Email the Department | Dalby Extension Project/Lynwood gas station submission guide

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Add your concerns to the email below to create a unique submission. The information below provides some details that the Department should consider when reviewing Arrow’s massive gas plant proposal.

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Subject:

Dear Manager Assessment,

RE: Submission on the Environmental Authority Amendment Application for the Dalby Expansion Project – A-EA-AMD-100829511

The application should be refused on the basis of its contributions to impacts to public health,  impacts on surface and ground-waters, greenhouse gas (GHG) emissions and consequent climate impacts, impacts to biodiversity. The project would adversely affect the character, resilience and value of the receiving environment and the project is contrary to the public interest.

The application should be refused because the development for which approval is sought does not improve the total quality of life, either now or in the future, in a way that maintains the ecological processes on which life depends in accordance with ss 3 and 5 of the Environmental Protection Act 1994 (Qld) (EP Act). The application should be refused as the project is inconsistent with the standard criteria under Schedule 4 of the EP Act, particularly criteria (a)(i)-(iii), (b), (e) and (i).

Approval of the application is not compatible with human rights and is therefore unlawful under the Human Rights Act 2019 (Qld) (HR Act).

The proposed project is inconsistent with the precautionary principle - standard criteria (a)(i). The precautionary principle provides that “where there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation”.

- Health risks: Arrow Energy’s Lynwood gas compressor station, which is proposed to be built less than 9km from Cecil Plains and its 400 residents, puts the health of local residents, farmland, ecology and water resources at risk via toxic air pollution and risks of contamination to water.

Dangerous chemicals are released into the air including volatile organic compounds, polyaromatic hydrocarbons, nitrogen oxides, radioactive materials, diesel fumes, hydrogen sulfide, acrolein and heavy metals. Additional chemicals form in the atmosphere, including formaldehyde, particulate matter from aerosols and ground level ozone, which travel long distances damaging health and agriculture.

Reported health risks for those living in proximity to gas facilities include increased severity of asthma in children, higher hospitalisation and death rates due to heart attacks, heart failure, respiratory diseases and some cancers. Multiple studies have detected interference with normal development of unborn babies. This includes higher risk of low birth weight, pre-term delivery and spontaneous abortion, severe birth defects and risk of acute lymphoblastic leukemia.

The 16 gas engines which will operate the 4 gas compressors at Lynwood, will create a cocktail of noxious emissions on a daily basis including over 1 tonne of oxides of nitrogen and over 2 tonnes of carbon monoxide per day.

Arrow has failed to include assessment of other noxious air pollutants in their application, despite these being produced at their other existing gas compressor sites, as reported to the National Pollutant Inventory. These air pollutants represent a long-term risk to human health for local residents.

Arrow’s 2023-25 Plan of Operations for the Dalby Expansion Project will double the size of Lynwood at a future date from the currently proposed 4 compressors to 8. This proposal is the start of a mammoth future gas processing facility and toxic emissions in harmful proximity to regional residents and young families.

- Insufficient baselines: the air quality data to establish background air quality levels for assessing cumulative impacts for Cecil Plains has been taken from the Miles Air Quality Monitoring Station (AQMS), which has now ceased to operate.  Miles is 130km from Cecil Plains, and has existing industrial uses, therefore does not provide an accurate air quality baseline for Cecil Plains.

- Pollution must be monitored: Arrow’s proposed mitigation actions for air pollution include “Implement a quantifiable monitoring and measuring program” but that program is not included. The gas industry decommissioned the air quality monitoring network in the Surat Basin in 2023. Despite the industry’s continual expansion, alarmingly there is now no air quality monitoring in the gasfields of southwest Queensland.

- Dust, Light, Noise and traffic impacts: Arrow’s proposal poses significant impacts during the construction and maintenance phases, through dust, light, noise and a hazardous increase in traffic density through our quiet rural town. The substantial increase in traffic movements through town will pose a significant safety hazard to young children who regularly cross the main road between the school, library and park. The flare will cause extreme light, noise and even vibrational impacts to nearby residents.

- Community consultation: Arrow Energy has failed to consult, engage with and keep the community informed about their plans to go ahead with the construction of the Lynwood compressor station.  There has not been a community information session in the local area since 2021.  This is a breach of their coexistence commitments, including those made during the EIS process.

- Impacts on Biodiversity: Arrow is seeking approval to the company to clear 132 hectares of native vegetation, much of which is protected wildlife habitat for the Koala, Grey Snake, Diamond Firetail, Death Adder, Greater Glider, Yellow-bellied Glider, Glossy Black-cockatoo, Brigalow Woodland Snail and Painted Honeyeater. There is a real risk that this Project has a serious or irreversible impact on these protected species.

- Ozone pollution: the intensification of gas processing infrastructure could affect agricultural yields and wildlife. Arrow needs to examine these impacts and the Government must impose additional conditions to protect the community, farming and nature.

- Greenhouse Gas pollution: According to company documents, the Lynwood gas plant will cause an additional 70,000 tonnes of greenhouse gas emissions (scope 1) on average per year, equating to over 1.25 million tonnes of additional greenhouse pollution in Australia over the course of its lifetime. These figures are based on estimates and not on actual measured emissions across the Surat Gas Project footprint. The Project involves the addition of a compression station at Lynwood, which will facilitate the ongoing roll out of the Surat Gas Project. The proponent argues that the GHG emissions from the Project have already been assessed under the EIS assessment of the broader Surat Gas Project of which the Project is a component. This approach is incorrect, and the department should consider the emissions facilitated by the amendment application as additional emissions. Australian scientists are concerned about the lack of measured fugitive gas emissions in Queensland gasfields, calling for baseline studies to be undertaken. Research by the International Energy Agency shows that actual methane emissions could in fact be double those recorded in Australia.

The precautionary principle provides that “where there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation”.
The impacts of climate change contributed to by the Project’s continued accretion of GHG emissions, the impacts of the Project on biodiversity, and the impacts of the Project on groundwater and surface water, present a real risk of serious or irreversible environmental damage, such that approval of the Project would be inconsistent with the precautionary principle.

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