> AGL has provided the EPA with incomplete and misleading responses, and now we have until Wednesday"> > AGL has provided the EPA with incomplete and misleading responses, and now we have until Wednesday">
Uncategorized | 29th Mar, 2021

Hold AGL accountable by writing your submission to the EPA

The Environmental Protection Authority (EPA) is currently assessing AGL’s plans to build a gas import terminal in Westernport Bay.

During last year’s public hearings of AGL’s Environment Effects Statement (EES), the EPA made clear that AGL’s reports lacked the key information necessary to assess their works approval application.

Because of this, AGL was served a ‘Section 22 Notice’, requiring them to answer 25 questions on how their gas import terminal would be compliant with Victorian regulations. You can see the EPA’s questions here >>

AGL has provided the EPA with incomplete and misleading responses, and now we have until Wednesday 31 March to send our comments. Help us hold AGL accountable by filling out the EPA survey >>

The EPA will decide on AGL’s works approval application one month after they receive Minister’s Wynne decision on the EES process. The EPA’s assessment is independent from this decision, and if they find AGL’s response is inadequate, this could potentially stop the project by itself.  

This is another opportunity to protect Westernport Bay’s Ramsar wetlands and to stand with the Westernport community.

Make a submission by filling out the epa’s survey

Information for your submission

We have prepared the material below to help you in filling out your submission. The questions we have included are those that are most likely to impact AGL’s plans to get a works approval:

Survey Question 1. Please provide your comments below regarding AGL’s response to s22 (Questions 1 – 4) 

  • In broad terms AGL was requested to explain (1) How the wastewater discharges from their gas import terminal could “provide water for the environment” (2) How the wastewater would be used in any way beyond simply being disposed of, and (3) Provide info on whether their wastewater could be treated and managed to a level to protect beneficial uses.
  • AGL contends that providing water for the environment is not relevant to the EPA’s assessment, despite it being specified as a requirement in the explanatory note to clause 22 of the SEPP (Waters)
  • AGL’s argument that discharging cold, chlorinated water into Westernport Bay should be considered as “providing water to the environment” is ridiculous as (1) the environment will not be benefited by polluted water and (2) the sea does not benefit from more water.  AGL directly disposing their wastewater directly into Westernport bay only benefits AGL.
  • AGL’s case that disposing wastewater into the environment could be qualified as their polluted water being “re-used” or “re-cycled” is simply outrageous.
  • If AGL wants to argue that exceeding environmental would not put beneficial uses at risk, they should have provided information to back that claim up.

Survey question 2. Please provide your comments below regarding AGL’s response to s22 (Question 8) 

  • Leave blank.

Survey question 3. Please provide your comments below regarding AGL’s response to s22 (Question 12) 

  • Leave blank.

Survey question 4. Please provide your comments below regarding AGL’s response to s22 (Question 7) 

  • Leave blank.

Survey question 5. Please provide your comments below regarding AGL’s response to s22 (Question 16) 

  • Leave blank.

Survey question 6. Please provide your comments below regarding AGL’s response to s22 (Question 13) 

  • Leave blank.

Survey question 7. Please provide your comments below regarding AGL’s response to s22 (Question 5) 

  • AGL has not properly addressed its duty to avoid the generation of wastewater as it is stipulated by Clause of the SEPP (Waters). 
  • Characterising the discharge hundreds of millions of litres of polluted water using as an example of ‘re-use’ or ‘re-cycling’ is misleading. Disposing waste products is the opposite of recycling or reusing. 
  • Disposal is a better term as AGL is not planning to contain, treat or recycle their wastewater. 
  • AGL argues it is choosing to proceed with its open loop to avoid emitting carbon pollution.  Asking the EPA to assess what is preferable between climate action and the protection of the local environment shows how this project is deeply flawed. 

Survey question 8. Please provide your comments below regarding AGL’s response to s22 (Question 6) 

  • Leave blank. 

Survey question 9. Please provide your comments below regarding AGL’s response to s22 (Question 9) 

  • The lack of evidence on the area of water that will exceed the proposed guidelines values for temperature and chlorine-produced oxidants due to the FSRU’s wastewater means the project’s application should be rejected. 
  • The burden of proof on whether AGL is adopting all the “reasonably practicable” measures to avoid exceedance to the environmental quality objectives is on AGL. AGL cannot expect to benefit from the lack of information it provided to the EPA. 

Survey question 10. Please provide your comments below regarding AGL’s response to s22 (Question 11) 

  • Leave blank.