Dear Professor Tonts,
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
- The International Energy Agency and IPCC clearly and unequivocally stated that NO new coal, oil or gas provinces or fields should be opened if we are to avoid the worst impacts of global heating
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
- Code of Practice
- Early and ongoing engagement with local communities
- 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 be assessing this proposal.
I call on the EPA to stop assessing 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 include the following in the EPA’s Environmental Scoping Document:
- The latest climate change modelling, including extreme weather events and flooding, incorporated into all aspects of the EPA’s review.
- Climate related impacts on all environmental factors, from scope 1, 2 & 3 greenhouse gas emissions (including estimated fugitive emissions) from the proposal over its lifetime.
- Consultation with and studies into the significance to Traditional Custodian groups in the area of the impacts on fauna, flora and vegetation (eg. bush food and medicine trees).
- Full accounting of potential fugitive emissions (e.g. methane) from drilling and fracking operations, including via well integrity failure, faults and fractures, and induced seismic activity.
- Identify how flowback water will be safely stored, treated and disposed of with regard to risks to human and environmental health.
- Identify how contamination of surface and/or groundwater by flowback water will be mitigated.
- Identify how overflow of wastewater ponds from flooding/extreme rainfall events will be mitigated.
- Identify how flooding risks due to heavy rains particularly in wet season will be mitigated.
- Assess the cumulative impacts on the environment, health and communities.
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