Submission of Appeal
On Monday 30th July 2012, we submitted an appeal against the content of the Report and recommendations of the Environmental Protection Authority (EPA) for the Browse Liquefied Natural Gas (BLNG) Precinct (Report #1444). Our main concerns are that sound scientific methods have not been used to support the environmental impact assessments associated with this project and that there is a high level of uncertainty over the potential impacts of the development.
The grounds for our appeal fall into the following inter-related categories:
(i) Dolphins: There is a lack of baseline data available on dolphin populations in the area on which to base assessments of the potential impacts of the development;
(ii) Marine fauna and amendments in proposed activities: There are numerous contradictory statements on the information used to assess the potential impacts of the BLNG development and the recently proposed increases in the scale of the development have not been assessed;
(iii) The precautionary principle: The potential impacts of the development on marine fauna were deemed insignificant at the population level, but this conclusion does not appear to be based on sufficient data or internationally recognised techniques to assess the sustainable levels of human impact on wildlife populations.
With regard to dolphins, in particular, insufficient data exists on the distribution, population abundance and habitat use of any of the dolphin species in the area, including, but not limited to, the listed migratory species: Australian snubfin and Indo-Pacific humpback dolphins. The EPA’s report acknowledges that there may be species of dolphins, such as a small morph of the spinner dolphin, occurring in the proposal area that were not identified by the proponents. Thus, the EPA has little grounds upon which to assess potential impacts, at the population level, for dolphin populations that occur in the area.
We have subsequently recommended that the approval of the BLNG development by the EPA be reversed until the proponent has provided adequate information on all marine mammal populations that occur in the region. This would allow the EPA to make an informed assessment of the likely impacts of the BLNG development. This additional information should include: species diversity, population abundance, distribution, habitat use and the degree of connectivity between populations in the region.
The onus should fall on the proponents of development to reduce uncertainty over the potential impacts on marine fauna if the development is to proceed.