the requirements in the following Arrow has proposed the framework approach to inform the siting of
section of the terms of reference”. Section 3.1.2, infrastructure. The framework identifies constraints to coal seam gas
which asks for “identifying potential areas to site development in the project development area, having regard to the sensitivity
infrastructure”. Section 4.14 (second paragraph) of identified environmental values. The level of environmental constraint
which asks for “information and criteria used to provides an indication of the project activities that could occur in a particular
inform the site selection and decision making on area, subject to the application of appropriate environmental management
the siting of project activities…” Section 4.14 (third controls. The framework approach also indicates what project activities
paragraph) which requires “the analysis must be should not occur in certain areas; see EIS Chapter 8, Table 8.1. Known and
sufficient to determine the potential for petroleum potential areas of development (regional and local context) are presented in
activities to occur on any individual lot of land in the SREIS Attachment 8, Constraints Mapping Update.
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Table 19.1 Approvals
Issue No. Submission No. Issue Reference Responses
R1019 S157 project area.” Precise locations of wells and associated infrastructure will be agreed with
landholders under the terms of a conduct and compensation agreement,
taking into account environmental and existing land use constraints. The EIS
conceptualised that vertical wells would be drilled across the project
development area with a separation distance between wells averaging a
minimum of 800 m. As discussed in SREIS Chapter 3, Project Description,
Section 3.4, the use of deviated drilling technology may allow the surface well
pad sites for multi-well pads to be separated over a distance in excess of
2,000 m where possible.
It is not feasible that the precise location of approximately 6,500 wells be
known in advance, as knowledge of gas reserves will evolve over time and
infrastructure needs to be planned to reduce impacts to landholder’s existing
and future land use. Site-specific environmental assessment will be
undertaken, as required, prior to each environmental authority (EA) or EA
amendment application in order to provide the level of detail required by
legislation to support these applications (see SREIS Chapter 2, Project
Approvals, Section 2.3). Since the publication of the EIS, property locations
have been identified for four CGPFs and a temporary workers
accommodation facility (see SREIS, Chapter 3, Project Description, Section
3.5). These sites have been investigated as part of the SREIS to determine
potential impacts and management measures. This information will support
an EA or EA amendment application for the initial stage of proposed
development.
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Table 19.2 Project Need
Issue No. Submission No. Issue Reference Responses
R2001 S046 Coal seam gas is a very considerable emitter of – Noted.
greenhouse gas in comparison with solar.
R2002 S150 The preparation of technical reports should include EIS As described in EIS Chapter 8, Environmental Framework, the technical
an evaluation of alternative forms of development, Chapter 8 reports have been prepared to inform the protection of environmental values
and significant weight should be given to those and natural resources of the project development area. The framework
strategies which minimise the impacts on natural approach allows appropriate environmental management controls for project
resources. activities to be identified and has underpinned the preparation of the EIS.
Technical studies have identified and documented environmental and social
constraints to activities within the project development area. Constraints
mapping will be utilised to assist in siting project infrastructure, and will be
updated on an ongoing basis.
The framework approach provides for the orderly development of coal seam
gas fields through the application of environmental management controls
(avoidance, mitigation and management) that are reflective of the level of
sensitivity of environmental values. In doing so, the approach allows for
alternative sites to be considered for facilities and wells where environmental
and social impacts can be avoided or reduced.
R2003 S050, S082 No alternatives have been proposed that preserve EIS EIS Chapter 13, Agriculture, Section 13.6, notes that through appropriate
the premium agricultural assets and allows a gas Chapter 13, Section 13.6 consultation with landholders and the broader community, intensively farmed
industry on the non-cropping and marginal cropping land (IFL) and coal seam gas developments can coexist without causing
land. This is an extremely unbalanced view given permanent alienation of, or diminished productivity from IFL.
the world's need to double food production by 2050 Key strategies for reducing the potential for permanent alienation of IFL
and the Queensland Government's policy is to do include the siting of wells in consultation with landholders in locations which
likewise. reduce impacts on productive areas and provide the best opportunity for
rehabilitation, aligning new infrastructure with existing infrastructure where
practicable and locating production facilities on less productive land, not IFL.
Further, as part of Arrow's commitment to coexistence, Arrow has committed
to minimising its operational footprint to less than 2% of total IFL area.
R2004 S081, S082, S108, The need for the project appears to rely on data EIS Alternative energy sources (including renewables) to coal seam gas do exist,
S111, S117, S138, from 2007 and projects a linear growth in demand Chapter 3, sections 3.1.1 although not currently on a scale and stage of development that will meet
S142, S163 for all energy sources to 2030. These projections and 3.3.2 Australian and world energy demands in the short to medium term. Natural
neglect the recent and significant changes in the gas has been widely identified as a ‘transitional’ fuel that will allow
renewable sector, particularly the role of solar in governments to implement policies that provide both for economic growth and
meeting energy demands. These changes will a move from a high dependence on carbon rich fossil fuels (such as coal) to a
significantly erode the need for future gas supplies, range of less carbon intensive sources, including renewable energy.
a factor which is neglected in the EIS. Predictions by the International Energy Agency, published in 2010 and
The supplementary EIS therefore needs to look at discussed in the EIS, identified natural gas, in particular, as playing a central
other options rather than full on, irrational role in meeting the world’s energy needs for the next two-and-a half decades
exploitation of coal seam gas reserves with its (EIS Chapter 3, Project Need, Section 3.1.1). The International Energy
associated significant impacts. There are better Agency’s most recent World Energy Outlook (IEA, 2012), which focuses on
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Table 19.2 Project Need
Issue No. Submission No. Issue Reference Responses
R2004 S081, S082, S108, energy alternatives to coal seam gas. the period 2010 to 2035, predicts that renewables will grow rapidly and
S111, S117, S138, provide an increasing share of global primary energy use on the basis of
S142, S163 government support, falling costs, carbon pricing and rising fossil fuel prices
in the longer term. Fossil fuels (oil, gas and coal) are however expected to
remain the principal source of energy worldwide, with natural gas almost
overtaking coal as the primary energy supply mix by 2035.
In Queensland, the Government considers the use of gas to be a key factor in
reducing the greenhouse gas emissions intensity from electricity generation
(Queensland Government, 2007). Reliance on natural gas therefore will
continue through the next 20 to 30 years while alternatives, such as solar,
become more viable on a large scale.
R2005 S030 There are many other sites more suitable for the EIS The Surat Gas Project aims to extract coal seam gas for domestic use and
development of the gas resource other than highly Chapter 13, Section 13.6 LNG export. The location of the proven and probable coal seam gas
developed irrigation farmland. By the project not resources will determine the most appropriate and viable areas for field
proceeding, the supposed benefits will not be lost; development.
they will be deferred to a more appropriate time EIS Chapter 13, Agriculture, Section 13.6, notes that through appropriate
when science can fully inform an approval. consultation with landholders and the broader community, intensively farmed
land (IFL) and coal seam gas developments can coexist without causing
permanent alienation of, or diminished productivity from IFL.
Key strategies for reducing the potential for permanent alienation of IFL
include the siting of wells in consultation with landholders in locations which
reduce impacts on productive areas and provide the best opportunity for
rehabilitation, and locating production facilities on less productive land, not
IFL.
R2006 S108, S117, S138, The supply of LNG is not guaranteed to substitute EIS Natural gas has been widely identified as a ‘transitional’ fuel that will allow
S142, S163 higher emission energy sources as it may delay the Chapter 3, sections 3.1.1 governments to implement policies that provide both for economic growth and
implementation of zero emission energy projects and 3.3.2 a move from a high dependence on carbon rich fossil fuels (such as coal) to a
such as wind or solar. A report prepared for APPEA SREIS range of less carbon intensive sources, including renewable energy.
(Australian Petroleum Production and Exploration Appendix 3, Section 6 Predictions by the International Energy Agency are that natural gas, in
Association) showed that emissions are highly particular, will play a central role in meeting the world’s energy needs for the
dependent on technology and even ultra super next two-and-a half decades (EIS Chapter 3, Project Need, Section 3.1.1). In
critical black coal power stations can have lower Queensland, the Government considers the use of gas to be a key factor in
life-cycle emissions intensity than some open cycle reducing the greenhouse gas emissions intensity from electricity generation
gas turbine power stations. Assessment criteria for (Section 3.3.2). Reliance on natural gas therefore will continue through the
the Project Environmental Authority do not include next 20 to 30 years while alternatives, such as solar, become more viable on
assessment of the impact of other activities that a large scale. The move to alternative energies and the rate of this change
may seek approval if the project does not proceed. will, to a large extent, also be dependent on the policy framework adopted by
Further, it would be neglecting the requirements of different governments around the world.
the Environmental Protection Act to disregard the The EIS can only assess projects that exist, have taken a financial investment
emissions from the project due to a hypothetical decision to proceed, or have sufficient information available to enable
consideration of other projects that may seek cumulative impacts to be assessed. Projects meeting these criteria have
approval if the project is refused. been included in the cumulative assessment (EIS Chapter 28, Cumulative
Impacts). The EIS is not required to assess hypothetical alternatives as
Coffey Environments
7040_12_PartB_Ch19_Rev1.docx
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