NEWCASTLE CLIMATE CHANGE RESPONSE
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    • Presenters >
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      • Jacquie Svenson
      • Jeremy Leibman
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        • Callan Lawrence
        • Callen Newby
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        • Erin Killion
        • Frances O'Brien
        • Garry Derkenne
        • Greg Mullins
        • Harrison Callen
        • Heather Stevens
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        • Jo Lynch
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        • Dr Kathleen Wild
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        • Nissa Lee Phillips
        • Dr Patrice Newell
        • Peter Brennan
      • Presenters Q-Z >
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        • Revd Robyn Fry
        • Samantha Mella
        • Dr Sharlene Leroy-Dyer
        • Siobhan Isherwood
        • Sophie Nichols
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Newcastle Climate Change Response Inc.Submission to Council’s Climate Action Plan 2020-2025

31/8/2020

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​Newcastle Climate Change Response Inc.
Submission to Council’s Climate Action Plan 2020-2025

(“the Plan”)
In general Newcastle Climate Change Response Inc. endorses the actions taken by CN to reduce its own (operational) emissions, and these are to be commended. However, when these emissions are only 0.6% of City-wide emissions (2.5% when Summer Hill Waste Management Centre is included) against a total of 3.84m Tonnes across the LGA (business, residential, educational and operational), and 2 billion tonnes of CO2e emissions originate from Hunter coal exports worldwide, there are key ways the current Climate Action Plan needs to be strengthened so that we are to genuinely play our unique role in stopping global warming.

Here is NCCR Inc.’s feedback on the Plan.
Do you support the vision?: YES (but it needs some work).

Do you have any feedback on the proposed Targets?
:
YES: The Plan needs to include Council-wide emissions reduction targets, not mere implementation targets (e.g. % renewable energy).
We need to achieve net zero CO2e emissions city-wide (including business, residential, education & Summer Hill, and including gas) by 2030, which means a cut of 3.84 million tonnes (Council's current city-wide emissions, assuming those 2008 figures are still correct of course. We note the out of date nature of the figures included) plus emissions from natural gas (which are omitted from the Plan entirely).

​Do you have any feedback on the proposed timeframe to achieve Net Zero Emissions for CN?:
YES: As above, to be consistent with actions that are to have a 2/3 chance of the Earth staying below 1.5 degrees C of warming above pre-industrial levels1, Council’s target needs to be Net Zero Emissions by 2030, citywide.

Do you have any other feedback on the Plan?:
YES:
  1. Business emissions - Noting that in our council area 70-83% of emissions are from business (and mostly the top 20), cutting these must be a major, funded, detailed part of the plan (beyond the aspirational graph Chart 10, pathways for which are not detailed anywhere in the Plan!).
  2. Council must take its unique opportunity to massively impact global emissions falling to safe levels by working with Councils & industry across the region to lead our fast & just transition away from coal mining & exports. When 2b tonnes of global CO2e emissions originate from our port, this MUST be part of Council's work plan. Council has proved with the Plan that it can cut its own emissions, but these were already tiny: to make real impact, we must also work to help get our region out of coal.

Do you have suggestions on how CN can work with the community to support the transition to a net zero emission City?:
YES: Cultural & fiscal incentives to business to get those business emissions DOWN. Compulsory reporting; awards, recognition & rate cuts for those that do the right thing; seminars & support for those that are still learning how (see for example the Hunter SDG Taskforce and the Carbon Neutral Adelaide Awards https://s3-ap-southeast-2.amazonaws.com/cna-public-assets/general-downloads/Carbon-Neutral-Adelaide-Awards_Booklet_2019.pdf.); a climate safe procurement & tender policy & more charging points for commercial (& private) electric vehicles.

Happy to discuss.
Regards

Jacquie Svenson
Co-Convenor
For Newcastle Climate Change Response Inc.


1 See ClimateWorks Australia 2020: Decarbonisation Futures: Solutions, Actions & Benchmarks for a Net Zero Emissions Australia. Retrieved from https://www.climateworksaustralia.org/wp-content/uploads/2020/04/Decarbonisation-Futures-March-2020-full-report-.pdf

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NARRABRI GAS PROJECT (SSD 6456) - Submission to supplementary material

21/8/2020

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Narrabri Gas Project - Submission to supplementary material by Alec Roberts

​21 August 2020
Office of the Independent Planning Commission NSW
Level 3, 201 Elizabeth Street, Sydney, NSW 2000
P: (02) 9383 2100 E: [email protected]
 
Dear Independent Planning Commission,
 
This is a submission objecting to the Narrabri Gas Project in accordance with the Commission’s ‘Additional Material’ policy[1] and in response to the following new material provided to the Commission:
  • the document entitled ‘Submission to IPC following public hearing’ (including attachments), provided by the Applicant on 10 August 2020[2], and
  • the Department’s ‘Response to Independent Planning Commission Questions’, provided to the Commission on 14 August 2020

Thank you for the opportunity to provide comment on this designated additional material for the Narrabri Gas Project (NGP) and taking the time to consider my submission.
 
Most of my response to the designated additional material is from my original submission.[3]  However, as this submission must specifically relate to the new material only, parts of the original submission will be quoted here as required to address the new material only.
Please note that this document does not supersede my original submission but is in addition to it.
Similar to my original submission, this submission will focus on the areas of economics, gas supply and demand, climate change impacts, gas as a transition fuel and alternative fuels to natural gas. However, comment will be provided in association with Groundwater Impacts and Ecological Impacts – Koalas.
 
Groundwater - Assertions that the Project is located in a major recharge zone for the GABSantos refuted the assertion that the Project is in a major recharge area of the GAB, and that this poses an unacceptable risk to aquifers of the GAB.
In my original submission I stated:
“The Pilliga Sandstone Aquifer is a high-quality shallow groundwater that local communities rely on for water for stock, domestic and irrigation purposes and is one of the main aquifers in the southern Great Artesian Basin.  The Pilliga Sandstone is also the main outcropping aquifer in the Pilliga forest region within the project area, and this region and along with outcropping along the Warrambungle Range are recharge beds for the Great Artesian Basin in NSW.[4] [5]  A near-surface aquifer, the Namoi Alluvium, is also a major water resource for agriculture in the region. Together these form the main source of water these communities rely on for their livelihoods.
The contamination of groundwater is a major environmental risk with Coal Seam Gas, with the major potential contamination from ‘produced water’ which is pumped from the underlying coal seams to depressurize the seams and allow gas to be released and be extracted.  CSG produced water is typically of poor quality due to being located within the coal seams.  The Narrabri region produced water is high in salinity and contains high levels of heavy metals, boron and fluoride and presents a major risk to groundwater contamination in the area.
Given a number of leaks and/or spills of produced water have already occurred within the 70 appraisal and exploration wells in the area, there is a strong likelihood with 850 wells that significant leaks and/or spills of produced water will occur throughout the life of the project risking contamination of the aquifers / recharge beds for the Great Artesian Basin and affecting the livelihoods of those that depend on this valuable resource.” 3
The potential contamination of the aquifers flies in the face with the assessment that the project will “not result in significant impacts on people or the environment”.
 
Ecology – KoalaSantos stated (in quoting the NGP EIS) that the impacts of the Project on the current Koala population will not lead to a long-term extinction of a viable local population.
In my original submission I stated:
“The Pilliga Forest has been classified as a priority area for koala conservation.  Energy and Environment Minister Matt Kean recently set a goal of doubling the number of koalas by 2050 in a bid to defy projections the marsupial could become extinct in the wild in NSW by mid-century.[6]  The Narrabri Gas project will result in the fragmentation of 85,000 hectares of the Pilliga Forest.  Fragmented islands of koala habitat such as will result from this development which will result in unhealthy koala populations.  Koalas need wide corridors to spread out to ensure effective breeding.  Koala corridors are vital and are recognised generally as such in the new Koala SEPP and acknowledged by the NSW Chief Scientist (2016):
“Koala populations need large areas of connected habitat to maintain their viability. Habitat loss and fragmentation has resulted in population decline and has been identified as a significant threat to the species persistence in NSW.”[7]
Recent studies within the project area suggest a dramatic decline in koala populations. Surveys of the Pilliga forests in the 1990s suggest that the forests were carrying the largest population of koalas west of the Great Dividing Range in NSW, with the population estimated at 15,000. Repeat surveys within the Pilliga forests show a decline of over 80% since the 1990s.7
The impact of extreme weather events such as drought and extreme heatwaves on koalas is expected to increase with climate change and may also exacerbate other threats such as disease.[8] The Pilliga forest koalas are likely to have faced extreme (but less frequent and long) heat events in the past and responded by retreating to creek lines with either available free water or a higher moisture content in the leaves of their food trees. However, land clearing within and on the periphery of the forests and from road construction since the early 1900s has resulted in creeks within the Pilliga forests silting up. Habitats that would have once likely functioned as a refuge during times of drought are now highly disturbed and are unlikely to provide the required level of protection for koalas.7
The planned significant fragmentation of habitat by the Narrabri Gas project will exacerbate the problems caused by earlier land clearance and may lead to the local extinction of the Koala. The potential local extinct of a vulnerable species appears to contradict the assessment that the project will “not result in significant impacts on people or the environment”.3
 
 
Why the Project is needed 
Santos stated that a “growing component of energy demand will need to be met by natural gas supply to complement renewables growth and battery storage in Australia as ageing coal-fired power plants close over coming decades.”
 
The use of gas in electricity production has reduced in recent years and modelling of the future electricity grid and further evidence has indicated that it is unlikely that gas will play a major role in the transition from coal-fired power plants to renewable energy and storage.
In my original submission, I noted that,
“the electricity market has already moved away from gas, with a 59% decline in usage in the National Electricity Market since 2014, whilst renewable energy has increased by 25% during the same period.[9] Furthermore, flexible gas plants already in the grid are running well below capacity.[10] AEMO forecast that increasing renewable generation developments in the NEM are expected to continue to drive down system normal demand for gas-powered generation. [11]
The AEMO modelled the future electricity grid in its Integrated Systems Plan.[12] [13]  The results showed for all scenarios that the transition from coal to renewable energy would not be via gas.10  The role of gas would be reduced with a decline in gas generation through to 2040.9  The report notes that to firm up the inherently variable distributed and large-scale renewable generation, there will be needed new flexible, dispatchable resources such as: utility-scale pumped hydro and large-scale battery energy storage systems, distributed batteries participating as virtual power plants, and demand side management.12 13  It also noted that new, flexible gas generators such as gas peaking plants could play a greater role if gas prices materially reduced, with gas prices remaining low at $4 to 6 per GJ.13  However this is unlikely as gas prices have tripled over the past decade and expected NSW gas prices are over 60% more than this price.10 [14]   AEMO noted that the investment case for new gas-powered generation will critically depend on future gas prices, as gas-powered generation and batteries can both serve the daily peaking role that will be needed as variable renewable energy replaces coal-fired generation.  In their 2020 Gas Statement of Opportunities report, AEMO predicted that as more coal-fired generation retired in the long term, gas consumption for gas-powered generation in the National Electricity Market was forecast to grow again in the early 2030s, recovering to levels similar to those forecast for 2020.11   However, in a later report, AEMO determined that by the 2030s, when significant investment in new dispatchable capacity is needed, new batteries will be more cost-effective than gas-powered generation. 13  Furthermore, the commissioning of the Snowy 2.0 pumped hydro project in 2026 will result in less reliance on gas-powered generation as a source of firm supply.11”3
“AEMO noted that stronger interconnection between regions reduces the reliance on gas-powered generation, as alternative resources can be shared more effectively. 13  The expansion network interconnection enables the growth of variable renewable energy without a significant reliance on local gas generation.[15]  Supporting this assertion, the AEMO announced a series of actionable transmission projects including interconnector upgrades and expansions and network augmentations supporting recently announced renewable energy zones.[16]  13  AEMO noted that as each of these new transmission projects is commissioned, the ability for national electricity market regions to share resources (particularly geographically diverse variable renewable energy) is increased, and therefore demand for gas-powered generation is forecast to decrease.11 The Marinus Link is forecast to be commissioned in 2036, with surplus renewable generation from Tasmania then being available to the mainland National Electricity Market, which would see further declines in gas-fired generation, despite continuing coal-fired generation retirements.11 ”3
Therefore, it is highly unlikely that a “growing component of energy demand will need to be met by natural gas supply to complement renewables growth and battery storage in Australia as ageing coal-fired power plants close over coming decades”.
 
Santos quoted from the 2020 ISP that
“GPG can provide the synchronous generation needed to balance variable renewable supply, and so is a potential complement to storage. The ultimate mix will depend upon the relative cost and availability of different storage technologies compared to future gas prices.”
In my original submission, I stated,
“However, the current installation of synchronous condensers in South Australia and other eastern states to increase system strength and stabilise the electricity network will reduce the need for gas-fired generators acting in the role of synchronous generators as more renewables enter the grid.[17]  Ancillary services are likely to utilise battery storage and synchronous condensers in the future and no longer require the use of gas-powered generation.”3
 
Santos stated that, “Additional gas is required in the domestic gas market to meet residential, commercial and industrial gas demand.”
Gas demand has been declining in recent years and predictions are that gas demand will not increase in the future and may decrease, therefore it is unlikely that additional gas will be required in the domestic gas market to meet residential, commercial, and industrial gas demand.
In my original submission, I noted that,
“demand for natural gas in NSW has declined over recent years. From 2014 to 2018, annual consumption of natural gas in NSW fell by 15 per cent, with the major contributor of this fall in consumption being the reduction in the use of gas for power generation.[18] Whereas domestic demand for gas has fallen for use in manufacturing by 14%, it has dropped by a staggering 59% for power generation by since 2014. 9 “
ACCC recently stated that “overall consumption of gas in the east coast was largely unchanged over the first five months of 2020 relative to 2019”[19] and that the COVID-19 pandemic has not had a material effect on the overall level of production or consumption in the East Coast Gas Market. However, they stated that it is unknown whether the contraction in economic activity brought about by the COVID-19 pandemic will result in a decline in domestic and/or international demand for gas in 2021.
 
Commercial and Industrial (C&I) gas users utilise gas for applications such as a heat source for boilers and furnaces, for producing steam, or for drying processes, and as a feedstock to produce fertilisers, explosives, chemicals, and plastics. ACCC reported that a number of suppliers expected Gas Powered Generation (GPG) and C&I demand to be lower in 2020 and that many C&I users reported that they are slowing production due to the COVID-19 pandemic which raised the potential for significant adverse consequences for these users in having to pay for gas that they cannot use or on-sell (with take or pay contract obligations). ACCC concluded that there is now a considerable degree of uncertainty surrounding the demand for gas by gas users (non GPG) following the COVID-19 pandemic and the impact this has had on economic activity, both domestically and internationally.19
 
Whereas 2019 was somewhat of an anomalous year with failures in Coal Powered Generation resulting in additional GPG being utilised, the ACCC reported that GPG demand over the first five months of 2020 was 36% lower than over the same period in 2019.
In my original submission I noted that AEMO forecast that, “demand for gas-powered generation is predicted to continue to fall by over 85% from 2019 levels by 2028.[20]” 3
 
In my original submission I noted that,
“The ACT is planning to go gas free by 2025.  This is expected to reduce their overall emissions by 22%.  As part of the ACT Climate Change Strategy 2019-2025, all government and public-school buildings will be completely powered by 100% renewable energy eliminating the need for natural gas.  The ACT has also removed the mandatory requirement for new homes built in the ACT to be connected to the mains gas network and will begin to introduce new policies to replace gas appliances with electric alternatives.  Some 14% of residents have already converted over to 100% electric. [21]” and that “There are moves in other jurisdictions to remove the mandatory requirement for a gas connection in new developments such as in South Australia.”3
 
In my original submission I noted that,
“AEMO forecasts further reductions in gas use as consumers fuel-switch away from gas appliances towards electrical devices, in particular for space conditioning. The Commonwealth and NSW Government are exploring options to free-up gas demand through electrification, fuel switching and energy efficiency. [22]
Fuel switching from gas appliances towards electrical devices can often be more economic. A 2018 study of household fuel choice found that 98% of households with new solar financially favoured replacement of gas appliances with electric.  With existing/no solar 60-65% of households still favoured replacement of gas appliances with electric. [23] 
In the residential sector, for example, reverse-cycle air-conditioning is expected to reduce gas demand that could have arisen due to gas heating.[24]”3
 
Therefore, it is unlikely that additional gas will be required in the domestic gas market to meet residential, commercial, and industrial gas demand.
 
Downward pressure on NSW gas prices and more jobs 
Santos quoted the ACIL Allen analysis findings that,
“By the later 2020s and beyond, the Project will be among the lower cost resources.”
As lower cost supplies dry up the higher cost supplies will be utilised including NGP.  NGP will only be “among the lower cost contingent resources” because lower cost supplies will be less available.
However, in my original submission I noted that,
“according to an AEMO commissioned report, gas extraction costs from this field will be over twice the cost of other existing fields in the eastern gas region.9 According to AEMO, the Narrabri Gas Project is ranked 41 out of 51 actual and undeveloped gas projects and there are 18 developed and 22 undeveloped gas projects with lower estimated production costs than the Narrabri Gas Project. 18
 
Santos quoted the ACIL Allen analysis findings that,
“The Project can place downward pressure on gas prices in NSW, potentially by between 4 per cent and 12 per cent from 2025 onwards. Even if 40 TJ per day is provided to establish a local fertiliser plant, a 3 per cent to 9 per cent price reduction in Sydney is estimated.”
It should be noted that this analysis is based on the spot market only under pure market conditions and not Gas Supply Agreement (GSA) prices.  As noted by ACIL Allen, “Most wholesale gas is sold and transported under bilateral agreements between producers, pipeline owners, retailers and major users.” “the eastern Australian market continues to operate primarily based on long-term bilateral contracts, with the spot markets used largely to manage operational and contract imbalances” and “The spot prices provide an indication of short-term and seasonal variations in the supply demand balance and bear little relationship to long-term contract prices.” And that “Spot prices are a good indication of possible prices in short term contacts of up to 18 months. They are not a good indication of prices in longer term gas sales contracts.“  Information obtained by the ACCC from gas suppliers in the east coast indicated that suppliers were unlikely to use expected future LNG spot prices to assess prices in domestic contracts with a term beyond three years.14
 
ACIL Allen further noted, “Most of the gas traded in the east Australian gas market is under long term gas sales agreements. It is difficult to model the impact of contracts on average prices of gas at different points in the market as the terms and prices contained in these gas sales agreements are not public.”
ACIL ALLEN noted that future prices in GSAs are likely to be driven primarily by:
— the marginal cost of undeveloped, contingent, and prospective resources after around 2026.
— longer term LNG price movements which in turn will be influenced by movements in oil prices, global economic conditions, and global LNG production capacity
— transmission pipeline capacity and the efficiency of the transmission system and capacity trading
— the level of competition in the eastern Australian gas market.
ACIL Allen also noted that with the commissioning of LNG import terminals “the pricing dynamics in the eastern Australian market will increasingly be influenced by LNG import pricing, and away from export parity pricing.”
In my original submission I noted,
“The marginal source of supply (the final source of gas supply needed to meet demand) is likely to set floor price in negotiations between gas suppliers and buyers in NSW.[25]  This cost of production together with transmission costs to Sydney is currently some 20% less than the proposed Narrabri Gas Project.  Furthermore, future marginal source of supply may be satisfied by imported LNG (where wholesale gas prices would be set to import parity levels) or through existing or developed lower cost domestic supplies (such as noted by AEMO). 18  Under these circumstances, the Narrabri Gas Project would not provide the marginal source of supply for wholesale gas in NSW, and is thus unlikely to exert any influence over wholesale gas prices in NSW over the near or long term and therefore not contribute to any reduction in domestic gas prices.”3
 
The ACIL Allen modelling showed an overall increase in gas prices of over 30% in the medium term rising to over 40% in the longer term.  The modelling indicated that the NGP would reduce the amount of increase in gas prices somewhat than without it for the spot market.
However, the estimated NGP production costs of $6.40/GJ used in the modelling that are based on ACIL Allen’s internal data are below the AEMO estimates that the NGP will have costs at a minimum $7.28/GJ.9 Using the AEMO estimates may give a different result with a reduced ability to “place downward pressure on gas prices”.
 
How these modelling results would potentially affect real gas prices over time for such a small potential reduction in gas price increase is drawn into question.  Factors such as export parity, import parity, producers’ marginal costs of production are more likely to affect contract prices and thus overall gas prices.  Therefore, this analysis may not be able to show whether the “Project can place downward pressure on gas prices in NSW”.
 
Santos quoted the ACIL Allen analysis findings that,
“Because of Santos’ commitment that all the gas produced from the Project will be available for the domestic market, a new competitive source of supply close to Sydney is expected and this will lead to more competitive prices on long term gas contracts, particularly into the late 2020s and 2030s.”
 
ACIL Allen’s analysis suggested that delivery of NGP gas delivered to Sydney would be competitive with Queensland supplied gas.  However, this assumed NGP production costs of $6.40/GJ.  If the AEMO estimate of a minimum production cost of $7.28/GJ is used then NGP is no longer competitive with Queensland supplied gas to Sydney.9
As for any changes to the level of competition, this is not an open market and has little visibility, it has very limited numbers of producers (5) (of which Santos is already one), a limited number of retailers (6), and an even limited number of pipeline owners (2), and GSA contract prices which make up the majority of gas demand are undisclosed. 
The ACCC noted that the response of the LNG producers to increased domestic demand in 2019 highlighted their ability to divert gas into the domestic market when required and suggested Queensland gas could meet forecast demand should risks associated with southern states’ production arise. They also noted that, “The capacity of LNG producers to seemingly increase domestic supplies to keep the East Coast Gas Market supplied with just enough gas may also point to broader competition and market power concerns.”14
 
In my previous submission I noted that,
“Domestic gas prices in Australia have remained at levels far in excess of international parity prices.  Whilst prices have fallen somewhat, they have not fallen by nearly as much as those in Asia or Europe.  Domestic prices have remained some 30-40% higher than ACCC calculated export parity prices (a.k.a. "netback" prices).[26]”3
Of increasing concern to the ACCC is the widening divergence between domestic prices offers and the LNG netback price. Domestic prices in Queensland now diverge from export parity LNG netback prices by more than $2/GJ. ACCC find this extremely concerning, as it raises serious questions about the level of competition among producers in the East Coast Gas Market.19
Of even further concern to the ACCC is that since September 2019 there have been 18 LNG spot cargoes sold by Queensland LNG producers, with the prices received for these spot cargoes well below the prices being offered to the domestic market.19
The ACCC concluded that the spot cargo sales, together with the divergence that has occurred between LNG netback prices and domestic prices, brings into question what is driving the pricing strategies of LNG producers and other suppliers in the East Coast Gas Market, and the extent to which it reflects a more fundamental lack of competition amongst suppliers.
 
The problems with competition in the Australian gas market are complex and there is a lack of understanding on how these could be resolved.19  It is unlikely that projected reductions in the increases in gas spot prices by the NGP would have a significant impact on competition in the East Coast Gas Market.
 
The role of natural gas in a low-carbon economy 
Santos stated that “Some submitters suggested that the Project should not be approved as it would contribute to an unacceptable increase in greenhouse gas emissions and that any forecast shortage in energy demand could be met by renewable sources of energy generation.”
 
As stated in my original submission,
“To address the issue of dangerous climate change, Australia, along 196 other parties, is a signatory to the Paris Agreement, which entered into force on 4 November 2016. The Paris Agreement aims to strengthen the global response to the threat of climate change, by:
Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change.[27]
NSW Climate Change Policy Framework details the NSW Government’s objective to achieve net-zero emissions by 2050.[28] This long-term objective “sets a clear statement of government’s intent, commitment and level of ambition and sets expectations about future emissions constraints that will help the private sector to plan and act.” The Policy Framework states that the NSW Government will investigate how to embed consideration of climate change mitigation and adaptation across government operations including service delivery, infrastructure, purchasing decisions and regulatory frameworks.  Furthermore, it states that Agencies will undertake additional policy investigation for sectors with significant opportunities and risks, including primary industries emissions and adaptation (Department of Primary Industries).
The IPCC report provides an estimate for a global remaining carbon budget of 580 GtCO2 (excluding permafrost feedbacks) based on a 50% probability of limiting warming to 1.5 degrees relative to 1850 to 1900 during and beyond this century and a remaining carbon budget of 420 GtCO2 for a 67% chance. [29]
Committed emissions from existing and proposed energy infrastructure represent more than the entire carbon budget that remains if mean warming is to be limited to 1.5 °C and perhaps two-thirds of the remaining carbon budget if mean warming is to be limited to less than 2 °C.  Estimates suggest that little or no new CO2-emitting infrastructure can be commissioned, and that existing infrastructure may need to be retired early (or be retrofitted with carbon capture and storage technology) in order to meet the Paris Agreement climate goals.[30]
Australia’s remaining emission budget from Jan 2017 until 2050 for a 50% chance of warming to stay below 1.5C warming relative to pre-industrial levels was estimated to be 5.5 GTCO2e.29 Adding the GHG emissions expended in 2017[31], 2018[32], and 2019[33], this leaves just 3.8 Gt CO2e remaining as at December 2019.  This leaves 6-7 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C.  Therefore, at current emissions rates, Australia will have exceeded its carbon budget for 2050 by 2026.
It therefore follows that no new fossil fuel development in Australia that is not carbon neutral, including the Narrabri Gas Project, that is estimated to result in 94.2 million tonnes of greenhouse gases over the life of the project, can be permitted because its approval would be inconsistent with the remaining carbon budget and the Paris Agreement climate target.”3 It follows that the NGP would contribute to an unacceptable increase in greenhouse gas emissions.
Santos further states “These submissions ignore the critical role of natural gas in the transition to a low-carbon economy, recognised by the International Energy Agency, or the relative contribution of the Project to Australia’s overall greenhouse gas (GHG) emissions, which is not significant.”
In my original submission I noted that,
“Natural gas has often been touted as the “transition fuel” for the electricity sector to replace coal’s greenhouse gas emissions and eventually paving the way for an emissions free future for Australia.  This has been used as an argument for the approval of the Narrabri Gas project. This concept is out of date and I believe incorrect. It is simply too expensive and too emissions intensive to be so.  Furthermore, the concept is based on the replacement of coal with gas which is effectively for electricity generation only.  Gas is also utilised for heat through combustion both industrially and domestically producing greenhouse gases.”
The response to the role of natural gas in the transition to a low-carbon economy can be found in my response to the following sections “Why the Project is needed”, “Greenhouse gas and climate change - Reservoir CO2 production”, and “Greenhouse gas and climate change – Fugitive emissions”
 
Greenhouse gas and climate change - Reservoir CO2 production 
As noted in my original submission the Narrabri Gas field has high levels of CO2 which will be vented into the atmosphere as part of gas extraction adding to the fugitive emissions from the implementation of this project.[34] Santos disputes Dr Grogan’s findings on the high levels of fugitive CO2 emissions from NGP.  I suggest you review Dr Grogan’s work with respect to the NGP; Dr Grogan is an independent expert in the field with specific knowledge on CO2 processes in geological formations.[35]
Santos claims Narrabri gas has a very low CO2 content compared to "some existing sources of natural gas in the east coast gas market" but does not say where.  As noted, the predicted fugitive CO2 gas emissions are high (up to 24%).  I would like to see what these existing sources are and are they being used?
Santos also claim that they will " beneficially re-use CO2 where relevant in further support of achievement of emissions reduction targets" but appear not to be capturing and reusing any of the significant CO2 fugitive emissions resulting from gas extraction from the Narrabri Gas Project.
Finally, with respect to CO2 fugitive emissions, Santos state that the NGP will be subject to the GHG Safeguard Mechanism to manage their emissions (including CO2 fugitive emissions).[36] However, this is unlikely to have any positive effect on emissions, as less than 9% of companies subject to the Safeguard Mechanism have had to surrender carbon credits in 2018-2019 due to the scheme’s weak rules.[37]
 
Greenhouse gas and climate change – Fugitive emissions 
Santos disputes that the Narrabri Gas Project EIS had underestimated the predicted fugitive methane emissions.  Santos uses an “allowed” factor in its EIS of 0.0058% of methane fugitive emissions, according to the Australian Government National Greenhouse and Energy Reporting (Measurement) Determination 2008, clause 3.72.
As noted in my original submission,
“The CSIRO report “Fugitive Greenhouse Gas emissions from Coal Seam Gas Production in Australia” [38] noted that fugitive emissions for Natural Gas in Australia are estimated to be 1.5% of gas extracted.  It should be noted that if fugitive emissions exceeded 3.1% then the emissions intensity would match that of coal (due to the fact that methane is 86 times more powerful as a greenhouse gas than CO2 over 20 years and 34 times more powerful over a 100-year time period).[39] They also noted that unconventional gas industry such as Coal Seam Gas would result in greater levels of fugitive emissions than the conventional gas industry.”
Methane leaks from natural gas production can make the process nearly as carbon intensive as coal.  Therefore, Santos’s claim that “If the natural gas produced by the Project was simply used to displace coal-fired power generation in the Australian energy market, it would be expected that this would also reduce CO2 emissions.” may not necessarily be true due to fugitive emissions (both methane and CO2).
 
Santos states that
“demand will remain irrespective of whether the Project is approved and, if the Project is refused, the demand will simply need to be met by other energy sources including but not limited to LNG import into NSW via approved and planned facilities. These alternative sources of gas could be expected to have higher emissions impacts due to transportation requirements including liquefaction, transportation, regasification and other sources of emissions.”
 
Whereas imported gas via gas import terminals may have reasonably high emissions due to the liquefaction process, my original submission detailed other alternative sources of gas that had significantly lower emissions than the NGP and in the long term could replace the need for new gas such as proposed by the NGP.
It should be noted that these technologies Green Hydrogen and Biogas and Biomethane not only look to transition electricity generation away from natural gas but also for other uses such as combustion for heat.
From my original submission,
“Hydrogen
Hydrogen is a colourless, odourless, non-toxic gas that is an excellent carrier of energy and can be used for a broad range of energy applications including as a transport fuel, a substitute for natural gas and for electricity generation.[40] Hydrogen gas can be produced from water in a process known as electrolysis, and when powered by renewable energy, the hydrogen produced is free from carbon emissions, making it an attractive way to decarbonise transport, heating and electricity generation.40
AEMO stated that, “Hydrogen has the exciting potential to become an alternative energy storage technology and a new export commodity for Australia” which could be used to help decarbonise the domestic heat, transport and the industrial and commercial sectors in Australia and noted that development of the hydrogen industry would potentially impact both natural gas and electric demands.24 12
Several developments involving green / renewable hydrogen are either planned or underway in Australia.
AEMO highlighted the potential for green steel production in Australia due to abundant renewable resources and the increased demand for low emissions industrial commodities worldwide. 24 ‘Green steel’ can be made via a direct reduction process which uses hydrogen (made from renewable energy) as the heat source and reducing agent to produce pig iron. The by-product of the iron reduction process using hydrogen is water, rather than carbon dioxide in conventional steel making. Renewable energy is then used by an electric arc furnace to produce low-emissions green steel.
The Arrowsmith Hydrogen Project, which will be built at a facility in the town of Dongara, located 320km north of Perth, will utilise dedicated onsite renewable energy 85MW of solar power, supplemented by 75MW of wind generation capacity to generate 25 tonnes of green hydrogen a day and will be operational in 2022.[41]
ATCO’s Clean Energy Innovation Hub, located in Jandakot in Western Australia, is being used to trial the production, storage and use of renewable hydrogen to power a commercial-scale microgrid, testing the use of hydrogen in different settings and applications including in household appliances.[42]  This includes optimising hydrogen storage solutions, blending hydrogen with natural gas and using hydrogen a direct use fuel.  Green hydrogen will be produced from on-site solar using electrolysis, fuelling a range of gas appliances and blending hydrogen into the natural gas pipeline.
The $3.3 million development project will evaluate the potential for renewable hydrogen to be generated, stored, and used at a larger scale. ATCO aims to assess the practicalities of replacing natural gas with hydrogen at a city-wide scale across a municipality.[43]
The new chair of the Australian Energy Regulator, Clare Savage recently stated:
“The national gas industry could also undergo significant change as some jurisdictions move towards a zero carbon emissions policy. This could have significant consequences for the future of gas pipeline networks. In response, the AER recently supported the future recovery of Jemena’s investment in trialling the production of hydrogen from renewable energy for injection into its Sydney network. If hydrogen trials such as Jemena’s prove successful, the natural gas networks could be re-purposed to distribute hydrogen. If not, the economic life of the assets could be limited.” [44]
 
Biogas and BiomethaneBiogas is a renewable energy source, that is continuous and dispatchable, reliable, and local source of energy. Biogas can be converted into heat and/or electricity using boilers, generators or with Combined Heat and Power units.[45]  Biogas also provides an alternative route for waste treatment and, as such, can help divert waste from landfill. Biogas consists primarily of methane and carbon dioxide, with trace amounts of other gases such as hydrogen sulphide, water vapour, oxygen, and ammonia.[46]  Biogas can also be upgraded into biomethane: a renewable gas that can replace natural gas with a chemical composition very similar to natural gas. Biomethane is produced from the separation of methane from the other gases. 46
Biogas and its industry offer many benefits:
  • Biogas is a renewable energy source that assists the decarbonisation of the economy. A study of the replacement of natural gas by biomethane in France reduced GHG emissions by greater than 85%. 
  • Biogas is a secure, continuous and dispatchable source of energy that can contribute to national energy supply.
  • Biogas also provides an alternative route for waste treatment and, as such, can help divert waste from landfill.
  • The biogas industry supports local economies and regional communities, creating jobs, and offering new income sources, particularly for farmers.
  • Biogas transformed into biomethane is a renewable gas that can replace natural gas, and can be used in homes for cooking, heating, and hot-water, or as a fuel for gas vehicles. It can be injected into the gas grid or used directly on-site. As biomethane has similar characteristics to natural gas, its injection into the gas grid does not require any adaptation of the existing infrastructure (neither the gas grid nor customer equipment connected to it). This is an opportunity for the gas and transport sectors to further assist the energy transition. 46
A landmark report commissioned by Bioenergy Australia last year identified the total estimated biogas potential to be 371PJ (103TWh) of available energy, which is enough to decarbonise industrial, commercial, and residential gas users currently supplied by distributed gas networks across Australia.[47]
Australian business, industry and utilities recently signed an open letter to the Commonwealth Government advocating for biomethane to be injected into the gas distribution networks to enable the lowest cost transition to a decarbonised energy market and address a number of challenges including:
  • Provide complementary reliable and flexible renewable resources for variable renewable energy.
  • Allow heavy industry dependent on process inputs and high-quality heat to decarbonise using existing gas connections.
  • Provide a pathway for Heavy vehicle decarbonisation.
  • Allow domestic gas customers to decarbonise their energy supply using existing networks and appliances.[48]
 
Both Renewable Hydrogen and Biogas/Biomethane can displace or replace natural gas as a fuel significantly reducing GHG emissions.  These technologies show promise in Australia with the resources available locally.  Once developed these would see assets such as the Narrabri Gas project left stranded.”3
 
 
 
Due to the above reasons I strongly object to the Narrabri Gas Project. Thank you again for the opportunity to comment. I look forward to hearing from you regarding this submission.
 
Yours sincerely,
 
Alec Roberts
 
 
 


[1] IPCN (n.d.) Policies - Additional material. Retrieved from https://www.ipcn.nsw.gov.au/policies
 

[2] Santos (2020, August 10) Narrabri Gas Project (SSD 6456) Submission to IPC following public hearing.  Retrieved from https://www.ipcn.nsw.gov.au/resources/pac/media/files/pac/projects/2020/03/narrabri-gas-project/correspondence/santos-submission/200810-santos-_final-submission-incl-attachments.pdf
 

[3] Roberts, A. (2020, August 3) Submission on Narrabri Gas Project - Alec Roberts. Retrieved from https://www.newcastleclimatechangeresponse.org.au/news/submission-on-narrabri-gas-project-alec-roberts

[4] CSIRO (2018, August) Potential water impacts of coal seam gas in the Pilliga Sandstone.  Retrieved from https://gisera.csiro.au/wp-content/uploads/2018/08/18-00384_GISERA_FACTSHEET_SGW-GABFluxFinalReport2pp_WEB_180807.pdf
 

[5] Sreekanth, J., Cui, T., Pickett, T. & Barrett, D. (2017) Uncertainty analysis of CSG-induced GAB flux and water balance changes in the Narrabri Gas Project area. CSIRO, Australia. Retrieved from https://publications.csiro.au/rpr/download?pid=csiro:EP173269&dsid=DS3
 

[6] Hannam, P. (2020, July 26). Matt Kean aims to double koala population by 2050.  Retrieved from https://www.smh.com.au/environment/conservation/matt-kean-aims-to-double-koala-population-by-2050-20200725-p55fdc.html

[7] NSW Chief Scientist & Engineer (2016, December). Report of the Independent Review into the Decline of Koala Populations in Key Areas of NSW.  Retrieved from https://www.chiefscientist.nsw.gov.au/__data/assets/pdf_file/0010/94519/161202-NSWCSE-koala-report.pdf
 

[8] Lunney, Daniel & Crowther, Mathew & Wallis, Ian & Foley, William & Lemon, John & Wheeler, Rob & Madani, George & Orscheg, C. & Griffith, Joanna & Krockenberger, Mark & Retamales, Melissa & Stalenberg, Eleanor. (2012). Koalas and climate change: a case study on the Liverpool Plains, north-west NSW. 10.7882/FS.2012.022.

[9] Robertson, B. (2020, July 23). IEEFA update: Australia sponsors a failing gas industry. Retrieved from https://ieefa.org/ieefa-update-australia-sponsors-a-failing-gas-industry/

[10] Morton, A. (2020, March 8). 'Expensive and underperforming': energy audit finds gas power running well below capacity.  Retrieved from https://www.theguardian.com/environment/2020/mar/08/expensive-and-underperforming-energy-audit-finds-gas-power-running-well-below-capacity
 

[11] AEMO (2020, March). Gas Statement of Opportunities, March 2020, For eastern and south-eastern Australia. Retrieved from https://aemo.com.au/en/energy-systems/gas/gas-forecasting-and-planning/gas-statement-of-opportunities-gsoo
 

[12] AEMO (2019, December 12). Draft 2020 Integrated System Plan - For the National Electricity Market.  Retrieved from https://aemo.com.au/-/media/files/electricity/nem/planning_and_forecasting/isp/2019/draft-2020-integrated-system-plan.pdf?la=en
 

[13] AEMO (2020b, July 30). 2020 Integrated System Plan - For the National Electricity Market.  Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/final-2020-integrated-system-plan.pdf?la=en
 

[14] ACCC (2020, January) Gas inquiry 2017-2025 – Interim Report.  Retrieved from https://www.accc.gov.au/system/files/Gas%20inquiry%20-%20January%202020%20interim%20report%20-%20revised.pdf
 

[15] AEMO (2020c, July 30) 2020 ISP Appendix 2. Cost Benefit Analysis. Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/appendix--2.pdf?la=en

[16] Energy Source & Distribution (2020, July 30). AEMO reveals Integrated System Plan 2020. Retrieved from https://esdnews.com.au/aemo-reveals-integrated-system-plan-2020/
 

[17] Parkinson, G. (2020, May 25) Big spinning machines arrive in South Australia to hasten demise of gas generation. Retrieved from https://reneweconomy.com.au/big-spinning-machines-arrive-in-south-australia-to-hasten-demise-of-gas-generation-64767/
 

[18] Pegasus Economics (2019, August) Report on the Narrabri Gas Project. Retrieved from https://8c4b987c-4d72-4044-ac79-99bcaca78791.filesusr.com/ugd/b097cb_c30b7e01a860476bbf6ef34101f4c34c.pdf

[19] ACCC (2020, July) Gas inquiry 2017–2025 Interim report July 2020.  Retrieved from https://www.accc.gov.au/system/files/Gas%20inquiry%20July%202020%20interim%20report.pdf

[20] AEMO (2020, March 27) National Electricity & Gas Forecasting 2020 GSOO Publication. Retrieved from http://forecasting.aemo.com.au/Gas/AnnualConsumption/Total

[21] Mazengarb, M. & Parkinson, G. (2019, September 16).  ACT to phase out gas as it launches next stage to zero carbon strategy.  Retrieved from https://reneweconomy.com.au/act-to-phase-out-gas-as-it-launches-next-stage-to-zero-carbon-strategy-92906/
 

[22] Energy NSW. (2020, January 31). Memorandum of understanding, Retrieved from https://energy.nsw.gov.au/government-and-regulation/electricity-strategy/memorandum-understanding
 

[23] Alternative Technology Association (2018, July) Household fuel choice in the National Energy Market.  Retrieved from https://renew.org.au/wp-content/uploads/2018/08/Household_fuel_choice_in_the_NEM_Revised_June_2018.pdf

[24] AEMO (2020a, July 30). 2020 ISP Appendix 10. Sector Coupling. Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/appendix--10.pdf?la=en

[25] ACCC (2020, January) Gas inquiry 2017-2025 – Interim Report.  Retrieved from https://www.accc.gov.au/system/files/Gas%20inquiry%20-%20January%202020%20interim%20report%20-%20revised.pdf
 

[26] Long, S. (2020, February 27). Gas giants misled governments and it is costing Australian jobs, ACCC boss says.  Retrieved from https://www.abc.net.au/news/2020-02-27/gas-giants-misled-governments-accc-boss-rod-sims-says/12004254
 

[27] IPCC (2018). Global Warming of 1.5°C: An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty, Intergovernmental Panel on Climate Change.  Retrieved from https://www.ipcc.ch/sr15/
 

[28] OEH (2018). NSW Climate Change Policy Framework. Retrieved from https://www.environment.nsw.gov.au/-/media/OEH/Corporate-Site/Documents/Climate-change/nsw-climate-change-policy-framework-160618.pdf
 

[29] Meinshausen, M. (2019, March 19). Deriving a global 2013-2050 emission budget to stay below 1.5°C based on the IPCC Special Report on 1.5°C.  Retrieved from https://www.climatechange.vic.gov.au/__data/assets/pdf_file/0018/421704/Deriving-a-1.5C-emissions-budget-for-Victoria.pdf

[30] Tong, D., Zhang, Q., Zheng, Y., Caldeira, K., Shearer, C., Hong, C., Qin, Y., & Davis, S. J. (2019). Committed emissions from existing energy infrastructure jeopardize 1.5 °C climate target. Nature, 572(7769), 373-377. https://doi-org.ezproxy.newcastle.edu.au/10.1038/s41586-019-1364-3
 

[31] Climate Council (2018) Australia’s Rising Greenhouse Gas Emissions. Retrieved from https://www.climatecouncil.org.au/wp-content/uploads/2018/06/CC_MVSA0143-Briefing-Paper-Australias-Rising-Emissions_V8-FA_Low-Res_Single-Pages3.pdf
 

[32] Cox, L. (2019, March 14). Australia's annual carbon emissions reach record high.  Retrieved from https://www.theguardian.com/environment/2019/mar/14/australias-annual-carbon-emissions-reach-record-high
 

[33] DISER (2020, May) National Greenhouse Gas Inventory: December 2019.  Retrieved from https://www.industry.gov.au/data-and-publications/national-greenhouse-gas-inventory-december-2019
 

[34] Grogan, A. (2020, April 8). Cherry-Picking: Santos selects convenient data to deflect Narrabri gas challenge. Retrieved from https://www.michaelwest.com.au/cherry-picking-santos-selects-convenient-data-to-deflect-narrabri-gas-challenge/

[35] NWPA (2020, April). Narrabri Gas Project - Greenhouse Gas Claims Refuted.  Retrieved from https://nwprotectionadvocacy.com/wp-content/uploads/2020/03/NARRABRI-GAS-PROJECT-GHG-claims-refuted-April-2020_web.pdf

[36] Clean Energy Regulator (2019, October 28). The safeguard mechanism.  Retrieved from http://www.cleanenergyregulator.gov.au/NGER/The-safeguard-mechanism

[37] Mazengarb, M. (2020, April 1). Industrial emissions grow as polluters side-step safeguard caps.  Retrieved from https://reneweconomy.com.au/industrial-emissions-grow-as-polluters-side-step-safeguard-caps-30115/

[38] CSIRO (2012). Fugitive Greenhouse Gas Emissions from Coal Seam Gas Production in Australia. Retrieved from https://publications.csiro.au/rpr/pub?pid=csiro:EP128173

[39] Robertson, B. (2020, January 30). IEEFA Australia: Gas is not a transition fuel, Prime Minister.  Retrieved from https://ieefa.org/ieefa-australia-gas-is-not-a-transition-fuel-prime-minister/  

[40] Tasmanian Government. (n.d.). Hydrogen. Retrieved from https://www.stategrowth.tas.gov.au/energy_and_resources/energy/hydrogen
 

[41] Mazengarb, M. (2020, April 29). Massive hydrogen project gets green light after securing $300m investment.  Retrieved from https://reneweconomy.com.au/massive-hydrogen-project-gets-green-light-after-securing-300m-investment-68959/

[42] Energy Source & Distribution (2018, October 4).  Nel awarded contract for Australia’s first hydrogen microgrid.  Retrieved from https://esdnews.com.au/nel-awarded-contract-for-australias-first-hydrogen-microgrid/

[43] ARENA (2018, July 3). Green hydrogen innovation hub to be built in WA.  Retrieved from https://arena.gov.au/news/green-hydrogen-innovation-hub-to-be-built-in-wa/

[44] West, M. (2020, July 3). A Savage Call: energy tsar calls time on Australia’s gas cartel.  Retrieved from https://www.michaelwest.com.au/a-savage-call-energy-tsar-calls-time-on-australias-gas-cartel/

[45] Ramos-Suárez, J. L., Ritter, A., Mata González, J., & Camacho Pérez, A. (2019). Biogas from animal manure: A sustainable energy opportunity in the Canary Islands. Renewable and Sustainable Energy Reviews, 104, 137–150. https://doi-org.ezproxy.newcastle.edu.au/10.1016/j.rser.2019.01.025t
 

[46] Carlu, E. Truong, T. Kundevski, M. (2019, May). Biogas opportunities for Australia. ENEA Consulting – March 2019.  Retrieved from: https://www.energynetworks.com.au/resources/reports/biogas-opportunities-for-australia-enea-consulting/

[47] Hughes, J. (2020, July 15).  Business, industry and utilities back biogas for net zero Australia.  Retrieved from https://www.worldbiogasassociation.org/business-industry-and-utilities-back-biogas-for-net-zero-australia/
 

[48] Bioenergy Australia (2020, June 9). Joint letter in support of Australian biomethane market development.  Retrieved from https://www.bioenergyaustralia.org.au/news/joint-letter-in-support-of-australian-biomethane/
 
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Submission on Narrabri Gas Project - Alec Roberts

3/8/2020

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Submission on Narrabri Gas Project by Alec Roberts

​3 August 2020
Office of the Independent Planning Commission NSW
Level 3, 201 Elizabeth Street, Sydney, NSW 2000
P: (02) 9383 2100 E: [email protected]
 
Dear Independent Planning Commission,
 
This is a submission objecting to the Narrabri Gas Project.
 
Thank you for the opportunity to provide a submission into the Narrabri Gas Project and taking the time to consider my submission.
 
I live in the Lake Macquarie / Newcastle region in NSW.  I work for the University of Newcastle, School of Environment and Life Sciences as a Project Officer and previously worked at the Tom Farrell Institute for the Environment. My current role involves conducting an environmental assessment for Norfolk Island.  In a volunteer capacity, I am a committee member of several organisations including the Hunter Environmental Institute, Richmond Vale Rail Trail Inc., Newcastle Climate Change Response, Hunter Innovation and Science Hub, and the Clean Energy Association of Newcastle and Surrounds.  I am also a member of the Charlestown chapter of The Wilderness Society.  I am involved in what could be termed environmental outreach, informing the public on environmental information, news, and activities through newsletters, conducting seminars, events, and conferences.  I have helped run the annual Mined Land Rehabilitation Conference and the Hunter Valley Electric Vehicle Festival over the last 4 years.  On the ground I am involved with Landcare work for the Richmond Vale Rail Trail.
 
Growing up in NSW I enjoyed camping holidays with my family in the area visiting the many beautiful places including Warrumbungle National Park, Siding Spring Observatory, Coonabarabran, and further north to Walgett, Lightening Ridge and Grawin.  The natural beauty of the area is stunning and as a new immigrant to these shores (at the time) it made a lasting impression on me.  Whether it be the beautiful fields of Sunflowers that stretch to the horizon, the emus matching the pace of the car as you drive down the road or the stunning natural architecture of the Warrumbungles.
 
The Narrabri Gas project will have significant Groundwater impacts, Ecological impacts, Climate Change impacts, and the economics and energy security reasons behind the proposal are flawed, and the project should be refused development consent.
 
The Narrabri Gas Project, that is estimated to result in 94.2 million tonnes of greenhouse gases over the life of the project, cannot be permitted because its approval would be inconsistent with the remaining carbon budget and the Paris Agreement climate target.  This project is not consistent with NSW’s climate change policy, the principle of inter-generational equity nor the public interest, as it clearly assumes failure to meet the Paris Agreement temperature goals and worsening climate change impacts for New South Wales.
 
Both Renewable Hydrogen and Biogas/Biomethane can displace or replace natural gas as a fuel significantly reducing GHG emissions.  No new gas is needed.
 
Furthermore, the project is not critical for energy security and reliability in NSW as:
  • Narrabri Gas project high production costs and resulting high gas prices will not put downward pressure on gas prices.
  • Domestic market forecast shortfalls by 2024 are unlikely due to a drop in domestic demand, a flattening on international demand freeing up supply, and LNG import terminals coming on-line prior to 2024.
  • Transition of the National Electricity Market away from a long-term reliance on coalfired power stations to a greater reliance on renewable energy will not be dependent on gas-fired power stations.
 
This submission is focused on economics, gas supply and demand, climate change impacts, gas as a transition fuel and alternative fuels to natural gas.  However, it would be remiss of me if I did not briefly mention some of the other potential impacts of the Narrabri Gas Project.
 
Groundwater Impacts
The project exposes the following major environmental risks impacting groundwater:
  • Long term risk of depressurisation and leakage from key water supply aquifers.
  • Groundwater and surface water contamination, particularly with CSG produced wastewater from the Project.
  • Fugitive gas migration into aquifers overlying the target coal seams (a groundwater contamination and safety hazard).[1]
 
The Pilliga Sandstone Aquifer is a high-quality shallow groundwater that local communities rely on for water for stock, domestic and irrigation purposes and is one of the main aquifers in the southern Great Artesian Basin.  The Pilliga Sandstone is also the main outcropping aquifer in the Pilliga forest region within the project area, and this region and along with outcropping along the Warrambungle Range are recharge beds for the Great Artesian Basin in NSW. [2] [3]  A near-surface aquifer, the Namoi Alluvium, is also a major water resource for agriculture in the region. Together these form the main source of water these communities rely on for their livelihoods.
 
The contamination of groundwater is a major environmental risk with Coal Seam Gas, with the major potential contamination from ‘produced water’ which is pumped from the underlying coal seams to depressurize the seams and allow gas to be released and be extracted.  CSG produced water is typically of poor quality due to being located within the coal seams.  The Narrabri region produced water is high in salinity and contains high levels of heavy metals, boron and fluoride and presents a major risk to groundwater contamination in the area.
 
Given a number of leaks and/or spills of produced water have already occurred within the 70 appraisal and exploration wells in the area, there is a strong likelihood with 850 wells that significant leaks and/or spills of produced water will occur throughout the life of the project risking contamination of the aquifers / recharge beds for the Great Artesian Basin and affecting the livelihoods of those that depend on this valuable resource.
 
Furthermore, the project has no approved plan to deal with the 840,000 tonnes of salt waste contaminated with heavy metals than will be produced over the life of the project, as no local landfill can accept this waste.
 
The potential contamination of the aquifers and lack of waste management of the contaminated salt waste flies in the face with the assessment that the project will “not result in significant impacts on people or the environment”.
 
Ecological Impacts – Koalas
The Pilliga Forest has been classified as a priority area for koala conservation.  Energy and Environment Minister Matt Kean recently set a goal of doubling the number of koalas by 2050 in a bid to defy projections the marsupial could become extinct in the wild in NSW by mid-century.[4]  The Narrabri Gas project will result in the fragmention of 85,000 hectares of the Pilliga Forest.  Fragmented islands of koala habitat such as will result from this development which will result in unhealthy koala populations.  Koalas need wide corridors to spread out to ensure effective breeding.  Koala corridors are vital and are recognised generally as such in the new Koala SEPP and acknowledged by the NSW Chief Scientist (2016):
“Koala populations need large areas of connected habitat to maintain their viability. Habitat loss and fragmentation has resulted in population decline and has been identified as a significant threat to the species persistence in NSW.”[5]
Recent studies within the project area suggest a dramatic decline in koala populations. Surveys of the Pilliga forests in the 1990s suggest that the forests were carrying the largest population of koalas west of the Great Dividing Range in NSW, with the population estimated at 15,000. Repeat surveys within the Pilliga forests show a decline of over 80% since the 1990s.5
The impact of extreme weather events such as drought and extreme heatwaves on koalas is expected to increase with climate change and may also exacerbate other threats such as disease.[6] The Pilliga forest koalas are likely to have faced extreme (but less frequent and long) heat events in the past and responded by retreating to creek lines with either available free water or a higher moisture content in the leaves of their food trees. However, land clearing within and on the periphery of the forests and from road construction since the early 1900s has resulted in creeks within the Pilliga forests silting up. Habitats that would have once likely functioned as a refuge during times of drought are now highly disturbed and are unlikely to provide the required level of protection for koalas.5
 
The planned significant fragmentation of habitat by the Narrabri Gas project will exacerbate the problems caused by earlier land clearance and may lead to the local extinction of the Koala. The potential local extinct of an vulnerable species appears to contradict the assessment that the project will “not result in significant impacts on people or the environment”.
 
Economics 
Gas supply on the east coast of Australia has tripled since 2014.  However, domestic gas prices have also tripled in the same period in response to a huge demand for gas for LNG production and export. LNG exporters in Gladstone were unable to supply enough gas from their CSG production wells, with reserves grossly overestimated compared to their supply capacity.  This resulted in a hoovering up existing low cost of production gas increasing domestic prices.[7]
 
Domestic gas prices in Australia have remained at levels far in excess of international parity prices.  Whilst prices have fallen somewhat, they have not fallen by nearly as much as those in Asia or Europe.  Domestic prices have remained some 30-40% higher than ACCC calculated export parity prices (a.k.a. "netback" prices).[8] This may be explained as there is a lack of competition in the supply and delivery in the domestic gas market with only 5 producers and 2 pipeline owners. This is compounded with a lack of transparency of gas prices (there is no wholesale gas market with most gas traded bilaterally via contracts) that puts domestic and industrial gas buyers at a disadvantage. 1
 
Consequently, gas has become uncompetitive as a fuel source for power generation in Australia and demand for gas-powered generation has fallen by 59% since 2014.6  Subsequently, gas-powered generation has been running well below capacity.[9] Not surprising that at present there are no committed new investments in gas-fired power generation.[10]  Nevertheless, electricity prices for both households and businesses have been driven up by higher gas prices, because gas-fired power stations typically supply the electricity market during times of peak demand.2  Gas is effectively the price setter in the National Electricity Market; for every $1/GJ increase in the price of gas the price of electricity rises by $11/MWh. 6
 
The CSIRO GenCost report indicated that renewables (wind and solar photovoltaic) with storage (such as pumped hydro) were now cheaper than gas for electricity generation in Australia.[11]  As such, it is expected that demand for gas for electricity generation will decline in the future.
 
One of the key competitive advantages Australian industry has enjoyed has been low energy prices.  Energy intensive industries and industries dependent on energy intensive inputs have become less competitive as prices for electricity and gas for combustion have increased.  This has forced the closure of some major manufacturing and chemical plants, lead to the offshoring of production and undermined the profitability and viability of other gas users.2  Gas use in manufacturing as a consequence of these prices has fallen by 12% since 2014.[12] 
 
AEMO forecasts further reductions in gas use as consumers fuel-switch away from gas appliances towards electrical devices, in particular for space conditioning. The Commonwealth and NSW Government are exploring options to free-up gas demand through electrification, fuel switching and energy efficiency. [13]
Fuel switching from gas appliances towards electrical devices can often be more economic. A 2018 study of household fuel choice found that 98% of households with new solar financially favoured replacement of gas appliances with electric.  With existing/no solar 60-65% of households still favoured replacement of gas appliances with electric. [14] 
 
In the residential sector, for example, reverse-cycle air-conditioning is expected to reduce gas demand that could have arisen due to gas heating.[15] For those residents who cannot afford the capital costs of replacing gas appliances, these increased prices are leading to a worrying growth in energy poverty in the domestic residential sector. [16] 
 
 
As over 70% of Australian gas is exported as LNG, increases in supply from CSG projects in NSW are unlikely to affect to domestic prices into the near future and any potential flow on effect to the Australian economy.  This is supported by the NSW Independent Pricing and Regulatory Tribunal (IPART) which expressed doubt as to whether the development of CSG projects in NSW was likely to have a bearing at all on gas prices in NSW as the development of the three LNG export projects meant the Eastern Gas Region had become linked to global LNG markets.[17]  Moreover, Coal seam gas is high-cost gas, being 50% more expensive to produce than conventional gas.[18] The proposed Narrabri Gas project is even more expensive, as according to an AEMO commissioned report, gas extraction costs from this field will be over twice the cost of other existing fields in the eastern gas region.6 According to AEMO, the Narrabri Gas Project is ranked 41 out of 51 actual and undeveloped gas projects and there are 18 developed and 22 undeveloped gas projects with lower estimated production costs than the Narrabri Gas Project.8
 
The marginal source of supply (the final source of gas supply needed to meet demand) is likely to set floor price in negotiations between gas suppliers and buyers in NSW.[19]  This cost of production together with transmission costs to Sydney is currently some 20% less than the proposed Narrabri Gas Project.  Furthermore, future marginal source of supply may be satisfied by imported LNG (where wholesale gas prices would be set to import parity levels) or through existing or developed lower cost domestic supplies (such as noted by AEMO).8  Under these circumstances, the Narrabri Gas Project would not provide the marginal source of supply for wholesale gas in NSW, and is thus unlikely to exert any influence over wholesale gas prices in NSW over the near or long term and therefore not contribute to any reduction in domestic gas prices.
 
Kevin Gallagher, Managing Director and CEO of Santos recently stated, “The notion that any industry can survive selling its product lower than its cost of production is clearly out of step”. [20]  This may be the case for the Narrabri Gas project with predicted high production costs precluding LNG export (if allowed) and production costs higher than marginal source of supply for domestic distribution.
 
The Narrabri Gas Project was declared a Strategic Energy Project because of the crucial role it could play in strengthening energy security and reliability in NSW due in part on being able to address the AEMO predicted future gas supply shortfalls in the Eastern Gas Region in 2024 “if no further sources of gas or alternative infrastructure are developed”.8 Furthermore, the Australian Commonwealth and NSW Government have entered into a Memorandum of Understanding that includes an undertaking that the NSW Government will facilitate investment opportunities for new gas infrastructure that will inject as additional 70 PJ of gas in to the east coast market which happens to be the estimated production of the Narrabri Gas project. 13 However, recent predictions by AEMO are that supply is projected to be sufficient to meet all eastern and south-eastern Australian demand until 2026-2027. [21] In this assessment, AEMO further noted that the annual southern shortfall is estimated to be 51 PJ, lower than the estimated production from Narrabri of 70 PJ.
 
AEMO in 2018 estimated that in NSW, industry accounts for 42% of domestic gas demand, gas powered generation accounts for 21% of demand and residences accounted for the remaining 37%.[22]
 
It should be noted that demand for natural gas in NSW has declined over recent years. From 2014 to 2018, annual consumption of natural gas in NSW fell by 15 per cent, with the major contributor of this fall in consumption being the reduction in the use of gas for power generation.8 Whereas domestic demand for gas has fallen for use in manufacturing by 14%, it has dropped by a staggering 59% for power generation by since 2014. 6 
 
The AEMO 2020 Gas Statement of Opportunities stated that their 2020 gas consumption forecast was lower than all previous forecasts for 2023 onwards, largely reflecting a reduced outlook for the LNG sector, along with a muted outlook for gas-powered generation as new utility-scale renewable capacity forecasts were higher than previously forecast.15
 
Whereas AEMO has predicted no effective change to the level industrial gas use and residential and commercial gas use in NSW, demand for gas-powered generation is predicted to continue to fall by over 85% from 2019 levels by 2028.[23] 
 
International demand for LNG has stagnated and it is likely that Eastern Gas Region reserves will no longer be drawn on by Queensland LNG export projects to satisfy their export orders while demand is flat.[24]  Consequently, the supply of natural gas in the Eastern Gas Region is expected to ease.
 
Several LNG import terminals are planned for the 3 southern states.  All the proposed LNG
import terminals intend to utilise Floating Storage Regasification Unit (FSRU) technology. FSRUs require little construction or investment, can provide access to LNG much faster (around 2 years), and cost less than half the cost of an onshore facility and the vessel can be reassigned on project completion.  The first NSW LNG import terminal at Port Kembla is expected to commence supply at the start of 2021 with an expected capacity of 100 PJ and could be increased further to 140– 150 PJ per annum in the future.8 17 In April 2020, approval was granted to increase the annual capacity to 115 PJ and to allow up to 500 TJ/day in winter months to account for high domestic demand periods.[25]  The second NSW LNG import terminal Newcastle Gas Terminal was declared a NSW Critical State Significant Infrastructure in August 2019, and if approved would have an expected capacity of 110 PJ.  The NSW government has committed to fast tracking/streamlining regulatory assessments for the Port Kembla import terminal and, if approved, the Newcastle Gas Terminal.14  The east coast gas import terminals would reduce the need for pipeline development and complement the seasonality of gas production by securing a reliable supply in winter (typically the time of peak domestic gas demand for heating), when the demand in the northern hemisphere is typically low (during the northern hemisphere summer). 7
 
The planned LNG import terminal at Crib Point, Victoria has the potential to supply up to 160 PJ of natural gas per annum to the gas grid and is expected to be operational by 2022.  If approved, the project would meet the shortfall in gas supply predicted by AEMO and would provide gas supply certainty to Victoria, NSW and South Australia. [26] 15
 
In considering the predicted future gas supply shortfall for NSW in 2024 and whether it will eventuate, one should consider the drop in demand for gas in NSW, the stagnation of international demand and potential freeing up of reserves, and the impact of LNG import terminals coming on line from 2021 onwards.  Given these factors, it is unlikely that there will be any shortage of supply in NSW from 2024 onwards.
 
Economic recovery and jobs?It is dubious that projects such as the Narrabri Gas Project will deliver the goods for an economic recovery.  The industry is not a large employer and pays little or no tax.[27]  Analysis by The Australia Institute noted that the gas sector was one of the worst options to choose for mass job creation and that investment in other sectors would create many more jobs.[28] This doesn’t include losses in employment in other sectors resulting from the project such as agriculture.

Climate Change Impacts
The impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally.[29]
 
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australian native wildlife, the Australian people and the wealth of the nation as noted by the recent catastrophic bushfires and devastating drought. 
 
To address the issue of dangerous climate change, Australia, along 196 other parties, is a signatory to the Paris Agreement, which entered into force on 4 November 2016. The Paris Agreement aims to strengthen the global response to the threat of climate change, by:
Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change.[30]
NSW Climate Change Policy Framework details the NSW Government’s objective to achieve net-zero emissions by 2050.[31] This long-term objective “sets a clear statement of government’s intent, commitment and level of ambition and sets expectations about future emissions constraints that will help the private sector to plan and act.” The Policy Framework states that the NSW Government will investigate how to embed consideration of climate change mitigation and adaptation across government operations including service delivery, infrastructure, purchasing decisions and regulatory frameworks.  Furthermore, it states that Agencies will undertake additional policy investigation for sectors with significant opportunities and risks, including primary industries emissions and adaptation (Department of Primary Industries).
 
The IPCC report provides an estimate for a global remaining carbon budget of 580 GtCO2 (excluding permafrost feedbacks) based on a 50% probability of limiting warming to 1.5 degrees relative to 1850 to 1900 during and beyond this century and a remaining carbon budget of 420 GtCO2 for a 67% chance. [32]
 
Committed emissions from existing and proposed energy infrastructure represent more than the entire carbon budget that remains if mean warming is to be limited to 1.5 °C and perhaps two-thirds of the remaining carbon budget if mean warming is to be limited to less than 2 °C.  Estimates suggest that little or no new CO2-emitting infrastructure can be commissioned, and that existing infrastructure may need to be retired early (or be retrofitted with carbon capture and storage technology) in order to meet the Paris Agreement climate goals.[33]
 
Australia’s remaining emission budget from Jan 2017 until 2050 for a 50% chance of warming to stay below 1.5C warming relative to pre-industrial levels was estimated to be 5.5 GTCO2e.15 Adding the GHG emissions expended in 2017[34], 2018[35], and 2019[36], this leaves just 3.8 Gt CO2e remaining as at December 2019.  This leaves 6-7 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C.  Therefore, at current emissions rates, Australia will have exceeded its carbon budget for 2050 by 2026.
 
It therefore follows that no new fossil fuel development in Australia that is not carbon neutral, including the Narrabri Gas Project, that is estimated to result in 94.2 million tonnes of greenhouse gases over the life of the project, can be permitted because its approval would be inconsistent with the remaining carbon budget and the Paris Agreement climate target.
 
This project is not consistent with NSW’s climate change policy, the principle of inter-generational equity nor the public interest, as it clearly assumes failure to meet the Paris Agreement temperature goals and worsening climate change impacts for New South Wales.

Natural gas as a “transition fuel”? 
Natural gas has often been touted as the “transition fuel” for the electricity sector to replace coal’s greenhouse gas emissions and eventually paving the way for an emissions free future for Australia.  This has been used as an argument for the approval of the Narrabri Gas project. This concept is out of date and I believe incorrect. It is simply too expensive and too emissions intensive to be so.  Furthermore, the concept is based on the replacement of coal with gas which is effectively for electricity generation only.  Gas is also utilised for heat through combustion both industrially and domestically producing greenhouse gases.
 
Methane leaks from natural gas production can make the process nearly as carbon intensive as coal.  The CSIRO report “Fugitive Greenhouse Gas emissions from Coal Seam Gas Production in Australia”[37] noted that fugitive emissions for Natural Gas in Australia as a whole are estimated to be 1.5% of gas extracted, whereas if fugitive emissions exceeded 3.1% then the emissions intensity would match that of coal (due to the fact that methane is 86 times more powerful as a greenhouse gas than CO2 over 20 years and 34 times more powerful over a 100-year time period).4 They also noted that unconventional gas industry such as Coal Seam Gas would result in greater levels of fugitive emissions than the conventional gas industry.  Moreover, the Narrabri Gas field has very high levels of CO2 which will be vented into the atmosphere as part of gas extraction adding to the fugitive emissions from the implementation of this project.[38]
 
As noted above, the electricity market has already moved away from gas, with a 59% decline in usage in the National Electricity Market since 2014, whilst renewable energy has increased by 25% during the same period.6 Furthermore, flexible gas plants already in the grid are running well below capacity.3 AEMO forecast that increasing renewable generation developments in the NEM are expected to continue to drive down system normal demand for gas-powered generation. 15
 
The AEMO modelled the future electricity grid in its Integrated Systems Plan.[39] [40]  The results showed for all scenarios that the transition from coal to renewable energy would not be via gas.3  The role of gas would be reduced with a decline in gas generation through to 2040.6  The report notes that to firm up the inherently variable distributed and large-scale renewable generation, there will be needed new flexible, dispatchable resources such as: utility-scale pumped hydro and large-scale battery energy storage systems, distributed batteries participating as virtual power plants, and demand side management.13 26  It also noted that new, flexible gas generators such as gas peaking plants could play a greater role if gas prices materially reduced, with gas prices remaining low at $4 to 6 per GJ.26  However this is unlikely as gas prices have tripled over the past decade and expected NSW gas prices are over 60% more than this price.3 10  AEMO noted that the investment case for new gas-powered generation will critically depend on future gas prices, as gas-powered generation and batteries can both serve the daily peaking role that will be needed as variable renewable energy replaces coal-fired generation.  In their 2020 Gas Statement of Opportunities report, AEMO predicted that as more coal-fired generation retired in the long term, gas consumption for gas-powered generation in the National Electricity Market was forecast to grow again in the early 2030s, recovering to levels similar to those forecast for 2020. 15  However, in a later report, AEMO determined that by the 2030s, when significant investment in new dispatchable capacity is needed, new batteries will be more cost-effective than gas-powered generation. 33  Furthermore, the commissioning of the Snowy 2.0 pumped hydro project in 2026 will result in less reliance on gas-powered generation as a source of firm supply.15
 
AEMO noted that stronger interconnection between regions reduces the reliance on gas-powered generation, as alternative resources can be shared more effectively. 26  The expansion network interconnection enables the growth of variable renewable energy without a significant reliance on local gas generation.[41]  Supporting this assertion, the AEMO announced a series of actionable transmission projects including interconnector upgrades and expansions and network augmentations supporting recently announced renewable energy zones.[42]  26  AEMO noted that as each of these new transmission projects is commissioned, the ability for national electricity market regions to share resources (particularly geographically diverse variable renewable energy) is increased, and therefore demand for gas-powered generation is forecast to decrease.15 The Marinus Link is forecast to be commissioned in 2036, with surplus renewable generation from Tasmania then being available to the mainland National Electricity Market, which would see further declines in gas-fired generation, despite continuing coal-fired generation retirements.15
 
Therefore, it is unlikely that further gas peaking plants would be developed to play a significant role in providing dispatchable energy to the grid as the grid transitions to greater levels of variable renewable energy.
 
Gas-powered generation can provide the synchronous generation needed to balance variable renewable supply, and so is a potential complement to storage.13  However, the current installation of synchronous condensers in South Australia and other eastern states to increase system strength and stabilise the electricity network will reduce the need for gas-fired generators acting in the role of synchronous generators as more renewables enter the grid.[43]  Ancillary services are likely to utilise battery storage and synchronous condensers in the future and no longer require the use of gas-powered generation.
 
Transitioning away from Gas
The ACT is planning to go gas free by 2025.  This is expected to reduce their overall emissions by 22%.  As part of the ACT Climate Change Strategy 2019-2025, all government and public-school buildings will be completely powered by 100% renewable energy eliminating the need for natural gas.  The ACT has also removed the mandatory requirement for new homes built in the ACT to be connected to the mains gas network and will begin to introduce new policies to replace gas appliances with electric alternatives.  Some 14% of residents have already converted over to 100% electric. [44]
There are moves in other jurisdictions to remove the mandatory requirement for a gas connection in new developments such as in South Australia.
Several technologies new or new to Australia are expected to reduce the use of natural gas as the Australian economy transitions to a net zero emissions economy and would replace the need for new gas such as proposed by the Narrabri Gas project.  Please note that these technologies not only look to transition electricity generation away from natural gas but also for gas combustion for heat. These technologies could also address any gas supply shortfalls.
Hydrogen
Hydrogen is a colourless, odourless, non-toxic gas that is an excellent carrier of energy and can be used for a broad range of energy applications including as a transport fuel, a substitute for natural gas and for electricity generation.[45] Hydrogen gas can be produced from water in a process known as electrolysis, and when powered by renewable energy, the hydrogen produced is free from carbon emissions, making it an attractive way to decarbonise transport, heating and electricity generation.26 
 
AEMO stated that, “Hydrogen has the exciting potential to become an alternative energy storage technology and a new export commodity for Australia” which could be used to help decarbonise the domestic heat, transport and the industrial and commercial sectors in Australia and noted that development of the hydrogen industry would potentially impact both natural gas and electric demands.7 26
 
Several developments involving green / renewable hydrogen are either planned or underway in Australia.
 
AEMO highlighted the potential for green steel production in Australia due to abundant renewable resources and the increased demand for low emissions industrial commodities worldwide.7 ‘Green steel’ can be made via a direct reduction process which uses hydrogen (made from renewable energy) as the heat source and reducing agent to produce pig iron. The by-product of the iron reduction process using hydrogen is water, rather than carbon dioxide in conventional steel making. Renewable energy is then used by an electric arc furnace to produce low-emissions green steel.
 
The Arrowsmith Hydrogen Project, which will be built at a facility in the town of Dongara, located 320km north of Perth, will utilise dedicated onsite renewable energy 85MW of solar power, supplemented by 75MW of wind generation capacity to generate 25 tonnes of green hydrogen a day and will be operational in 2022.[46]
 
ATCO’s Clean Energy Innovation Hub, located in Jandakot in Western Australia, is being used to trial the production, storage and use of renewable hydrogen to power a commercial-scale microgrid, testing the use of hydrogen in different settings and applications including in household appliances.[47]  This includes optimising hydrogen storage solutions, blending hydrogen with natural gas and using hydrogen a direct use fuel.  Green hydrogen will be produced from on-site solar using electrolysis, fuelling a range of gas appliances and blending hydrogen into the natural gas pipeline.
 
The $3.3 million development project will evaluate the potential for renewable hydrogen to be generated, stored, and used at a larger scale. ATCO aims to assess the practicalities of replacing natural gas with hydrogen at a city-wide scale across a municipality.[48]
 
The new chair of the Australian Energy Regulator, Clare Savage recently stated:
 
“The national gas industry could also undergo significant change as some jurisdictions move towards a zero carbon emissions policy. This could have significant consequences for the future of gas pipeline networks. In response, the AER recently supported the future recovery of Jemena’s investment in trialling the production of hydrogen from renewable energy for injection into its Sydney network. If hydrogen trials such as Jemena’s prove successful, the natural gas networks could be re-purposed to distribute hydrogen. If not, the economic life of the assets could be limited.” 11
 
Biogas and Biomethane
Biogas is a renewable energy source, that is continuous and dispatchable, reliable, and local source of energy. Biogas can be converted into heat and/or electricity using boilers, generators or with Combined Heat and Power units.[49]  Biogas also provides an alternative route for waste treatment and, as such, can help divert waste from landfill. Biogas consists primarily of methane and carbon dioxide, with trace amounts of other gases such as hydrogen sulphide, water vapour, oxygen, and ammonia.[50]  Biogas can also be upgraded into biomethane: a renewable gas that can replace natural gas with a chemical composition very similar to natural gas. Biomethane is produced from the separation of methane from the other gases.31
 
Biogas and its industry offer many benefits:
  • Biogas is a renewable energy source that assists the decarbonisation of the economy. A study of the replacement of natural gas by biomethane in France reduced GHG emissions by greater than 85%. 
  • Biogas is a secure, continuous and dispatchable source of energy that can contribute to national energy supply.
  • Biogas also provides an alternative route for waste treatment and, as such, can help divert waste from landfill.
  • The biogas industry supports local economies and regional communities, creating jobs, and offering new income sources, particularly for farmers.
  • Biogas transformed into biomethane is a renewable gas that can replace natural gas, and can be used in homes for cooking, heating, and hot-water, or as a fuel for gas vehicles. It can be injected into the gas grid or used directly on-site. As biomethane has similar characteristics to natural gas, its injection into the gas grid does not require any adaptation of the existing infrastructure (neither the gas grid nor customer equipment connected to it). This is an opportunity for the gas and transport sectors to further assist the energy transition. 31
 
A landmark report commissioned by Bioenergy Australia last year identified the total estimated biogas potential to be 371PJ (103TWh) of available energy, which is enough to decarbonise industrial, commercial, and residential gas users currently supplied by distributed gas networks across Australia.[51]
 
Australian business, industry and utilities recently signed an open letter to the Commonwealth Government advocating for biomethane to be injected into the gas distribution networks to enable the lowest cost transition to a decarbonised energy market and address a number of challenges including:
  • Provide complementary reliable and flexible renewable resources for variable renewable energy.
  • Allow heavy industry dependent on process inputs and high-quality heat to decarbonise using existing gas connections.
  • Provide a pathway for Heavy vehicle decarbonisation.
  • Allow domestic gas customers to decarbonise their energy supply using existing networks and appliances.[52]
 
 
Both Renewable Hydrogen and Biogas/Biomethane can displace or replace natural gas as a fuel significantly reducing GHG emissions.  These technologies show promise in Australia with the resources available locally.  Once developed these would see assets such as the Narrabri Gas project left stranded.
 
Summary
In summary, the Narrabri Gas project should not be approved. 
 
The Narrabri Gas Project, that is estimated to result in 94.2 million tonnes of greenhouse gases over the life of the project, cannot be permitted because its approval would be inconsistent with the remaining carbon budget and the Paris Agreement climate target.  This project is not consistent with NSW’s climate change policy, the principle of inter-generational equity nor the public interest, as it clearly assumes failure to meet the Paris Agreement temperature goals and worsening climate change impacts for New South Wales.
 
Natural gas is not a “transition fuel” for the electricity sector to replace coal’s greenhouse gas emissions and eventually paving the way for an emissions free future for Australia.  It is simply too emissions intensive to be so. 
 
Both Renewable Hydrogen and Biogas/Biomethane can displace or replace natural gas as a fuel significantly reducing GHG emissions.  No new gas is needed.
 
Furthermore, it is not critical for energy security and reliability in NSW as:
  • Narrabri Gas project high production costs and resulting high gas prices will not put downward pressure on gas prices.
  • Domestic market forecast shortfalls by 2024 are unlikely due to a drop in domestic demand, a flattening on international demand freeing up supply, and LNG import terminals coming on-line prior to 2024.
  • Transition of the National Electricity Market away from a long-term reliance on coalfired power stations to a greater reliance on renewable energy will not be dependent on gas-fired power stations.
 
Due to the above reasons I strongly object to the Narrabri Gas Project. Thank you again for the opportunity to comment. I look forward to hearing from you regarding this submission.
 
Yours sincerely,
 
Alec Roberts


[1] EDO (2020, July 22) CSG: The public hearing into the Narrabri Gas Project.  Retrieved from https://www.edo.org.au/2020/07/22/csg-public-hearing-narrabri-gas-project/

[2] CSIRO (2018, August) Potential water impacts of coal seam gas in the Pilliga Sandstone.  Retrieved from https://gisera.csiro.au/wp-content/uploads/2018/08/18-00384_GISERA_FACTSHEET_SGW-GABFluxFinalReport2pp_WEB_180807.pdf

[3] Sreekanth, J., Cui, T., Pickett, T. & Barrett, D. (2017) Uncertainty analysis of CSG-induced GAB flux and water balance changes in the Narrabri Gas Project area. CSIRO, Australia. Retrieved from https://publications.csiro.au/rpr/download?pid=csiro:EP173269&dsid=DS3

[4] Hannam, P. (2020, July 26). Matt Kean aims to double koala population by 2050.  Retrieved from https://www.smh.com.au/environment/conservation/matt-kean-aims-to-double-koala-population-by-2050-20200725-p55fdc.html
 

[5] NSW Chief Scientist & Engineer (2016, December). Report of the Independent Review into the Decline of Koala Populations in Key Areas of NSW.  Retrieved from https://www.chiefscientist.nsw.gov.au/__data/assets/pdf_file/0010/94519/161202-NSWCSE-koala-report.pdf
 

[6] Lunney, Daniel & Crowther, Mathew & Wallis, Ian & Foley, William & Lemon, John & Wheeler, Rob & Madani, George & Orscheg, C. & Griffith, Joanna & Krockenberger, Mark & Retamales, Melissa & Stalenberg, Eleanor. (2012). Koalas and climate change: a case study on the Liverpool Plains, north-west NSW. 10.7882/FS.2012.022.
 

[7] Rios, J. (2019, September 13). What’s next for Australia’s natural gas market? Retrieved from https://www.eecc.eu/blog/whats-next-for-australias-natural-gas-market
 

[8] Long, S. (2020, February 27). Gas giants misled governments and it is costing Australian jobs, ACCC boss says.  Retrieved from https://www.abc.net.au/news/2020-02-27/gas-giants-misled-governments-accc-boss-rod-sims-says/12004254
 

[9] Morton, A. (2020, March 8). 'Expensive and underperforming': energy audit finds gas power running well below capacity.  Retrieved from https://www.theguardian.com/environment/2020/mar/08/expensive-and-underperforming-energy-audit-finds-gas-power-running-well-below-capacity
 

[10] Robertson, B. (2020, January 30). IEEFA Australia: Gas is not a transition fuel, Prime Minister.  Retrieved from https://ieefa.org/ieefa-australia-gas-is-not-a-transition-fuel-prime-minister/  
 

[11] CSIRO (2019, December) GenCost 2019-20: preliminary results for stakeholder review. Retrieved from https://www.aemo.com.au/-/media/Files/Electricity/NEM/Planning_and_Forecasting/Inputs-Assumptions-Methodologies/2019/CSIRO-GenCost2019-20_DraftforReview.pdf
 

[12] Robertson, B. (2020, July 23). IEEFA update: Australia sponsors a failing gas industry. Retrieved from https://ieefa.org/ieefa-update-australia-sponsors-a-failing-gas-industry/
 

[13] Energy NSW. (2020, January 31). Memorandum of understanding, Retrieved from https://energy.nsw.gov.au/government-and-regulation/electricity-strategy/memorandum-understanding
 

[14] Alternative Technology Association (2018, July) Household fuel choice in the National Energy Market.  Retrieved from https://renew.org.au/wp-content/uploads/2018/08/Household_fuel_choice_in_the_NEM_Revised_June_2018.pdf

[15] AEMO (2020a, July 30). 2020 ISP Appendix 10. Sector Coupling. Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/appendix--10.pdf?la=en

[16] Snow, J. (2014, February). Energy Policy Institute of Australia - Public Policy Paper
Paper 2/2014 The economic impact of high energy prices in Australia, Retrieved from http://oakleygreenwood.com.au/wp-content/uploads/2017/10/6_Snow_Jim_Public_Policy_Paper-6Feb2014.pdf
 

[17] Pegasus Economics (2019, August) Report on the Narrabri Gas Project. Retrieved from https://8c4b987c-4d72-4044-ac79-99bcaca78791.filesusr.com/ugd/b097cb_c30b7e01a860476bbf6ef34101f4c34c.pdf
 

[18] West, M. (2020, January 2). Smithereens: Australia’s climate commitments blown if giant fossil fuel projects proceed.  Retrieved from https://www.michaelwest.com.au/smithereens-australias-climate-commitments-blown-if-giant-fossil-fuel-projects-proceed/
 

[19] ACCC (2020, January) Gas inquiry 2017-2025 – Interim Report.  Retrieved from https://www.accc.gov.au/system/files/Gas%20inquiry%20-%20January%202020%20interim%20report%20-%20revised.pdf
 

[20] West, M. (2020, July 3). A Savage Call: energy tsar calls time on Australia’s gas cartel.  Retrieved from https://www.michaelwest.com.au/a-savage-call-energy-tsar-calls-time-on-australias-gas-cartel/
 

[21] AEMO (2020, March). Gas Statement of Opportunities, March 2020, For eastern and south-eastern Australia. Retrieved from https://aemo.com.au/en/energy-systems/gas/gas-forecasting-and-planning/gas-statement-of-opportunities-gsoo

[22] AEMO (2018, June). 2018 Gas Statement of Opportunities, June 2018, For eastern and south-eastern Australia. Retrieved from https://aemo.com.au/en/energy-systems/gas/gas-forecasting-and-planning/gas-statement-of-opportunities-gsoo

[23] AEMO (2020, March 27) National Electricity & Gas Forecasting 2020 GSOO Publication. Retrieved from http://forecasting.aemo.com.au/Gas/AnnualConsumption/Total

[24] McCarthy, J. (2020, July 20) Our $70 billion gas industry sinking as export ships 'steaming around in circles'. Retrieved from https://inqld.com.au/business/2020/07/20/our-70-billion-gas-industry-collapsing-as-export-ships-steaming-around-in-circles/
 

[25] GHD (2019, November) Port Kembla Gas Terminal Proposed Modification Environmental Assessment November 2019. Report for AIE. Retrieved from https://www.planningportal.nsw.gov.au/major-projects/project/25811
 

[26] Gas Import Jetty and Pipeline Project (2020, July). Gas Import Jetty and Pipeline Project Summary Document Environmental Effects Statement, July 2020. Retrieved from https://www.gasimportprojectvictoria.com.au/environment-effects-statement#view-the-ees

[27] IEEFA (2019, November 25). IEEFA Australia: Oil and gas industry paying less tax than Telstra [PRESS RELEASE]. Retrieved from https://ieefa.org/ieefa-australia-oil-and-gas-industry-paying-less-tax-than-telstra/
 

[28] The Australian Institute (2020, July). Gas Fired Backfire Why a “gas fired recovery” would increase emissions and energy costs and squander our recovery spending.  Retrieved from https://www.tai.org.au/sites/default/files/P908%20Gas-fired%20backfire%20%5Bweb%5D_0.pdf
 

[29] NASA (n.d.) Scientific Consensus: Earth's Climate is Warming.  Retrieved from https://climate.nasa.gov/scientific-consensus/
 

[30] IPCC (2018). Global Warming of 1.5°C: An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty, Intergovernmental Panel on Climate Change.  Retrieved from https://www.ipcc.ch/sr15/
 

[31] OEH (2018). NSW Climate Change Policy Framework. Retrieved from https://www.environment.nsw.gov.au/-/media/OEH/Corporate-Site/Documents/Climate-change/nsw-climate-change-policy-framework-160618.pdf
 

[32] Meinshausen, M. (2019, March 19). Deriving a global 2013-2050 emission budget to stay below 1.5°C based on the IPCC Special Report on 1.5°C.  Retrieved from https://www.climatechange.vic.gov.au/__data/assets/pdf_file/0018/421704/Deriving-a-1.5C-emissions-budget-for-Victoria.pdf

[33] Tong, D., Zhang, Q., Zheng, Y., Caldeira, K., Shearer, C., Hong, C., Qin, Y., & Davis, S. J. (2019). Committed emissions from existing energy infrastructure jeopardize 1.5 °C climate target. Nature, 572(7769), 373-377. https://doi-org.ezproxy.newcastle.edu.au/10.1038/s41586-019-1364-3
 

[34] Climate Council (2018) Australia’s Rising Greenhouse Gas Emissions. Retrieved from https://www.climatecouncil.org.au/wp-content/uploads/2018/06/CC_MVSA0143-Briefing-Paper-Australias-Rising-Emissions_V8-FA_Low-Res_Single-Pages3.pdf
 

[35] Cox, L. (2019, March 14). Australia's annual carbon emissions reach record high.  Retrieved from https://www.theguardian.com/environment/2019/mar/14/australias-annual-carbon-emissions-reach-record-high
 

[36] DISER (2020, May) National Greenhouse Gas Inventory: December 2019.  Retrieved from https://www.industry.gov.au/data-and-publications/national-greenhouse-gas-inventory-december-2019
 

[37] CSIRO (2012). Fugitive Greenhouse Gas Emissions from Coal Seam Gas Production in Australia. Retrieved from https://publications.csiro.au/rpr/pub?pid=csiro:EP128173
 

[38] Grogan, A. (2020, April 8). Cherry-Picking: Santos selects convenient data to deflect Narrabri gas challenge. Retrieved from https://www.michaelwest.com.au/cherry-picking-santos-selects-convenient-data-to-deflect-narrabri-gas-challenge/
 

[39] AEMO (2019, December 12). Draft 2020 Integrated System Plan - For the National Electricity Market.  Retrieved from https://aemo.com.au/-/media/files/electricity/nem/planning_and_forecasting/isp/2019/draft-2020-integrated-system-plan.pdf?la=en
 

[40] AEMO (2020b, July 30). 2020 Integrated System Plan - For the National Electricity Market.  Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/final-2020-integrated-system-plan.pdf?la=en
 

[41] AEMO (2020c, July 30) 2020 ISP Appendix 2. Cost Benefit Analysis. Retrieved from https://aemo.com.au/-/media/files/major-publications/isp/2020/appendix--2.pdf?la=en

[42] Energy Source & Distribution (2020, July 30). AEMO reveals Integrated System Plan 2020. Retrieved from https://esdnews.com.au/aemo-reveals-integrated-system-plan-2020/
 

[43] Parkinson, G. (2020, May 25) Big spinning machines arrive in South Australia to hasten demise of gas generation. Retrieved from https://reneweconomy.com.au/big-spinning-machines-arrive-in-south-australia-to-hasten-demise-of-gas-generation-64767/
 

[44] Mazengarb, M. & Parkinson, G. (2019, September 16).  ACT to phase out gas as it launches next stage to zero carbon strategy.  Retrieved from https://reneweconomy.com.au/act-to-phase-out-gas-as-it-launches-next-stage-to-zero-carbon-strategy-92906/
 

[45] Tasmanian Government. (n.d.). Hydrogen. Retrieved from https://www.stategrowth.tas.gov.au/energy_and_resources/energy/hydrogen
 

[46] Mazengarb, M. (2020, April 29). Massive hydrogen project gets green light after securing $300m investment.  Retrieved from https://reneweconomy.com.au/massive-hydrogen-project-gets-green-light-after-securing-300m-investment-68959/

[47] Energy Source & Distribution (2018, October 4).  Nel awarded contract for Australia’s first hydrogen microgrid.  Retrieved from https://esdnews.com.au/nel-awarded-contract-for-australias-first-hydrogen-microgrid/

[48] ARENA (2018, July 3). Green hydrogen innovation hub to be built in WA.  Retrieved from https://arena.gov.au/news/green-hydrogen-innovation-hub-to-be-built-in-wa/
 

[49] Ramos-Suárez, J. L., Ritter, A., Mata González, J., & Camacho Pérez, A. (2019). Biogas from animal manure: A sustainable energy opportunity in the Canary Islands. Renewable and Sustainable Energy Reviews, 104, 137–150. https://doi-org.ezproxy.newcastle.edu.au/10.1016/j.rser.2019.01.025t
 

[50] Carlu, E. Truong, T. Kundevski, M. (2019, May). Biogas opportunities for Australia. ENEA Consulting – March 2019.  Retrieved from: https://www.energynetworks.com.au/resources/reports/biogas-opportunities-for-australia-enea-consulting/

[51] Hughes, J. (2020, July 15).  Business, industry and utilities back biogas for net zero Australia.  Retrieved from https://www.worldbiogasassociation.org/business-industry-and-utilities-back-biogas-for-net-zero-australia/
 

[52] Bioenergy Australia (2020, June 9). Joint letter in support of Australian biomethane market development.  Retrieved from https://www.bioenergyaustralia.org.au/news/joint-letter-in-support-of-australian-biomethane/
 
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Submission to Senate Select Committee on COVID-19

26/5/2020

1 Comment

 

My concerns about the National Covid-19 Coordination Commission
​by Alec Roberts

​

​26 May 2020
Senate Select Committee on COVID-19
 
My concerns about the National Covid-19 Coordination Commission
 
Dear Senators,
​
The effectiveness of the National Covid-19 Coordination Commission (NCCC) in assisting the government mitigate the economic effects of the Covid-19 pandemic is being compromised by perceived conflicts of interest, a pro-gas agenda, a lack of transparency, and inability for the public to have input into the process.  Gas is not the mooted transition fuel to a low carbon economy and gas industry connections in the NCCC may compromise the opportunity for a renewable energy led economic recovery from the Covid-19 crisis.
 
As part of the Australian Government's response to the COVID-19 pandemic, the Prime Minister announced on 25 March 2020 the “creation of a new National COVID-19 Coordination Commission (NCCC) that will coordinate advice to the Australian Government on actions to anticipate and mitigate the economic and social effects of the global coronavirus pandemic.”
“The Commission will ensure the Government receives the most comprehensive advice to meet the challenges ahead to cushion the economic impact of the coronavirus and help build a bridge to recovery.”
 
I am very concerned with the pro-gas agenda of the Prime Minister’s hand-picked National Covid-19 Coordination Commission (NCCC).  I’m concerned that the potential conflicts of interests and the networks of the gas-linked Commissioners will influence their advice. The Covid-19 Commission needs to be transparent and publish the details of their industry links and dealings.
 
Recently the Commission chair Neville Power stated that a $2 billion liquid ammonia plant at Narrabri, proposed by Santos and Perdaman Industries, and proposed to be fuelled by Santos’ proposed Narrabri Gas Project, ‘tops the list’ of ventures that the NCCC will back.  The Commission chair has also mooted the west-east gas pipeline from the North West Shelf previously rejected by the federal government. Furthermore, a leaked NCCC report calls for Australian taxpayers to underwrite gas industry expansion.
 
Several of the NCCC members have strong links to the fossil fuel industry, and yet there is no publicly available conflict of interest register, no published diary to see who the Commission are meeting with, and no opportunities for the community to have a say.
 Specifically:
  • The Chair, Neville Power, is Non-Executive Director and Deputy Chair of Strike Energy which is seeking to exploit gas reserves in WA and SA.  Not surprisingly he is putting forward a project to construct a gas pipeline from WA to the east coast.  If that is not conflict of interest, then what is? Even if he temporarily steps down as Non-Executive Director and Deputy Chair of Strike Energy, he currently holds over 12.6 million shares in the company with a market value of over $1.6 million dollars.
  • Catherine Tanna is the former Managing Director of Queensland Gas Company which became the BG Group before it was acquired by Royal Dutch Shell.  Catherine is currently the Managing Director of EnergyAustralia, one of the biggest polluters in Australia and owner of several Gas Power Plants. EnergyAustralia’s parent company CLP Group is a 20% stakeholder in the proposed Narrabri Gas Project. Here is what appears to be another conflict of interest.
  • Andrew Liveris is a special advisor to the NCCC and a former adviser to the NT government on the development of the gas industry there. Andrew Liveris is also a board member of Saudi Aramco (an Oil and Gas Company).
  • James Fazzino is on the Board of APA Group which owns and operates the largest interconnected gas transmission network across Australia and several Gas Power Plants. James Fazzino is also the former Managing Director and CEO of Incitec Pivot Ltd (one of Australia’s largest consumers of gas).  APA Group is seeking to build a pipeline connecting the Narrabri gas project to the Moomba Sydney Pipeline and another connecting the Moomba pipeline to Port Kembla.  APA Group has entered into an agreement with Santos to build the pipeline to deliver gas from the proposed Narrabri Gas Project to market.  As noted above, the Narrabri gas fields have been put forward as a key project by the NCCC.  Again, this is appearing to be a key conflict of interest. 
 
The NCCC needs a transparent conflict of interest register of all members, including special advisors.  Furthermore, all findings and advice from the NCCC should be made in the best interests and in full view of the Australian people.
 
It is unlikely that a gas led recovery will deliver the goods for an economic recovery.  The industry is not a large employer and pays little or no tax.  Analysis by The Australia Institute noted that the gas sector was one of the worst options to choose for mass job creation and that investment in other sectors would create more jobs.
 
Gas supply on the east coast of Australia has tripled since 2014.  However, domestic gas prices have also tripled in the same period. Gas prices in Australia have remained at levels far in excess of international parity prices.  Whilst prices have fallen somewhat, they have not fallen by nearly as much as those in Asia or Europe.  Consequently, gas has become uncompetitive as a fuel source for power generation in Australia and demand for gas-powered generation has fallen by 41% since 2014.  Not surprising that at present there are no committed new investments in gas-fired power generation.  Furthermore, as over 70% of Australian gas is exported as LNG, increases in supply are unlikely to affect to domestic prices into the near future and any potential flow on effect to the Australian economy.
 
Methane leaks from natural gas production can make the process nearly as carbon intensive as coal.  The CSIRO report “Fugitive Greenhouse Gas emissions from Coal Seam Gas Production in Australia” noted that fugitive emissions for Natural Gas in Australia as a whole are estimated to be 1.5% of gas extracted, whereas if fugitive emissions exceeded 2% then the emissions intensity would match that of coal (due to the fact that methane is 86 times more powerful as a greenhouse gas than CO2 over 20 years). They also noted that unconventional gas industry such as Coal Seam Gas would result in greater levels of fugitive emissions than the conventional gas industry.
 
Natural gas has often been touted as the “transition fuel” for the electricity sector to replace coal’s greenhouse gas emissions and eventually paving the way for an emissions free future for Australia.  It is simply too expensive and too emissions intensive to be so.
 
In the case of the Narrabri Gas project supported by the NCCC, the proposed Narrabri Gas project will unlikely contribute to a reduction in gas prices, as gas extraction from this field will be more expensive than other existing fields in the eastern gas region. Moreover, the Narrabri Gas field has very high levels of CO2 which will be vented into the atmosphere as part of gas extraction adding to the methane fugitive emissions from the implementation of this project.
 
The CSIRO GenCost report indicated that renewables (wind and solar photovoltaic) with storage (such as pumped hydro) were now cheaper than gas for electricity generation in Australia.  Furthermore, the current installation of synchronous condensers in South Australia and other eastern states to increase system strength and stabilise the electricity network will reduce the need for gas-fired generators acting in the role of synchronous generators as more renewables enter the grid.  As such, it is expected that demand for gas for electricity generation will decline in the future.
 
The IMF stated that all economic stimulus post pandemic should have clear aspects and focus on decarbonisation, long term cost benefit, that there should be jobs and clear accountability from an emissions point of view what these projects will do. Expansion of the gas industry is unlikely to realise these important objectives.
 
This month the International Energy Agency (IEA) stated that each country’s economic recovery packages post COVID-19 should be aligned to the Paris agreement to best meet agreed climate and sustainability objectives. A gas led recovery would not achieve this.  They noted we need to look beyond fossil fuel candidates and look to new investment in job creating renewable energy and energy efficiencies that will decrease costs of energy and boost the economy.   IEA also highlighted the massive opportunity open to us now in laying down the foundations for the huge technology driven growth in electric vehicles, batteries, and zero emission hydrogen-producing electrolysers.
 
I’m concerned about gas industry connections in the NCCC potentially compromising the opportunity for a renewable energy-led recovery from the Covid-19 crisis.
 
The consensus among economists is that we face long term financial impacts from the Covid-19 pandemic. We need long term, socially, economically and environmentally sustainable solutions to create the pathway out of the current economic downturn. Expansion of the gas industry is unlikely to achieve this.  Monies and efforts are best spent in other areas.
 
Furthermore, it is very important that the public have a say on the economic recovery efforts after Covid-19. There needs to be a process to allow diversity of industries to have a meaningful voice in the next steps for Australia.  Our local communities and regional areas have so much to offer.
 
Thank you for taking the time to read my submission.

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Q&A Modern Monetary Theory with Prof Bill Mitchell

6/5/2020

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Q&A Modern Monetary Theory with Prof Bill Mitchell

​by Newcastle Climate Change Response

Newcastle Climate Change Response is very excited to facilitate a Q&A session with the amazing Bill Mitchell on Modern Monetary Theory and how peering through this lens may be useful to ensure a socially just and environmentally sound economic recovery from Covid-19 and how NCCRs and others may act to make this happen. If you don’t know what I’m on about, check this one out and then join us tomorrow from 4-5 with questions a ready! 

Recording of Q&A

A recording of the Q&A session is below (recording starts shortly into the Q&A session).
​To download the recording select the vertical ellipsis (3 dots) and select "Download".
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EPBC Act Review - Submission Alec Roberts

17/4/2020

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Note:  Submissions close May 1st 2020.

17/04/2020

Dear Professor Samuel and Independent Review Panel,
 
Thank you for the opportunity to provide a submission into the 2019-2020 Independent Review of the EPBC Act.
 
I live in the Lake Macquarie / Newcastle region in NSW.  I work for the University of Newcastle, School of Environment and Life Sciences as a Project Officer and previously worked at the Tom Farrell Institute for the Environment. My current role involves conducting an environmental assessment for Norfolk Island.  In a volunteer capacity, I am a committee member of several organisations including the Hunter Environmental Institute, Richmond Vale Rail Trail Inc., Newcastle Climate Change Response, Hunter Innovation and Science Hub, and the Clean Energy Association of Newcastle and Surrounds.  I am also a member of the Charlestown chapter of The Wilderness Society. I am involved in what could be termed environmental outreach, informing the public on environmental information, news and activities through newsletters, conducting seminars, events and conferences. I have helped run the annual Mined Land Rehabilitation Conference and the Hunter Valley Electric Vehicle Festival over the last 4 years.  On the ground I am involved with Landcare work for the Richmond Vale Rail Trail.
 
The EPBC Act is 20 years old and has failed to address the loss in biodiversity and extinction prevention of plants and animals or habitat destruction within Australia.  The Act is complex and unwieldy and is in drastic need of reform. The Act needs to address the environmental threats that we face including climate change and habitat destruction through land clearing.
 
Rather than amending and modernising the Act, a new Act should be drafted with biodiversity conservation and environmental protection being the key drivers.  The new Act should provide government leadership on environmental protection, include safeguards for plant and animal extinction including stopping habitat destruction of endangered species, and to increase resilience of plants and animals and their habitats to key challenges such as climate change.
 
The principle of Ecologically Sustainable Development is a key aspect with the Act and should be modernised and strengthened to include principles of continuous improvement and non-regression of environmental standards, goals, and policies; achieve high levels of environmental protection through best practices; and increased resilience to climate change and other pressures on the environment.
 
With my involvement with the Mined Land Rehabilitation Conference I have seen the effects of cumulative approvals of mines and mine expansion in the Hunter Valley on the environment, the decreased resilience to change, the health impact on individuals living and working within the area.  For example, there is a cumulative issue relating to air quality in the Upper Hunter that needs attention. Average levels of coarse particle pollution in the Hunter Valley have increased at a rate higher than the rest of NSW. Air quality in the local area has been deteriorating over time, reaching 470 air quality alerts in 2019 prior to the bushfires. The top three for PM10 particulate levels of air pollution in NSW are in the local area. This air pollution contributes to heart disease, stroke, deaths, diabetes, low birth weight for babies, restricted lung growth in children, lung cancer in non-smokers, asthma and emphysema.  A planned expansion of the Glendell Mine this year in the area would exacerbate an already dire set of circumstances with respect to air quality and health issues in the local area. However, the mine expansion went ahead as cumulative impacts are not considered in planning laws. The Act needs to explicitly consider cumulative impacts of past, present and future developments and decisions. The use of strategic environmental assessments may assist in assessing cumulative impacts.
 
The impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australian native wildlife, the Australian people and the wealth of the nation as noted by the recent catastrophic bushfires and devastating drought. 
 
To ensure the health and resilience of the Australian environment and its people in the face of such challenges, laws and processes will need to be enacted to mitigate climate change and address the impacts of climate change, extreme weather and drought.  This would include sustainably managing environments affected by climate change and rebuilding and restoring ecosystems burnt by bushfires. Although climate change is the most significant environmental threat it is not mentioned anywhere in the Act. The Act should address and regulate the impacts of climate change on biodiversity.
 
For example, following the recent catastrophic bushfires, koala populations are at a crisis point and it is imperative that urgent action be taken to ensure the survival of this iconic species within south eastern Australia.
 
Climate change is predicted to affect koala habitat conditions and cause more severe weather conditions (such as the recent severe drought and catastrophic bushfires) which will impact koala survival rates. Climate change is predicted to affect koala habitat by altering the structure and chemical composition of koala food trees, changing the composition of plant communities, and changing the range of important habitat species.
In my local area, changing sea levels as a result of climate change will impact on low lying priority habitat, within the Port Stephens area and Stockton Bight, further fragmenting habitat stands.
The ability of Koalas to migrate due to the effects of climate change are impacted by the connectivity across the landscape.  Particular attention is required to remove or mitigate the barriers to connectivity and to preserve and enhance existing connectivity, such as undertaken in the Hunter Valley with the Great Eastern Ranges initiative.  For example, regional and local conservation planning should consider protecting existing connectivity and enhancing connectivity of koala habitat patches that are within 100m of another patch.
 
Climate change considerations need to be included in the Act to identify and protect habitat and corridors that will support species resilience to more extreme heat and natural disasters, even if there is no population in those areas now.
 
Matters of national environmental significance (triggers) are an essential part of the Act that trigger assessment processes under the Act.  These triggers should be retained and expanded to include vulnerable ecological communities (alongside other threatened specifies and ecological communities), significant land-clearing activities, significant water resources (in addition to coal seam gas and large coal impacts)., the National Reserve System, significant greenhouse gas emissions and nationally important ecosystems (key biodiversity areas and areas of high conservation value).
 
Any biodiversity offsetting must be based on clear scientific principles and limits and maintaining or improving ecological outcomes.  The government should avoid lowest common denominator standards that rely on the market such as with the NSW system. The Act should not allow ‘offsetting’ critical habitat, endangered species and ecological communities.  Furthermore, offset land should be of similar habitat (like-for-like), should provide an improvement for the impacted species or ecological community, must comply with the provision of no net loss of biodiversity, must be protected in perpetuity, should be consistent with any species recovery plans, cannot be substituted by the payment of money, such as into a Biodiversity Conservation Fund, and should be a last resort following efforts made to mitigate impacts.
 
Offset land must be an additional protection.  For example, a developer cannot use existing parkland to offset koala habitat such as was proposed by Lendlease near Campbelltown in NSW last year.
 
From my personal experience with the Mine Rehab Conference, Mine Rehab land is unlikely to be an effective offset (in line with like-for-like habitat, no net loss of biodiversity, etc) and should be excluded.  The former NSW Office of Environment and Heritage noted that “there is no certainty that functioning ecosystems can be restored to their original value through rehabilitation” and questioned whether restoration of biodiversity on a degraded site was even possible.
 
Offset land must be secured prior to development / land clearing going ahead. For example, after seven years and multiple time extensions, Whitehaven’s Maules Creek mine has failed to secure over 5000 hectares of biodiversity offsets for their clearing the critically endangered box gum grassy woodland ecological community near Narrabri and is now in court. Only 5% of this iconic woodland still exists and provides habitat for the Regent Honeyeater, Superb Parrot and Squirrel Glider.
 
Ecosystem services underpin human existence, health and prosperity, with biodiversity central to the production of ecosystems services.  In recognising the intrinsic importance of the environment to Australia, the Act needs to acknowledge the value of ecosystem services. The assessment and value of ecosystem services also needs to be included in decision making to ensure potentially hidden social costs or benefits are considered.
 
To ensure government accountability and effective decision making, greater public transparency is required together with effective community consultation and the right of appeal.  Decisions should be informed by community engagement (including public submissions) and the reasoning behind the decisions documented and provided back to the community. Specifically, the Act should provide information on policies, policy changes, and specific assessments, decisions and actions to the public in a timely and accessible manner.  It should not be necessary to undertake lengthy and expensive FOI requests to get the reasoning behind decisions. The right of appeal should extend to the courts with judicial review of government decisions such that is available in the states. Similarly interested parties should be able to seek merits review of decisions.
 
To facilitate reform and effectiveness of the new Act, a national ecosystem assessment should be undertaken to establish a baseline and determine indicators of success / failure.  National ecosystem assessments could then be undertaken periodically to help measure, maintain, and improve environmental outcomes.
 
To improve governance, a new national Environmental Protection Authority (EPA) needs to be established as the chief environmental regulator and to assess and approve projects, monitor compliance and take enforcement action.  Furthermore, a new National Sustainability Commission be established to set national environmental goals and standards, coordinate national plans and actions, develop policy responses to current and future environmental impacts and in light of scientific evidence, and publicly report through Parliament each year on the state of the environment, impact of actions and environmental outcomes. The government should be required to respond to these reports.
 
And finally, resourcing has been a constant issue for the effective implementation of the Act.  Government funding should be increased to enable this, such as resourcing to enable the effective implementation of environmental protection and restoration, and the listing and conserving of threatened species and ecological communities.
 
Thank you for your consideration of my submission
 
Sincerely,
 
Alec Roberts
Chair CLEANaS
 




References 
Department of the Environment, Water Heritage and the Arts (2010) Ecosystem services: Key concepts and Applications. Retrieved from https://www.environment.gov.au/system/files/resources/b53e6002-4ea7-4108-acc8-40fff488bab7/files/ecosystem-services.pdf

Eco Logical Australia 2013. Lower Hunter Koala Study. Prepared for Dept Sustainability, Environment, Water, Population and Communities’.

Environmental Defenders Office (2020, April 3) Court challenge over coal mine’s critically endangered woodlands offsets failure.  Retrieved from https://www.edo.org.au/2020/04/03/court-challenge-over-coal-mines-critically-endangered-woodlands-offsets-failure/?fbclid=IwAR0_7Ffv9e2_JD1R83l-VPEoU5lUwx05J1F5hs8TfnVjPJ_FVQkRBTUPjeM

Hannam, P. (2016, March 16) 'Very poor': Environment office opposed miners using rehabilitation work as biodiversity offset.  Retrieved from https://www.smh.com.au/environment/very-poor-environment-office-opposed-miners-using-rehabilitation-work-as-biodiversity-offset-20160315-gnjfb3.html

Hannam, P. (2017 November 9) 'Greed trumps nature': Leaked report points to big offset savings for developers.  Retrieved from https://www.smh.com.au/environment/greed-trumps-nature-leaked-report-points-to-big-offset-savings-for-developers-20171109-gzhnln.html
​

Hannam, P. (2018, October 29) 'Scam': Developer to use parkland to offset koala habitat destruction.  Retrieved from https://www.smh.com.au/environment/conservation/scam-developer-to-use-parkland-to-offset-koala-habitat-destruction-20181028-p50cfz.html
 
Additional Sources (not included in submission):

Wildlife Preservation Society of Queensland (n.d.) 
Extension to submissions for EPBC Act review.  Retrieved from https://wildlife.org.au/extension-to-submissions-for-epbc-act-review/

Australian Conservation Foundation (n.d.) How to write a great a submission to strengthen our national environment laws. Retrieved from https://docs.google.com/document/d/1lTIX62hfOOEp1kZVibVPHg7_axJoZuzt7GR7M1IUxbI/edit

WWF Australia (n.d.) Now is our chance to end animal extinction: Here is the message we are sending: Submission in response to the EPBC Act Review. Retrieved from https://www.wwf.org.au/get-involved/stop-australias-extinction-crisis

Hunter Bird Observers Club (n.d.) Submission to the 2019 Review of the Environment Protection and Biodiversity Conservation Act 1999. Retrieved from https://www.hboc.org.au/wp-content/uploads/EPBC-Act-Review-2020.pdf

Environmental Defenders Office (n.d.) EDO Submission to the EPBC Act Review Discussion Paper. Retrieved from https://www.edo.org.au/publication/submission-10-year-review-epbc-act/
​​
Environmental Defenders Office (2020, April 3) 
Guide for making a submission to the EPBC Review.  Retrieved from https://www.edo.org.au/publication/guide-for-submissions-to-epbc-review/

Samuel, G. (2019, November 21) Independent review of the EPBC Act: Discussion Paper.  Retrieved from https://epbcactreview.environment.gov.au/resources/discussion-paper

Wilderness Society (n.d.) EPBC submission guide. Retrieved from https://www.wilderness.org.au/make-your-voice-heard

To submit your submission
 Submissions close May 1st 2020.
To submit your submission complete questions 1 &​ 8, and attach your submission in question 7 in the link below
https://environment.au.citizenspace.com/epbc-review/epbc-act-review-submission-discussion-paper/consultation/
​
1 Comment

Submission to the Draft Koala Habitat Protection Guideline

4/4/2020

0 Comments

 
Submission to the Draft Koala Habitat Protection Guideline
​by Alec Roberts

 
To whom it may concern,
 
Please accept this letter as my submission to the Draft Koala Habitat Protection Guideline. I consent to the Department making this submission and my name public.
 
Following the recent catastrophic bushfires, koala populations are at a crisis point and it is imperative that urgent action is taken to ensure the survival of this iconic species within NSW.
 
Koalas are currently listed as a vulnerable threatened species in NSW, and therefore have a high risk of local extinction in the medium term.  In 2016 it was estimated that there remained approximately 36,000 koalas in NSW (representing a decline of 26% over 2 decades).  However, other studies suggest much lower numbers.  Furthermore, compounding this, more than 24% of koala habitats were within fire-affected areas in eastern NSW with the recent bushfires.
 
In my area of the Lower Hunter, areas of know Koala Habitat have had an estimated 75% reduction in habitat since European Settlement with commensurate declines in koala population due to habitat clearing.   Furthermore, areas of high priority koala habitat are often unprotected, with just over 20 percent within existing formal conservation reserves.
 
The main threats to Koala populations across the Lower Hunter include:
  • Fragmentation, degradation and loss of habitat (at both macro and micro scale);
  • Barriers to habitat connectivity (both natural and manmade);
  • Road fatalities;
  • Predation by dogs;
  • Disease (e.g. Chlamydia);
  • Fire (bushfires and control burns); and
  • Climate Change.
 
Changes in habitat in the Lower Hunter can be attributed to high development pressure and piecemeal planning resulting in isolated fragments of habitat remaining between urban areas.  The long-term conservation of koalas is reliant on understanding habitat requirements and population dynamics and incorporating this into urban planning.  The Koala SEPP 2019 and the Guideline should provide consistent requirements for development assessment on core koala habitat across the State.
 
 
NSW laws do not prohibit the clearing of koala habitat. Despite declining koala numbers and the devastation caused by this summer’s catastrophic bushfires, NSW laws still allow koala habitat to be cleared with approval. Decision makers just need to ensure development approvals are consistent with koala plans of management (if they exist) or these guidelines are considered.  For our laws to protect koalas and their habitats, the approval process should not allow important koala habitat to be offset or cleared in exchange for money (as NSW Biodiversity Assessment Method does). 
 
Comprehensive koala plans of management should be mandatory for all councils wherever there is koala habitat with a set completion timeframe.  With only 5 LGAs adopting comprehensive koala plans of management since 1995 (including only one from the Lower Hunter) a mandatory approach is required. These plans should be monitored, reviewed and reported publicly on a set and regular timeframe.  To assist local councils with these obligations the NSW government should provide incentive and support for councils to develop and maintain these plans.  Furthermore, for consistency, the Koala SEPP 2019 should be applicable across the state wherever there is koala habitat.
 
The Koala SEPP 2019 and the Guideline need to apply to a wider range of developments and activities that can impact on koala habitat that are outside of the domain of local councils including: complying development, major projects (State significant development and State significant infrastructure), Part 5 activities (e.g. activities undertaken by public authorities) and land clearing activities requiring approval under the LLS Act. The NSW planning system, public and private forestry, and land management (land clearing) laws fail to protect koala habitat. The limited application of the Koala SEPP 2019 is unlikely to lead to improved outcomes for koalas.
 
The threshold of 1 hectare for triggering the Koala SEPP 2019 where a plan is not in place is arbitrary and leaves small koala habitat areas, particularly koala habitat in urban areas, without adequate protection. The one-hectare requirement also contributes to cumulative impacts and can reduce connectivity across the landscape by allowing small patches to be cleared. The threshold should be removed.
 
Climate change considerations need to be included in the Koala SEPP 2019 and the Guideline to identify and protect habitat and corridors that will support koalas’ resilience to more extreme heat and natural disasters, even if there is no koala population in those areas now.
 
Climate change is predicted to affect koala habitat condition and cause more severe weather conditions (such as the recent severe drought and catastrophic bushfires) which will impact koala survival rates. Climate change is predicted to affect koala habitat by altering the structure and chemical composition of koala food trees, changing the composition of plant communities, and changing the range of important habitat species.

Changing sea levels as a result of climate change will impact on low lying priority habitat area with Port Stephens area and Stockton Bight affected, further fragmenting habitat stands.
The ability of Koalas to migrate due to the effects of climate change are impacted by the connectivity across the landscape.  Particular attention is required to remove or mitigate the barriers to connectivity and to preserve and enhance existing connectivity, such as undertaken in the Hunter with the Great Eastern Ranges initiative.  For example, regional and local conservation planning should consider protecting existing connectivity and enhancing connectivity of koala habitat patches that are within 100m of another patch.
 
Koala research findings, and potential application of mitigation measures, should feed back into the Koala SEPP 2019 and the Guideline, as part of a regular review process.  In particular, new information should be added to Koala Development Application Maps and Site Investigation Area for Koala Plans of Management Maps to ensure they are current and accurate.  The processes for the development and application of these maps needs to be transparent to allow for effective ground-truthing to ensure accuracy.
 
Regular monitoring and compliance are required to ensure the success of the Koala SEPP and Guideline. Monitoring, review, public reporting and compliance need to be established with a defined and regular timeframe.
 
To protect koalas, koala habitat must be protected from destruction.  The Koala SEPP 2019 at present does not increase the protection for koala habitat.  Until our laws are strengthened to truly limit or prohibit the destruction of koala habitat, koala populations and their habitat will continue to be at risk and koala numbers will continue to decline in NSW, possibly to the point of local extinction.
 
I urge the Department and relevant Ministers to strengthen the Koala SEPP 2019, the Koala Habitat Protection Guideline and provide incentive and support for councils.
 
Yours sincerely,
Alec Roberts
Gateshead 2290
 
I have read the Department's Privacy Statement and agree to the Department using my submission in the ways it describes. I understand this includes full publication on the Department's website of my submission, any attachments, and any of my personal information in those documents and possible supply to third parties such as state agencies, local government and the proponent.
 
References: 
Adams-Hosking, C., McAlpine, C., Rhodes, J. R., Grantham, H. S. and Moss, P. T. (2012). "Modelling changes in the distribution of the critical food resources of a specialist folivore in response to climate change." Journal of Conservation Biogeography Diversity and Distributions: 1-14.
 
Biodiversity Conservation Act 2016, s 4.4(3)
 
Department of Planning, Industry and Environment, Understanding the impact of the 2019-20 fires, https://www.environment.nsw.gov.au/topics/parks-reserves-and-protected-areas/fire/park-recovery-and-rehabilitation/recovering-from-2019-20-fires/understanding-the-impact-of-the-2019-20-fires
 
Department of Planning, Industry and Environment, Koala conservation, https://www.environment.nsw.gov.au/topics/animals-and-plants/native-animals/native-animal-facts/koala/koala-conservation  
 
‘Eco Logical Australia 2013. Lower Hunter Koala Study. Prepared for Dept Sustainability, Environment, Water, Population and Communities’.
 
Local Land Services, Threatened Fauna of the Hunter & Mid Coast: Koala,2019, https://www.lls.nsw.gov.au/__data/assets/pdf_file/0007/1118563/koala.pdf
 
NSW Chief Scientist & Engineer, Report of the Independent Review into the Decline of Koala Populations in Key Areas of NSW, December 2016 above no 6, citing Adams-Hosking, C, McBride, M.F, Baxter, G, Burgman, M, de Villiers, D, Kavanagh, R, Lawler, I, Lunney, D, Melzer, A, Menkhorst, P, Molsher, R, et al. (2016). Use of expert knowledge to elicit population trends for the koala (Phascolarctos cinereus). Diversity and Distributions, 22(3), 249-262. doi: 10.1111/ddi.12400
 
Paull, D., Pugh, D., Sweeney, O., Taylor, M, Woosnam, O. and Hawes, W. Koala habitat conservation plan. An action plan for legislative change and the identification of priority koala habitat necessary to protect and enhance koala habitat and populations in New South Wales and Queensland (2019), published by WWF-Australia, Sydney, which estimates koala numbers to be in the range of 15,000 to 25,000 animals. In 2018, the Australian Koala Foundations estimates koala numbers in NSW to be between 11,555 and 16,130 animals, see www.savethekoala.com/our-work/bobs-map-%E2%80%93-koala-populations-then-and-now
 
Additional Sources (not referenced in submission):
Environmental Defenders Office, Analysis: Koalas: new laws – old tricks, February 20, 2020, 
https://www.edo.org.au/2020/02/20/koalas-nsw-new-laws-old-tricks/#_edn1

Nature Conservation Council, Submission Guide: Koala Habitat Protection Guideline, 2020, https://www.nature.org.au/news-and-resources/submission-guides/koala-habitat-protection-guideline/

​
Nature Conservation Council, 2020, Defend koala protection laws, https://www.nature.org.au/get-involved/take-action/koala-sepp-guidelines-review/
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Requesting your support for Climate Change Bill

11/2/2020

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Independent member for Warringah , Zalli Steggall has launched her intention to introduce a private members bill to parliament on climate action. If you live in the Shortland electorate and you'd like to let Pat Conroy know that you would like him to support this bill click on the following link https://climateactnow.com.au/, select your electorate, and enter your name and email address. With a little extra energy you could contact Pat directly by email or mail if you would like to make your preferences known to him prior to the bill (Personal emails work the best). Thanks for your support.
For those outside the Shortland electorate please contact your local Federal member:
Hunter - Joel Fitzgibbon ALP
Newcastle - Sharon Claydon ALP
Paterson - Meryl Swanson ALP
#ClimateActNow


This letter was written requesting support for the Climate Change Bill by Pat Conroy my local Federal member of Parliament:


Pat,

​
Support for Climate Change Bill

The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the health and wellbeing of its citizens and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australians and the wealth of the nation as noted by the recent catastrophic bushfires and devastating drought.

As one of your constituents, I’m writing to urge you to support the Climate Change Bill that will be introduced into parliament on Monday March 23rd by way of a conscience vote. 

I support the proposed Climate Change legislation because I believe it’s vital that we have a national climate change framework that ensures Australia has:
  • Long-term plans for reducing greenhouse gas emissions to meet emissions reduction statutory targets which align with the science and international commitments (Net-zero emissions by 2050);
  • A positive response to the challenges of climate change that looks to new opportunities, just transitions from legacy industries and addresses generational equity;
  • Plans for adapting to the effects of climate change, whether that be responding to changing physical conditions or developing progressive international policies; and
  • Transparent and accountable adaptation and mitigation planning through an independent Climate Change Commission to advise the Government.


There are 20 other countries already with Climate Change framework legislation such as the UK and New Zealand that we could learn and adapt from.

This bill gives Australia the ability to respond as a nation to the risks, challenges and opportunities of climate change and provides a proven legislative framework to lead a transition to a zero-carbon economy.
It will provide the business sector with certainty and position Australia to take advantage of the world demand for low emissions technology.

The cost of inaction far outweighs the cost of action as shown by natural disasters such as the recent bushfires, droughts, and floods. As the costs will increase of these more prevalent and severe disasters as warming increases.
The Climate Change Bill aims to protect the Australian economy against these impacts.

I implore you to support the Climate Change Bill.  

Thank you for taking the time to read my letter.

Yours Sincerely

Alec Roberts
Gateshead, NSW
Project Manager | Chair CLEANaS
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Submission on Glendell Continuation Project

31/1/2020

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Submission on Glendell Continuation Project (part of Mt Owen Complex)
by Alec Roberts (thanks to George Woods for the great info supporting this submission)
Objection to Project
Climate Change
The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the health and wellbeing of its citizens and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australians and the wealth of the nation.
NSW Climate Change Policy Framework details NSW Government’s objective to achieve net-zero emissions by 2050. This long-term objective “sets a clear statement of government’s intent, commitment and level of ambition and sets expectations about future emissions constraints that will help the private sector to plan and act.” The Policy Framework states that the NSW Government will investigate how to embed consideration of climate change mitigation and adaptation across government operations including service delivery, infrastructure, purchasing decisions and regulatory frameworks.  Furthermore, it states that Agencies will undertake additional policy investigation for sectors with significant opportunities and risks, including primary industries emissions and adaptation (Department of Primary Industries).
 
The Glendell Continuation Project will result in 230.8 million tonnes of greenhouse gases over the life of the project. This is in addition to the greenhouse pollution from the rest of the Mount Owen complex.
 
The assessment admits that the project is consistent with the IPCC’s “high emissions A2 emission trajectory scenario.” This is a shocking admission and all the more shocking that it did not prompt the company to withdraw the proposal. The A2 scenario is projected to result in warming by approximately 3.4C by 2100. As the greenhouse assessment outlines, this scenario is associated with increased maximum temperatures, hot days and severe fire danger days.
 
This project is not consistent with NSW’s climate change policy, the principle of inter-generational equity nor the public interest, as it clearly assumes failure to meet the Paris Agreement temperature goals and worsening climate change impacts for New South Wales.
 
Air quality
There is a cumulative issue relating to air quality in the Upper Hunter that needs attention.  Average levels of coarse particle pollution in the Hunter Valley have increased at a rate higher than the rest of NSW
Air quality in the local area has been deteriorating over time, reaching 470 air quality alerts in 2019 prior to the bushfires.
The top three for PM10 particulate levels of air pollution in NSW are in the local area.
This air pollution contributes to heart disease, stroke, deaths, diabetes, low birth weight for babies, restricted lung growth in children, lung cancer in non-smokers, asthma and emphysema.
The expansion will exacerbate an already dire set of circumstances with respect to air quality and health issues in the local area.
 
The mine assessment admits that most air quality monitoring sites in the vicinity of Glendell Mine have experienced at least one day above the national standards for PM10 particulate pollution in the past seven years and some exceeded annual average thresholds in the last two years. Camberwell and Singleton also exceeded the PM2.5 criterion last year.
But the EIS uses a low pollution year, 2014, as its base year, setting background air pollution levels at less than half of the pollution concentrations experienced in the vicinity more recently. Nevertheless, the assessment shows intensification of PM2.5 and PM10 air pollution in Camberwell and surrounding areas.
 
Water Loss
This project further extends mining in a heavily-mined area, exacerbating water loss.
 
Baseline monitoring has identified water level drawdown within the coal seams due to the cumulative impact of approved activities that surround the proposed Glendell Pit Extension. The Environmental assessment noted
“The proposed Glendell Pit Extension will further depressurise the geological strata directly intersected by the mining activities. The Project will create a zone of drawdown around the mining activity where groundwater levels will decline during the mine life. The depressurisation will also create an area of low pressure within the groundwater system centred on the Glendell Pit Extension that will encourage groundwater to flow through coal seams towards the mining area drawing groundwater from the adjacent water sources.”
 
The mine’s groundwater assessment shows that dramatic drawdown of the coal seam under the Bowman’s Creek alluvium propagates upward into the alluvium and causes drawdown and loss of surface water.
This adds to stress already being experienced in the area from other mines, and the groundwater assessment also shows cumulative draw down of over 2 metres in the alluvium during the proposed mining operations.

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Submission on EPAA bill

13/12/2019

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Submission opposing bill to prevent the regulation of greenhouse gas emissions from Australian coal burned overseas.

The NSW Government has introduced a bill to amend the Environmental Planning and Assessment Act 1979 (NSW) (EP&A Act) and the State Environmental Planning Policy (Mining, Petroleum Production and Extractive Industries) 2007 (NSW) (Mining SEPP) to prohibit the imposition of conditions of development consent that purport to regulate any impact of the development occurring outside Australia or any impact of development carried out outside Australia and to to remove the specific requirement to consider downstream greenhouse gas emissions in determining a development application for development for the purposes of mining, petroleum production or an extractive industry.

In a nutshell, the New South Wales Government has introduced legislation to prevent the regulation of greenhouse gas emissions from Australian coal burned overseas.

Online submissions can be entered via a questionnaire (SurveyMonkey form) until Sunday 15 December 2019. 

Attached below is my submission:

​I am opposed to legislation to prevent the regulation of greenhouse gas emissions from Australian coal, gas and oil burned overseas. Specifically, in “determining a development application for development for the purposes of mining, petroleum production or an extractive industry", the State Environmental Planning Policy (Mining, Petroleum Production and Extractive Industries) 2007 should RETAIN the specific requirement to "consider downstream greenhouse gas emission in determining a development application"
 
The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the health and wellbeing of its citizens and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australians and the wealth of the nation.
 
The Rocky Hill decision was made based on science and fact. In considering the impacts of the Rocky Hill mine and the public interest, Chief Justice Brian Preston held that downstream indirect GHG emissions should be considered in determining the DA, as both direct and indirect GHG emissions (i.e. Scope 1, 2 and 3 emission) contribute to the cumulative impacts of climate change. The Chief Justice indicated that the following factors must be considered:
  • GHG emissions from the development;
  • the likely contribution of GHG emissions to climate change;
  • the consequences of this contribution to climate change; and
  • other impacts of the development.
This includes ‘downstream emissions’ which included:
  • the transportation and combustion of coal product from a mine; and
  • GHG emissions from the combustion of product coal by end users.
Please note that Clause 14 (2) of the Mining SEPP has never been the sole reason a coal mine has been refused. The Rocky Hill and also the Bylong coal projects were both refused primarily because of their local environmental impacts.


Downstream greenhouse gas emission of "mining, petroleum production or an extractive industry" are significant in contributing to global warming.  As noted by Professor Will Steffen in the Rocky Hill case “it is one climate system”, the burning NSW coal overseas impacts communities here at home. Emissions from NSW coal are not something that happens outside Australia, they have a deep and lasting impact here at home, as seen recently with the devastating bush fires and severe drought in NSW. You cannot artificially carve out climate impacts from Australian coal on local communities. The impacts of climate change on NSW communities matter.
That’s why we all need to take responsibility for those emissions, and it’s appropriate our laws and policy need to reflect that. Furthermore, it is irresponsible to propose blinkering a planning authority from considering one of the environmental impacts of a development, and contrary to the spirit of the Environmental Planning and Assessment Act and established case law.  A decision to remove that requirement would be a retrograde step and inconsistent with a science-based response to managing climate change.
 
NSW Climate Change Policy Framework details NSW Government’s objective to achieve net-zero emissions by 2050. This long-term objective “sets a clear statement of government’s intent, commitment and level of ambition and sets expectations about future emissions constraints that will help the private sector to plan and act.” The Policy Framework states that the NSW Government will investigate how to embed consideration of climate change mitigation and adaptation across government operations including service delivery, infrastructure, purchasing decisions and regulatory frameworks.  Furthermore, it states that Agencies will undertake additional policy investigation for sectors with significant opportunities and risks, including primary industries emissions and adaptation (Department of Primary Industries). 
The proposed legislation flies in the face of the NSW Climate Change Policy Framework. It removes the consideration of climate change mitigation from a regulatory framework.  It works against Agency policy investigation and development on primary industry emissions and adaptation. Furthermore, it sets the wrong expectations of future emissions constraints to private sector across the Mining, Petroleum Production and Extractive Industries in their planning for new or expanded operations. In addition to retaining the specific requirement to "consider downstream greenhouse gas emission in determining a development application", the government should consider ways to assist these industries in transitioning towards low emission industries and renewable energy production in the immediate future.
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