The Australia Institute welcomes the opportunity to appeal Report 1727 North West Shelf Project Extension Proposal.

The role of the Western Australian Environmental Protection Authority (EPA) is to prevent, control and abate pollution and environmental harm.

In recommending the approval of a 50-year extension of Australia’s most polluting fossil fuel project, the North West Shelf (NWS) LNG project, the EPA is failing its primary function and enabling serious environmental harm.

Despite the urgency of climate change and its dire impacts on Western Australia, the EPA recommends allowing the extension that will result in 4.3 billion tonnes of greenhouse gas emissions (carbon dioxide equivalent – CO2e). 91 percent of these emissions (4 billion tonnes CO2e) are from combustion of the gas (scope 3) with no proposal for abatement at all.

This should be a reason for recommending against allowing the extension. Instead, the EPA has given this as a reason to simply ignore them and recommend approving the extension anyway.

Woodside claims it will reduce Scope 1 emissions to net zero by 2050 then continue to operate until 2070. Details on how mitigation will be achieved only explain the first 30 percent in emissions reduction, with no detailed mitigation strategies to reach net zero. Even if these targets were achieved, the aspirational abatement of 138.85 Mt CO2e is just 3.1% of total emissions. With the additional imposed conditions by the EPA, the Extension Proposal’s total Scope 1 emissions will still total 128 Mt CO2e, which cannot be considered compatible with the objective of reducing emissions – if the Extension Proposal was rejected, then 128 Mt CO2e in Scope 1 emissions could be avoided.

Given there is no explanation for 70 percent of the reduction of scope 1 emissions other than that the proponent will “avoid, reduce or offset” them, it appears the reductions will rely heavily on offsets.

All new major projects in Western Australia are required to contribute to the state’s aspiration of Net Zero by 2050. However, offsets cannot meet state targets because there is no mechanism allowing carbon offsets to contribute to subnational climate targets in Australia. This is true of both Australian Carbon Credit Units and international carbon credits.

For Western Australia or any Australian state or territory to count offsets towards a Net Zero target, a national accounting framework would have to be developed that allowed the import and export of emissions reductions across jurisdictions. The EPA cannot credibly allow offsetting as a legitimate mitigation strategy by big emitting while there is no way of accounting for offsets in state or federal climate targets.

Even if offsets could be used to contribute to state targets, there are serious questions as to the integrity of both Australian Carbon Credit Units (ACCUs) and international offsets.

The proposal also allows a further 50 years of acid gas emissions despite acknowledging that it “may be a threat of serious or irreversible damage” to priceless Murujuga Rock Art. This is in addition to the acid gas emissions from Woodside’s Pluto expansion which has been described as Juukan Gorge in slow motion.

The Murujuga site is of deep cultural and spiritual significance to the traditional owners but is also of profound significance to Australia and the world. It is around ten times the age of Stonehenge and four times the age of the Lascaux cave art in France. It is inconceivable that the British or French would allow such a risk to their cultural heritage, and it is hard to imagine that sites of cultural importance to white Australia would be treated in this way.