Have your say on Vopak’s plan for a gas import terminal in Port Phillip Bay

Vopak’s marine assessment is incomplete and misleading: Impacts on the Bay’s underwater ecosystem, including its seabed, fish populations, and threatened species, have not been properly assessed. The EES reaches a conclusion of “no significant impact” using methods that are not transparent, independently repeatable, or grounded in the existing body of knowledge about the Bay’s already-stressed environment.

• Wrong species. Vopak are required to assess species of conservation concern in the project area. Instead, Vopak devoted 110 pages of the marine ecology assessment to species like whales and turtles that don't meaningfully inhabit the Bay, leaving the impacts to species that actually live here - like the endangered Southern Hooded Shrimp and School Shark - without proper scrutiny.
• Flawed fieldwork. Seabed habitats, the area of greatest ecological concern, were assessed using coarse categories that cannot properly predict impacts or recovery. We identified multiple errors in the fieldwork, including misclassification of obvious features like scallops and seaweed. Impact predictions were presented as subjective narrative with assumptions not supported by - and in some cases were contrary to - existing evidence.
• Cable impacts. Two proposed subsea power cables could disrupt the movement and feeding of migrating school shark pups and a wide range of other fish, rays, eels, sharks and skates. The Scoping Requirements required assessment of electromagnetic disturbance because school shark pups migrate through exactly the area where these cables would be laid. The EES fails to grapple with what disrupting that migration could mean for an already threatened species.
• Toxic discharge. The floating terminal would discharge disinfection by-products as a cold plume directly onto the seabed, into the Werribee relict paleochannel. These substances can be highly toxic and bioaccumulate in marine life. The Scoping Requirements required identification of all contaminant discharges. Vopak did not assess this at all, meaning there is currently no analysis of what these substances could do to the Bay floor and the creatures that live on it.
• Excluded areas. Large areas of potential impact were excluded from the assessment, including The Rip at Port Phillip Heads and the Phillip Basin. The Scoping Requirements required the full extent of potential impact to be assessed. By excluding these areas, Vopak has avoided assessing some of the most ecologically significant and heavily used waters in the entire region.
• Cumulative Impacts. The EES did not assess cumulative impacts at all. The Bay's ecosystem is already in a declining and impoverished state. Adding further pressure without understanding how it interacts with existing stress could tip the system into an unrecoverable state. This is not a theoretical risk. It is the most likely outcome when an already stressed ecosystem is assessed in isolation.
• No Ecosystem Model. The EES ecosystem assessment was not based on any ecosystem description or model from the project area. The environmental management framework proposed by Vopak is incapable of meeting the principles of modern ecosystem-based management, which are enshrined in the Marine and Coastal Act. There is no outcomes-based approach that would ensure ecologically sustainable development.

Vopak quietly abandoned its renewable energy commitment: When this terminal was first proposed in 2022, Vopak planned to power it entirely with renewable energy. That commitment has since disappeared without explanation, with serious consequences for the project’s emissions footprint and its compliance with the Scoping Requirements.

• Clean energy abandoned. When this terminal was first proposed in 2022, Vopak planned to power it entirely with renewable energy. That commitment has since disappeared without explanation. Electricity now accounts for half the project’s total lifetime emissions and 82% of its operational emissions. These emissions would have been zero under the original plan. Rather than assessing renewables as an alternative, Vopak compared grid electricity only against generating power from gas on site, effectively designing renewables out of the comparison entirely.
• Hidden emissions. Shipping emissions have been underestimated by approximately half. Vopak has not shown its working, but we believe fugitive methane emissions from LNG tankers have been ignored entirely. Methane is far more potent than CO2 as a greenhouse gas. Ignoring fugitive emissions means the public has been given a significantly incomplete picture of this project’s true climate impact.
• Pollution from shipping. Shipping alone is estimated to generate 3.6 million tonnes of additional climate pollution over the project’s life. This figure is based on Vopak’s own data, corrected for the shipments and emissions factors they appear to have omitted. It represents substantial and avoidable additional emissions at a time when every tonne counts.
• Climate blind. Vopak has dismissed interactions between climate change and the project’s environmental impacts without any analytical method or supporting evidence. The Bay’s Ramsar wetlands are already identified in the 2018 Ramsar Site Management Plan as under serious threat from sea level rise. Only four impact pathways were assessed, and the conclusions simply repeat the optimistic findings of other reports in the EES without independent analysis.

Threatened grasslands and protected wetlands are at risk: Vopak proposes to run the pipeline through some of the most ecologically sensitive land in the region, including internationally recognised Ramsar wetlands and critically endangered native grasslands, without properly considering alternatives that could have avoided this damage.

• Destroyed grasslands. Around 35 hectares of threatened grasslands sit in the project area, including 14 hectares that are critically endangered. Vopak proposes to destroy or damage 3.5 hectares without exploring obvious alternative routes such as shifting the pipeline to Windermere Road or trenching in the middle of existing roads rather than through grasslands. The Scoping Requirements required alternatives to be considered to avoid impacts on threatened ecological communities. Critically endangered grassland is irreplaceable.
• Ramsar obligations. Vopak proposes to run the pipeline through 443 hectares of internationally protected Ramsar wetlands, vital habitat for migratory shorebirds, the vulnerable Growling Grass Frog, and the critically endangered Orange-bellied Parrot, with historic annual counts exceeding 200,000 individual birds. Any works that could affect the ecological character of a Ramsar site trigger obligations under the Environment Protection and Biodiversity Conservation Act, one of Australia’s most significant environmental laws. These obligations have not been adequately addressed, and the consequences of getting this wrong are permanent.
• Habitat for waterbirds. 3.383 hectares of waterbird foraging habitat would be disturbed during horizontal directional drilling construction. Vopak claims it will reinstate the habitat but provides no timeline for when this would happen or any evidence that habitat would be functional when migratory birds actually need it. Vopak’s own mitigation plan proposes to engage Melbourne Water to flood alternative paddocks during construction. This should have been done before the EES was submitted, not flagged as a future action.
• Risk to birdlife. No targeted surveys were conducted for the endangered Australian Painted Snipe, Hooded Plover, Black Falcon (critically endangered in Victoria), Little Eagle, or listed waterfowl. Vopak has instead relied on general Melbourne Water monitoring not designed for this purpose. The Scoping Requirements required targeted surveys for listed species. We simply do not know what is at risk, and the EES cannot credibly claim to have assessed it.
• Impacts for bird migration. The EES does not establish whether the six-to-nine month construction period for the horizontal directional drilling overlaps with the arrival of migratory shorebirds at one of the most important shorebird sites in Australia. This is a basic question the Scoping Requirements required to be answered before impact ratings were assigned. If construction coincides with peak migration, the consequences could be severe and irreversible.
• Noise. Construction noise and vibration limits designed for humans are applied to wildlife without any justification or literature review. An EES should include a literature review of safe noise and vibration limits for relevant species. Applying human safety thresholds to wildlife without any justification is not science. It is an assumption dressed up as an assessment.

Safety assessment is incomplete: For a project involving large quantities of LNG in a busy marine environment, a thorough safety assessment is crucial. But Vopak’s assessment is incomplete with hazards not adequately identified or planned for.

• No risk management plan. The risk register itself omits inherent risk levels, likelihoods, and consequences, making it impossible to understand how residual risks were determined. More fundamentally, the risk management plan for the project does not yet appear to exist. The Safety, Hazard and Risk report suggests it is yet to be developed and the project is still at concept stage only. The project area has not even been surveyed for existing underground services that could cause obstruction during trenching - instead stating that if an obstruction is encountered, it will be dealt with at the time. Despite this, the same report claims all relevant hazards have been addressed consistent with industry standards.
• Risk of undetected gas leak. Gas is odourless during shipment, transfer, and transit through the Bay, all the way to the Gas Receiving Station onshore where odour is finally added. Vopak has not explained how an odourless gas leak would be detected or managed at any point along this route. Without odour, a leak in the Bay could go undetected until it reaches dangerous concentrations, in waters used daily by recreational boaters, swimmers and fishers.
• Shipping risks underestimated. The EES uses only a typical vessel size rather than a maximum, and shipping movements appear to have been underestimated. It also fails to account for Victoria’s seasonal gas use - shipments will be more frequent in the cooler months. If larger vessels are used, or if shipping frequency increases the safety case presented in the EES does not hold. The worst-case scenario has simply not been assessed.
• No maintenance plan. There is no plan for where the floating terminal or LNG tankers would go for major maintenance or emergency repairs. The absence of a maintenance plan means a significant operational risk has not been identified or mitigated. There is no answer in the EES to the basic question of what happens when the floating terminal needs major repairs, or where a vessel carrying LNG would go.