The Arid Lands Environment Centre (ALEC) is the peak regional environmental organisation in Central Australia. ALEC’s vision is for ‘healthy futures for arid lands and people’. For 36 years ALEC has worked both on the ground and on government policy to ensure good environmental outcomes for the long-term benefit of Territorians.

ALEC is staunchly opposed to the proposed Northern Gas Pipeline (NGP) due to its enabling effects on the Northern Territory onshore gas industry.

It is pertinent to consider this project in the context of the previous NT Government’s failed economic agenda. The Giles/Tollner Government spent millions of taxpayer dollars on promoting the onshore gas industry while significantly weakening the environmental safeguards supposed to regulate the industry. The Giles Government set the timeline and process in motion for this project, which has been described as the ‘whitest of white elephants’ in an Institute for Energy Economics and Financial Analysis report in May 2016[2]

In December 2015, Australia signed up to the Paris Agreement and is now in the process of ratification. The agreement seeks to limit global temperature rise to 1.5C, with the upper limit being 2C. This global target requires 80% of all known fossil fuel deposits to remain unburned and in the ground[1].

The stated economic justification of this project ‘stimulating the development of the Northern Territory through increased gas exploration and production’ and ‘providing a new source of competitively-priced clean, reliable energy to eastern Australia’ is in direct conflict with Australia’s meaningful participation in the Paris Agreement to reduce global emissions.

The cumulative impacts of this enabling project need to be considered as part of its environmental assessment. This is not currently the case.

Rural, remote and urban residents of the Northern Territory have expressed serious concern about the impact of fracking on groundwater and the environment, which has seen the newly elected Labor Government deliver the moratorium on fracking. It would be environmentally and economically irresponsible to allow this project to proceed while the moratorium on fracking is in place.

Project specific shortcomings and concerns identified by ALEC in the Jemena EIS.

• The principles of ecological sustainable development cannot apply to this project due to its proposed enabling impacts on the gas fracking industry and the future implications for both groundwater and greenhouse gas emissions.
• The ownership and operation of the pipeline, by Jemena that is a conglomerate of foreign state-owned utilities China State Grid (60%) and Singapore Power (40%) with recent issues raised about the restructuring of the company to reduce its tax liability in Australia [3].  
• Only 13 permanent jobs in the NT are forecast.
• The Mines Minister can approve the project, the NTEPA is not even listed as a stakeholder
• The reliance on desktop research and one fly-over to assess biodiversity and bilby habitats.
• Lack of clarity around evaporation ponds at the compressor stations and wastewater management.
• The EcOz Figures Volume 1 (2.2,2.3,2.4, 2.5, 2.6) all have disclaimers of warranty for every part of research they were involved in, yet the EIS is based on their work – who’s accountable?
• No Hydrostatic Test Management Plan (Sect 7.6.5)
• No specific details on methods and techniques of crossing watercourses  (2.13.5)
• Risks of wildfire spread in construction with only one fire truck in Tennant Creek and one fire trailer proposed
• Water Act – clarity needed as to whether this project is exempted from the Water Act as a petroleum activity
• Groundwater drawdown in a semi-arid areas with a lack of research and knowledge of potential water source. There needs to be a whole of life cycle analysis of the cumulative water impacts this project would have to obtain a viable amount of gas through the 30 year period.
• Construction timeline does not consider the variable and unpredictable climate of the Barkly, the risk of heavy rain impacting on the project is high.
• Weed hygiene and the creation of a weed corridor through 600kms of relatively pristine country.
• Social Impact Assessment is incomplete.
• Air management plans are inadequate.
• Traditional Owners and Native Title Holders have not given consent for this project to proceed.
• Biodiversity surveys, particularly the Bilby surveys were only completed in April, May and June – given the 18 month construction timeline, more seasonal ground surveys need to be conducted to ensure minimal impact on threatened species.

ALEC recommends that this project not be allowed to proceed based on its expressed justification to stimulate the Northern Territory onshore gas industry.  The development of shale gas by fracking is not sustainable and cannot be allowed to proceed if Australia is to honour its commitments under the Paris Agreement.

Time, energy and money spent on developing fossil fuel ventures is wasted money and ALEC recommends that the proponent instead seek opportunities to invest in renewable energy projects in the NT. 

[1] http://www.yesmagazine.org/issues/life-after-oil/why-we-need-to-keep-80-percent-of-fossil-fuels-in-the-ground-20160215

[2] http://ieefa.org/wp-content/uploads/2016/05/Pipe-Dream-A-Financial-Analysis-of-the-NEGI-MAY-2016.pdf

[3] http://www.afr.com/news/policy/tax/jemena-funding-arrangements-raised-with-the-ato-20160610-gpgk63

Public comment on the Jemena Northern Gas Pipeline EIS closed Friday 7^th October.