Dear WA EPA,
The EPA must assess Buru Energy’s ‘Rafael’ gas production and LNG proposal in the Kimberley at the highest level, Public Environmental Review (PER), for the reasons set out below.
1. Concerns with ‘Rafael’ gas production and LNG project that should be investigated and assessed by the EPA via a Public Environmental Review include:
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Groundwater extraction and contamination - the adequacy of baseline data, modelling assumptions and groundwater dependent ecosystem studies.
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Greenhouse emissions - adequacy of information regarding methane leakage, flaring, processing, transport and downstream emissions.
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Flora, fauna and habitat - adequacy of survey coverage, multi-seasonal studies, threatened-species surveys and indirect impacts.
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Subterranean fauna - whether the conclusions are supported by sufficient site-specific evidence.
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Air quality - whether the modelling adequately represents Rafael’s equipment, weather, and receptors.
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Traffic - whether the report evaluates future tanker movements and their impacts, rather than only existing traffic.
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Construction management - the specific controls, their effectiveness and how they would be enforced.
2. Buru Energy’s plans for future fracking in the Kimberley require assessment
Although the ‘Rafael’ project is based on conventional gas, Buru Energy has indicated that approval for ‘Rafael’, and resulting cashflow, is a stepping stone to much larger gas and oil production, including fracking at its ‘Yulleroo’ unconventional gas lease and re-commencing and expanding operations at its ‘Ungani’ oil production facility. (See Buru Energy’s Investor Presentation, 15 September 2026.)
These stated expansion and fracking plans must be considered by the EPA as part of a PER-level assessment in accordance with its obligation to assess a project’s ‘reasonably foreseeable future’ cumulative impacts.
3. Broader issues of fossil fuel expansion in Kimberley and EPA’s own call for environmental assessment
The EPA recently assessed and recommended approval for Black Mountain Energy’s ‘Valhalla’ gas fracking proposal in the Kimberley. In its assessment report and accompanying media release the EPA stated,
“However, noting the level of public interest, combined with the unique environmental and cultural values of the area, the EPA recommends that if there is likely to be growth in shale gas exploration or progression to production, that a regional cumulative risk assessment framework should be developed…If future growth of the petroleum industry in the Canning Basin is likely, we recommend the Minister consider a regional environmental assessment framework to ensure cumulative impacts are appropriately addressed.” (excerpts from EPA Report 1800 and EPA Chairman’s media release, 20 Jan 2026.)
As soon as the EPA announced its recommendation on ‘Valhalla’, Buru Energy released a statement praising the decision and saying it was a big boost for its own plans for fossil fuel expansion in the Kimberley, including the ‘Rafael’ and ‘Yulleroo’ gas projects. (See: Buru ASX announcement, 21 Jan 2026: ‘EPA Recommendation for Valhalla Project - Further Validation of Buru Strategy’)
This ‘Rafael’ proposal, coming just eight months after the EPA statements above, represents the ‘future growth’ the EPA referred to. The EPA must now be true to its own recommendation and either conduct a regional assessment of cumulative impacts itself or ensure that the recommended regional cumulative impact assessment is completed independently, prior to any consideration of the ‘Rafael’ proposal by the EPA.
4. Proponent’s poor environmental track record means open, public EPA assessment essential
Major environmental concerns over Buru Energy’s operations have been documented and reported since 2011, when Buru first conducted a fracking operation at its ‘Yulleroo’ well site near Broome. These concerns, many of them documented via Ministerial answers to Questions in Parliament and FOI’s, include: flooding of frack well pads despite claims such events could never happen; potential contamination of groundwater through reinjection of wastewater from oil production at ‘Ungani’ and ‘Blina’ oil production facilities; failure to properly close and decommission the ‘Blina’ oil production site despite contamination concerns; and the dumping of a million litres of toxic oil sludge from Buru’s Wyndham export facility in open ponds at the ‘Ungani’ oil production facility without prior approval.
Toxic hydrocarbon sludge dumped in an open pond over the wet season at Buru’s
‘Ungani’ oil facility without prior approval, 2023. Image: DWER compliance report 2024 - obtained under FOI.
Flooded Buru Energy well site, Yulleroo, 2011
Buru Energy wastewater ponds at Yulleroo well site in 2013
Buru Energy’s track record of pollution, well-site incidents and regulatory breaches shows that a full public EPA assessment of its ‘Rafael’ gas production and LNG proposal is essential if the public is to have any trust in the environmental claims and commitments made by the company.
5. Buru Energy gas is competing against renewable energy expansion in the Kimberley
Buru Energy wants to sell its ‘Rafael’ gas and oil condensate to towns like Broome and Derby, to mine sites and to First Nations communities (see Investor Presentation cited above). If it succeeds in locking-in gas and condensate contracts it will slow or prevent the necessary shift to abundant, pollution-free renewable energy in the region. For example, Horizon Power is proposing a large new solar farm and battery for Broome to shift away from reliance on LNG trucked-in from the Pilbara. Buru Energy however wants to sell its gas (LNG) to Broome, potentially blocking or reducing the promised “80% renewable power for Broome” potential stated by Horizon. The same goes for remote communities, which Buru Energy has identified as a market for its condensate, potentially blocking a shift to less expensive solar and batteries: “Rafael location delivers regional supply advantage…more than 100 remote communities rely on diesel for primary power generation.” (Buru Energy Investor Presentation, 15 September 2015).
As part of a PER-level assessment the EPA must consider the potential displacement of renewable energy and resulting environmental and social impacts, including pollution and reliability, if Buru Energy succeeds in developing and selling its ‘Rafael’ gas and oil condensate to Kimberley towns, mines and remote communities as it proposes.
Yours Sincerely,
[Your name will be automatically added]
