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The Conservation Council Western Australia has this week revealed that Woodside’s attempt to shortcut the environmental approval process has been knocked back for a critical component of its massive Browse gas proposal.’
According to CCWA this has taken place just weeks after it was revealed that the WA EPA has deemed Browse gas “unacceptable” due to multiple serious environmental risks to endangered turtles, blue whales and the pristine Scott Reef.
Freedom of Information documents have revealed that Woodside’s attempt to add offshore carbon dumping (CCS) to an existing application was rejected by the Department of Climate Change, Energy, the Environment and Water in August 2023.
The DCCEEW said the new proposal was “fundamentally different”.
The rejection came just one year after Woodside, who appeared at a Senate Environment and Communications Legislation Committee inquiry this week, described offshore carbon dumping at Browse as “high risk, high cost” and “unproven” in a 2022 application to the federal regulator.
Risks identified by the Department in rejecting the amendment included the potential impact of carbon dioxide leaking from wells or under the seabed, making nearby waters including Scott Reef more acidic.
Proposed seismic blasting, drilling and traffic and light pollution risked harming marine animals including endangered whales.
Browse, Australia’s largest untapped conventional gas field, is located off the coast of the pristine Kimberley region in WA, beneath the extraordinary Scott Reef.
According to CCWA Woodside already proposes to drill more than 50 wells around the Scott Reef system and pipe Browse gas more than 900 km along the ocean floor to the North West Shelf / Karratha Gas Plant at the Burrup Hub to be processed for export.
Woodside’s Browse gas proposal would involve the first time offshore carbon dumping has been tried in Australia.
According to the FOI documents, Woodside has advised the Department they would resubmit their application this year, years after commencing the environmental approval process for Browse.
The news comes as Woodside’s application to extend North West Shelf, the oldest, largest gas plant in Australia, is shortly to be decided by the WA Government following a two-year appeals process plagued by issues.
The WA EPA previously concluded the proposal posed a threat of “serious or irreversible damage” to UNESCO World Heritage nominated Murujuga rock art.
Jess Beckerling, the Executive Director of the Conservation Council of WA, said: “Woodside’s attempt to amend its Browse gas proposal to include carbon dumping, which it admitted was “high risk, high cost” and “unproven” just two years ago, has been knocked back by the Department.
“There has never been an offshore carbon dumping project in Australia, but Woodside is proposing to try this failed technology for the first time at the pristine Scott Reef.
“Carbon dumping is fantasy technology that doesn’t work, as we’ve seen with Chevron’s Gorgon facility, and it introduces a raft of new risks to the Browse gas proposal.
“It doesn’t meaningfully reduce emissions and it could have catastrophic impacts on Scott Reef in the event of a leak and will significantly increase drilling, seismic activity, traffic and light pollution in this highly sensitive marine environment.
“The only thing that carbon dumping has achieved is to extend the life of the fossil fuel industry but it can’t save Woodside’s Browse proposal.
“Woodside has tried over and over to make offshore carbon dumping work just like they’ve tried for years to make Browse stack up – they can’t.
“Multiple authorities have now knocked back Woodside’s reckless approach to Browse gas because the risks are too high. The state and federal government need to do the same and put this proposal out of its misery.”
The facts
In 2022, Woodside stated that offshore carbon dumping (“geosequestration”) was “high risk, high cost” and “unproven”. This was in its application to build its massive Browse offshore gas development at Scott Reef, in which it rejected carbon dumping.
In 2023 Woodside tried to amend the Browse application to include carbon dumping, insisting it was safe and proven. FOI documents show the Federal Government told Woodside it would reject the short-cut application citing numerous environmental risks from carbon dumping.
The letter stated that carbon dumping was in its “infancy” and that the damage it causes needs full assessment. This included: “CO2 toxicity”; risks of earthquakes; risks of leakage; marine impacts of ongoing seismic blasting required for monitoring; additional drilling impacts.
Woodside is now preparing a new application for full assessment by the federal Environment Minister – just one of many approvals it needs. The complex web of approvals needed under different laws has never been used before, and so is completely untested.
Woodside is yet to apply for any of these approvals and would be among the first to ever apply. Assessment is likely to take years.
Gas companies are not required to pay for the privilege of dumping their waste in public land. Instead, the government offers them crucial fiscal support. Woodside’s proposal, like all offshore carbon dumps, would benefit from the federal government providing a long term indemnity, for free, for things going wrong in the future.
Woodside’s blank cheque on long term damage would be similar to the indemnity given to Chevron’s Gorgon carbon dump, which is listed in every federal budget paper as a “contingent liability – nquantifiable”.
Woodside’s original proposal
In 2018, Woodside applied for federal environmental approval to build the Browse offshore gas project around Scott Reef, off north-western WA. Browse would produce up to 1.6 billion tonnes of CO2e over a period of up to 44 years. The gas would be sent by nearly 1000km of subsea pipeline to Karratha to be processed, almost all of which would then be exported via the North West Shelf LNG facilities (NWS).
The Browse gas reservoirs contain very high levels of CO2 (7-12%), higher than most gas projects. In the 2019 draft environmental impact statement (EIS), Woodside proposed to separate this CO2 from the usable methane and dump the CO2 into the atmosphere.
This is standard practice for gas projects. Vented reservoir CO2 emissions from Browse would be around 5 million tonnes a year. This is more than 1% of Australia’s total current emissions.
While large for one emissions source, note this is less than half the operational emissions from Browse, and a tiny component of the overall emissions from the project, around three quarters of which come from burning the product.
In the 2019 draft EIS, Woodside briefly considered ‘geosequestration’, or subsea dumping, as a way to prevent this CO2 from entering the atmosphere. But it notes there are: ”significant technical, operational and safety risks … technical feasibility as offshore geosequestration at the required scale is unproven. … Geosequestration is, therefore, a high risk, high cost mitigation option for Browse reservoir CO2” (page 698).
The July 2022 supplement to the EIS takes the same position: “geo-sequestration was assessed as presently being a high risk, high cost mitigation option for Browse reservoir CO2”. (page 120)
Woodside’s carbon dump proposal
A year and a half later, Woodside applied to include a carbon dump (“carbon capture and storage” or CCS) in the Browse project application. (FOI, requested by Greenpeace Australia). The application stated (page 4): “Since the time the EIS was prepared, the [Browse Joint Venture] BJV has continued to investigate the feasibility of CCS. Engineering and technical studies have now advanced to a stage where the BJV considers CCS to be part of the base case development concept. The BJV has now commenced the process to obtain regulatory approvals for CCS.”
Woodside stated the carbon dump should be included by amendment in the current application for approval, as: “the injection of CO2 as described in this document presents no increase in impacts to
[Matters of National Environmental Significance] MNES and no new significant risks or impacts, when compared with those contemplated by the current action and as described in the EIS.” (page 5)
Government concerns about direct impacts
The Minister’s delegate quickly advised that they intended to reject the proposal, citing a long list of significant environmental risks and impacts a carbon dump would pose. The delegate stated: “I am not satisfied that the character of the varied proposal is substantially the same as the character of the original proposal”. (page 253 of the FOI)
These impacts would substantially change the project, meaning Woodside would need to make
a brand new application for the carbon dump. The delegate points out that Woodside’s EIS did
not include carbon dumping because it was high risk, and even says that if Woodside wanted to
build a carbon dump they would apply for it separately.
The delegate then goes on to describe new risks and impacts caused by the carbon dump:
● “CO2 toxicity in general and localised ocean acidification may arise if a loss of well control event occurs”
● “a new environmental risk of reinjected CO2 escaping from the Calliance reservoir via a number of pathways, such as failed well barriers, induced fracturing of capping rocks when reinjection occurs, or escape through faults.”
● “successful CCS programs in offshore environments are complex to execute because the technology is in its infancy, and residual uncertainty would remain”
● “CCS will likely require long-term monitoring of… will likely require seismic surveys over the >40-year life of the project, which would generate noise that can injure and adversely affect biologically important behaviours of marine fauna, including cetaceans that are listed as threatened under the EPBC Act.”
● “additional drilling activities and installation of flowlines, resulting in direct and indirect
impacts,” (pages 259-260 of the FOI)
Recent public documents from Woodside state that it is preparing a new separate EIS for the Browse carbon dump. Notes from meetings with DCCEEW in May 2024 say they expect to submit it mid-2024.
Assessment complex and untested
Woodside would need a raft of approvals before they could start their carbon dumping:
● approval under the Environment Protection and Biodiversity Conservation Act 1999;
● a title and relevant permits from NOPTA under the Offshore Petroleum Greenhouse Gas Storage Act 2006 (OPGGS Act);
● a permit under the Environment Protection (Sea Dumping) Act 1981; and
● acceptance of various environment plans by NOPSEMA under the OPGGS Act.
None of these laws and regulations have ever been used for an offshore carbon dump. The regime is completely untested.
The government agencies appear unclear on how the different processes interact with each other, citing that certain steps are merely “anticipated” prior to others and urging applicants to keep information consistent across approvals. The sea dumping forms emphasise assessment will take more than a year and urged applicants not to sign contracts prior to receiving all approvals.
Woodside currently holds a Greenhouse Gas Assessment Permit over the relevant Browse title with assessment work due to be completed by August 2028. In June 2024, several blocks within this title were declared as an identified Greenhouse Gas Storage Formation under the OPGGS Act. This is the first step under the OPGGS Act towards enabling its use as a carbon dump.
Woodside has not yet applied for further required permits from NOPTA or a sea dumping permit from DCCEEW, lodged an EPBC referral with DCCEEW, nor submitted any environmental plans to NOPSEMA for assessment.
Increased emissions
One impact not considered by DCCEEW in its 2023 intention to reject Woodside’s variation is climate change. Using the carbon dump as an excuse to build the project will lead to significant new emissions, not a reduction in emissions.
Woodside states the Browse carbon dump would store 62 million tonnes of CO2 over the life of the project. This optimistic figure is not even all of the reservoir CO2 from the Browse project–it’s only around a quarter of the direct project emissions (scope 1), and a tiny share of lifecycle emissions. There is also a risk to the climate of the CO2 escaping. As the delegate said in their rejection, this is a technology in its infancy.
The timing of any such failure of the carbon dumping project is key for who is responsible:
- If this should occur during the injection phase, Woodside and partners would be liable for these emissions.
- If this occurs after the Browse project has closed the liability will then be indemnified by the Commonwealth.
