The Browse Carbon Dumping Project should be assessed by the WA EPA at the level of Public Environmental Review for several reasons.
Offshore carbon dumping (i.e. carbon capture and storage) has never before been attempted in Australian waters. World-wide, carbon dumping technology has consistently been a disappointing failure that over promises and under delivers (e.g. Chevron’s Gorgon project is predicted to only successfully dump about 4% of the development’s total emissions). Such unreliable technology should be subject to stringent environmental assessment given the inherent uncertainties.
The Browse Carbon Dumping Project poses potentially significant environmental risks, including harmful noise impacts from decades of seismic blasting, unplanned geological impacts to Scott Reef or Sandy Islet, carbon toxicity impacts from an unplanned gas release and pollution from an unplanned hydrocarbon release. Additionally, the dumped carbon will require long-term monitoring of at least 1,000 years. Given the scale of the potential impacts, the novel and unusual nature of some of these impacts and how devastating these impacts would be to Scott Reef if realised, a comprehensive assessment should be undertaken by the EPA.
The risks posed by the project could impact Western Australian fauna travelling to Scott Reef through Commonwealth waters, fauna in the State waters at Scott Reef, and the reef habitat itself. These are all highly valuable Western Australian environmental matters and the state – and its communities – should have a say in whether impacts to those matters are acceptable.
It is inappropriate to solely rely upon Commonwealth government processes to assess the project. Firstly, the Commonwealth government has not yet decided whether it will assess the project and whether any assessment would include an opportunity to make public comment.
Secondly, unlike Western Australian legislation, Commonwealth environmental assessments and approvals do not provide the public with merits review appeal rights.
Thirdly, the Commonwealth government is restricted in what it may assess and several Western Australian environmental matters would not be considered in a federal approval decision. For instance, any species listed as threatened under State law but not Commonwealth law would not be considered, such as the Silky Shark (Carcharhinus falciformis). Further, the State waters throughout Scott Reef would not be considered as part of any requirement to assess the ‘Commonwealth marine area, the protected matter being the environment generally’.
Fourthly, the state referral differs from the federal referral as it includes 1,000 years of post-operation monitoring of the carbon dioxide plume and reservoir management.
Scott Reef is an essential part of the Western Australian environment that is incredibly unique and biologically diverse. The reef and its wildlife deserve full assessment by the EPA of the terrible risks posed by Woodside’s outrageous carbon dumping proposal.