Proponent: Blue Energy Limited on behalf of title holder Eureka Petroleum
Location: Moranbah / Glenden
Disturbance area: Maximum 1,046ha
Life of facility: 20 years
Gas reserves: 363 petajoules (pj) of reserves and 1,278 pj of contingent resources (probably an underestimate)
Latest update – a legal challenge
EnvA has engaged the fabulous legal team at the Environmental Defenders Office to challenge the Queensland government’s approval of an environmental authority for this project! The reasons we are challenging are outlined below. If you can chip in a donation, it would be really appreciated. Legal challenges are costly, but we fully believe that we need to send a strong message to the Queensland Government that our environment and climate are more important than a company’s profits and the small economic contribution to the State. We know that we bear most of the costs in recovering from natural disasters, loss of local water supply and the loss of tourism as climate change continues to threaten our iconic wildlife and special places like the Great Barrier Reef.
What is wrong with the project?
There is so much wrong with this project! Hence the proposed Blue Energy project is a significant focus of EnvA’s campaign work. Coal seam gas (CSG) is a polarising issue in many, if not all, communities. Proponents argue that CSG is a vital energy resource necessary for continued gas supply. Opponents claim that CSG could have serious environmental and social impacts. We all know that the Bowen Basin has been a key player in the coal resource industry with over 80 mines developed in the region. But did you know that there is currently only one gas project in the Basin? The Moranbah Gas Project has been operated by Arrow Energy since 2004 (in a joint venture with AGL Energy) and services the Townsville Power Station and industrial market. Arrow sees this project as an appraisal project which may lead to a phased expansion into other Arrow resources as part of the Bowen Gas Project. In 2021, the Queensland and Australian governments each committed $5 million a Bowen Basin gas pipeline study. The study investigated the potential for infrastructure to connect gas reserves in the Bowen Basin to the east coast domestic market and overseas customers. The Department of Resources determined that the next step for the project is a structured market engagement process and has engaged a consultant to undertake this work. The aim of the market engagement is to build on the information in the concept study to further identify the commerciality of a pipeline. With the prospects of the development of a pipeline to feed into the east Australia coast and international market, Blue Energy decided to progress with the development of three of their petroleum leases in the Bowen Basin. Blue Energy has already contracted 500pj of gas to Queensland Pacific Metals and the domestic market in Townsville, with hopes to extend the supply to extend into the east Australia market and the global market – pending investment by government or others into a pipeline.
An environmental authority issued without a thorough assessment of the environmental impacts
This is a really frustrating part of this project. The Queensland government issued an Environmental Authority without requiring a a thorough assessment of the environmental impacts across the three lease areas covered by the approval. Here are just a few of the significant issues in the assessment process:
Threatened species and communities
Blue Energy identified numerous threatened ecological communities, flora species, fauna species and migratory species within or near the Project area. Their assessment of the potential impacts on biodiversity was based on a desk-top assessment and rapid field assessments with just one targeted survey in the Sapphire Block (the block with the least vegetation cover). Blue Energy noted that more detailed and targeted surveys will be undertaken which will provide a more thorough understanding of the habitats and species using the Project site. Despite knowing that matters of national and state environmental would be impacted, the Queensland government provided the approval without any detailed survey work on Central and Lancewood blocks, and without requiring Blue Energy to refer their application for assessment under the EPBC Act.
Information request
The Queensland government requested further information from Blue Energy to clarify their proposal and the likely impacts before providing approval for the project. The request was further information on water management, gas and associated infrastructure, soil types, field ecological assessments, and an assessment of habitat connectivity and offset requirements. Blue Energy’s response to the field ecology assessment was to confirm that additional desktop and ground-truthing was completed with this resulting “in a significant reduction in the project scale and intensity” of the proposed wells (see image above as the Sapphire Block example). The revised application notes that the number of well pads can be reduced from 530 to 370 pads along with a 30% reduction in the footprint area. However, Blue Energy considered that this demonstrated their ability to reduce the disturbance area, but still asked that their application be assessed at the original disturbance footprint. The Queensland government accepted this and provided an approval for the original number of well pads and disturbance area, despite the occurance of threatened species and communities and no detailed studies of their distribution across the project area.
Habitat fragmentation and offset requirements
Offsets are required in accordance with the Queensland Environmental Offsets Policy Significant Residual Impact Guideline where there are likely to be residual impacts on threatened species caused by habitat fragmentation. This requires propoponents to assess connectivity values in accordance with the landscape fragmentation and connectivity tool outlined in the guideline. Blue Energy identified important connectivity vegetation for flora and fauna in all three petroleum lease and have committed to field investigations to identify vales and carrying out the impact assessment before site disturbance. Despite the occurrence or potential occurrence of matters of state and national environmental significance, the Queensland government has approved the clearing and fragmentation of habitat on the promise that Blue Energy will do its best to not significantly impact on threatened species and communities and will seek additional or approvals if required. The environmental compliance has been left in the hands of the proponent.
Potential environmental impacts of the Blue Energy coal seam gas project
The following are just a few of the likely impacts of this project.
Ground water
To produce gas from coal seams, water must be extracted first, lowering the pressure so the gas can flow out of the coal. The volume of groundwater extracted can vary significantly between individual wells, coal seams and coal basins, depending on geological conditions. Groundwater extraction may affect the quality and reduce the quantity of groundwater in adjacent aquifers that may be used for landholder water supply or by groundwater dependent ecosystems. The Blue Energy application identifies 404 registered waterbores in or close to their proposed gas wells of which 56 are used for water supply. The impacts on the water supply from these bores for landholders had not been confirmed before the Queensland government provided approval for this project to proceed. We also know that the groundwater impacts are also likely to impact on the nationally important Lake Elphinstone wetland – but there is no assessment of the likely impacts on this important wetland and the recreational opportunities associated with the Lake.
Biodiversity
Blue Energy identifies four threatened ecological communities, 13 threatened plants, 22 threatened animals and 14 migratory species within or near to the Project area. All these species and communities will be directly impacted by the Project through the direct loss and fragmentation of habitat. Other operational activities, such as the gas piplines to transport the gas to market also have the potential to adversely impact on an even broader range of threatened species and communities. The assessment of the potential impacts on biodiversity has been based on a desk-top assessment and rapid field assessments with just one targeted survey in the Sapphire PL1034. More detailed and targeted surveys are yet to be undertaken which will provide a more thorough understanding of the habitats and species using the Project site, but this did not stop the Queensland government providing an approval.
Greenhouse gas emissions
The Project will negatively contribute to climate change and global warming through greenhouse gas (GHG) emissions resulting from the proposed activities. The accretion of GHGs in the atmosphere as a result of human activities has already caused changes in the climate system with tangible impacts, including extreme weather patterns and climate related disasters. Blue Energy recognises that ‘emissions of [greenhouse gases] are of a concern due to their potential to contribute to the greenhouse effect and thus climate change’. However, Blue Energy only addresses emissions from the Project in terms of the potential impact on local air quality. Blue Energy does not provide any assessment of GHG emissions in relation to their contribution to climate change. All we know is that the Project is modelled to access 363 petajoules of reserves and 1,278 petajoules of contingent resources. The Project and the resultant burning of the gas produced will amount to a significant contribution to GHG emissions.
EnvA’s campaign overview
We are still formulating our campaign plan which we will share when finalised. But to start with, what we have done so far:
* Lodged a submission on their Environmental Authority application. Our conclusion was that the project should be refused due to the environmental impacts and the significant greenhouse gas emissions. We also asked that in the alternative to a refusal, and prior to any decision on the Environmental Approval application, that the Project be referred for consideration under the Environment Protection and Biodiversity Conservation Act 1999 (Cth) and a thorough assessment of the environmental impacts be undertaken.
* Written to the Federal Environment Minister asking for her to use her authority under section 70 of the EPBC Act and ‘call in’ this project for a thorough assessment of the direct impacts to MNES and the indirect impacts from the contribution of the Blue Energy emissions to climate change.
* Written to the Queensland Environment Minister requesting that all fossil fuel projects be required to go through an EIS process. Without this, the community has a significantly reduced opportunity to provide public comment on proposals and are forced to make comment with only limited environmental information available.