SUBMISSION POINTS – Jemena Northern Gas Pipeline

Comment on the Draft Terms of Reference for the proposed gas pipeline today!

The Northern Territory Government has announced Jemena as their preferred company to build a gas pipeline from Tennant Creek to Mt Isa. The NT EPA has determined this pipeline project will need to be assessed with a full Environmental Impact Statement (EIS).

The first round of public submissions is on the draft Terms of Reference (TOR). The TOR will guide Jemena on what they need to include in their EIS.

Please use this opportunity to share your thoughts on the proposed gas pipeline. Submissions are open until Monday morning 14 December.

Below Frack Free NT has provided some points that we feel are lacking from the EPA’s draft Terms of Reference.

Please cut, paste, add in and edit these points and your own, then email your comments to by Monday morning 14 December to:

Alana MacKay via email: eia.ntepa@nt.gov.au 

Feel free to also CC in Chief Minister Adam Giles: Chief.minister@nt.gov.au

See the full draft Terms of Reference by the EPA here.

See the project plan submitted by Jemena for the pipeline here.

Ideas for your comments on the draft terms of reference:

In their first public media statement as the successful bidder for the pipeline, Jemena Managing Director Paul Adams said the pipeline would be a “catalyst to fast track development of the NT’s gasfields”.

If the pipeline is in fact a driver of fracked gas development, Jemena must discuss in their EIS any risks our water, conflicts involving landholder rights and any negative economic impacts on other industries like farming and pastoralism, plus the emissions and leaks from gasfields required for the pipeline.

In the Draft Terms of Reference, Section 2.2.2, Workforce, should provide the exact details of the training programs run by the company, considering the very short time frame for construction. Exact figures on how many local Indigenous people will be employed on a long-term basis should be provided.

Expand Section 2.6, Ecologically Sustainable Development, to request an outline of the ecological consequences of the new gas developments required to fill the proposed new gas pipeline.

In Section 4, Socio-economic Aspects, include justification  of why the pipeline is being built.

The EIS should justify the project’s economic feasibility in light of the following economic risks surrounding the project:

·      The difficulty in sourcing long-term capacity agreements to underpin it,

·      Who will pay the tariffs?

·      Finding buyers considering the international gas glut and low global oil prices, and lack of demand in the eastern gas markets,

·      Logistics and remoteness constraints,

·      Relying on commercially unproven gas reserves for future gas requirements of the pipeline, and the fact the NT unconventional gas will not be competitive for buyers in a global market.

Section 4 on Socio-economic Impacts should also be expanded to include the impacts of the three FIFO workers camps required for the project, the known social and poor mental health impacts from Fly In Fly Out (FIFO) camps and any measures to alleviate impacts.

Expand Section 5, Risk Assessment, to specifically require detailed geotechnical and engineering explanations in regards to the pipeline being built on a nationally listed earthquake hotspot.

Specifically request detailed information regarding flood risks, as the pipeline will cross eight major river systems in the Gulf country of the Northern Territory. Oil and gas pipelines have been known to burst in flood events around the world. The proponent must outline how the pipeline will be engineered to ensure this doesn’t take place.

In Section 5.3, Cumulative Impacts, the TOR must include calculations and scenario planning of how many shale gas wells are likely to be required to be fracked across the Northern Territory in order to make the pipeline financially viable.

All cumulative impacts should be listed and a summary provided of water use, waste production, land surface impacts, well failure ratios, public health impacts and the baseline studies required as part of any onshore gas development in the Northern Territory.

With new science from the United States shale gasfields showing large amounts of methane spewing into the atmosphere, the emissions from the gasfields required to fill the pipeline must also be considered as a cumulative impact.

In Section 5.5, Water, the TOR should require Jemena to outline detailed plans for the diversion of the rivers and waterways that would be required to take place.

What methods of water diversion or otherwise will be used and what are the downstream impacts? What delays in construction may be unavoidable to ensure seasonal sensitivity and lowest possible impact?

Section 5.7, Human Health and Safety should be expanded to include a point on mental health impacts from FIFO situations.