Thank you for the opportunity to comment on this proposal to frack twenty wells in the Kimberley. I make my comments below.
The Kimberley has the largest, most intact tropical savannah in the world, which is home to many threatened species. It is a national and international tourism icon for its intact landscapes and vibrant living Aboriginal culture.
I call on the EPA to reject fracking in the Kimberley for the following reasons –
- Fracking could result in thousands of oil and gas fracking wells across the Kimberley
- Fracking involves the use of large volumes of toxic chemicals
- The industry entails drilling and fracking through aquifers, with serious risks of pollution
- Flowback fluid is likely to contain radioactive material, as in previous fracking operations
- Liquid waste ponds have overflowed in the Kimberley in the past during heavy wet season rainfall events – this is unacceptable
- The absence of World’s Best Practice, e.g. storage and disposal of flowback fluid in open ponds instead of closed bladders
- The process of fracking requires wastewater reinjection as well as the pumping of large volumes of water, proppant and toxic chemicals under extreme pressures, and has been known to cause earthquakes – this has been well documented and was an important factor in the banning of fracking in the UK
- The oil and gas fracking industry undertakes seismic surveys on the ground which requires large scale land clearing. This often requires very large areas of habitat to be destroyed, with grid patterns of cleared land severely damaging the landscape values of the tropical savannah.
I note that the WA Government has committed to an ‘Implementation Plan’ for fracking that includes a number of actions that have yet to be completed, including –
- Veto rights for Traditional Owners
- Veto rights for freehold land owners
- Iconic Natural Heritage Places to be protected from fracking
- Code of Practice
- Early and ongoing engagement with local communities
- Public Health Impact
- Penalties (environmental compliance tools)
- Financial assurances
Given that these actions and others have yet to be finalised, and it is unknown which of them will require legislative changes, it is premature for the EPA to make a decision on this proposal.
We call on the EPA to delay any decisions on this proposal until the WA Government’s ‘Implementation Plan’ is finalised.
If the EPA does not reject this proposal then I strongly recommend the proposal to be set at the Public Environmental Review level. Reasons for this are:
- The extremely high level of public interest
- The proposed destruction of threatened species habitat
- Groundwater drawdown potentially affecting stygofauna
- The sensitive location – Fitzroy River catchment
- Risks of pollution
- Greenhouse gas emissions