1. Scott Reef is a 15 million-year-old marine biodiversity hotspot which is already under pressure from global warming, rising sea temperatures and coral bleaching caused by fossil fuel burning.

2. Scott Reef is home to an amazing variety of reef habitats and marine species, including, 

• Corals down to 70 metres depth in the unique Deep Lagoon on South Reef; 
• Population of 1000 genetically unique Green turtles that nest only on Sandy Islet and Browse Island;
• Four species of whale recorded in the Scott Reef region - Pygmy blue, Humpback, Bryde’s and Dwarf minke;
• In 2008, over 3000 dolphins were recorded from at least 10 species, including Spinner;  Bottlenose; Short-beaked, and two ‘oceanic dolphins’: Pilot ‘whales’ and False killer ‘whales’;
• Scott Reef is potentially the last stronghold for the endangered Dusky sea snake - it hasn't been sighted anywhere else since 2002.

3. The changes Woodside is proposing do not remove the unacceptable risks and impacts of a large scale gas extraction, processing and piping project in the midst of a unique and globally significant coral reef system.

4. The technological fixes Woodside is proposing may reduce some impacts and risks but the significance of the reductions is overstated. For example, Woodside says,

Underwater noise modelling conducted in support of the Browse EIS/ERD and summarised within the Pygmy Blue Whale Management Plan published as part of the Response to Submissions estimated that the underwater sound source level from a dynamically positioned MODU operating at Torosa would be up to 182.8 dB re 1μPa. The noise from drilling activities from a moored MODU when drilling is estimated to be lower, at 170.1 dB re 1μPa.

In other words, the reduction in noise would only be about 6.6%. Woodside selectively claims this small reduction would be significant for some species, but such claims must be independently verified.

5. In relation to the proposed use of ‘pyrotechnic shear ram’ technology, Woodside claims, 

Within the ERD, it was noted that the worst ‘worst case credible’ scenario arising from Torosa drilling activities could result in a 77 day loss of containment event, releasing up to 142,154 m3 of condensate. Evaluation of pyrotechnic shear ram technology determined that the longest credible duration of a blowout would be 12 hours.

To support the adoption of this technology Woodside cites an independent expert report it commissioned which also states, 

There remains a risk no matter how small that the K-BOS [pyrotechnic shear ram] when activated does not function and this needs to be identified in any probabilistic analysis.  

[Independent Review of Well Blowout Risk Management at Torosa. Stuart and Wright. 2024]

The expert report also makes it clear that adoption of this technology does not mean Woodside could abandon the other 'loss-of-containment' measures it has already committed to, in order to save money.

6. Woodside’s Browse fossil gas extraction project on Scott Reef can never be made environmentally acceptable. Woodside’s proposed modifications do not change that underlying reality. 

While the EPA may choose to accept these changes on the basis that they do not make the project worse from an environmental standpoint, they cannot be used to claim that the overall project has now become acceptable. The EPA must stick with its ‘preliminary view’ that the Browse/Scott Reef fossil gas project is environmentally unacceptable and reject it accordingly.