Our beautiful and beloved Westernport Bay is a perfect wildlife wonderland with its rich diversity of marine habitats. 

But it is all at risk if AGL the energy giant gets the tick of approval from the Victorian Planning Minister to build their proposed Gas Import Facility.

AGL’s plan involves a permanently moored industrial-sized 300-metre-long gas storage ship off Crib Point’s shore (south of Hastings), and a pipeline all the way to Pakenham. 15 hectares of native vegetation – half of which is endangered – would be removed for the pipeline works, and each year there would be up to 40 additional large carrier ships entering the bay.

A giant floating gas-filled ship is a terrible idea for an internationally protected Ramsar wetland and environmentally significant marine area. The potential irreversible damage to this highly-connected and sensitive ecosystem must not be risked.

Right now, AGL has its environmental impact reports on display through the state environmental assessment process, known as an Environmental Effects Statement (an EES).

AGL’s reports inadequately consider and understate the risks of explosions and ship collisions; impact on sensitive marine communities and listed species such as whales; impact on wetland habitat and waterbirds that are critical values of Westernport Bay’s Ramsar site; and the release of higher than safe levels of chlorine levels for the marine environment – to name a few.

Our biggest opportunity to speak up about the risks is right now, by sending in submissions by Wednesday 26 August.

To make it easier to have your say, we have provided guidance and some key points below to help you in drafting your submission.

Follow these steps to put in your submission:

Step 1 – Put together your submission

You can use our key points below we have put together to help. Submissions will have maximum impact if you put these in your own words and add your own perspective.

Alternatively,If you have specific expertise in a particular area you could focus on this area and do it well. Refer to AGL’s documents here.

Below are some of the high-level issues you can highlight in your submission.

If short on time, pick one or two to focus on. Remember, a submission can be as simple as short letter.

TERRESTRIAL IMPACTS – from construction of an almost 60-kilometre pipeline from Crib Point to Pakenham.

Construction of an almost 60-kilometre pipeline from Crib Point to Pakenham.

  • Native vegetation removed to make way for the pipeline will involve the direct loss of 15 hectares of native vegetation – almost half of which is endangered vegetation types.
  • The pipeline component of the project has the potential to impact on large number of threatened species, including:
    - 8 Environment Protection and Biodiversity Conservation (EPBC) Act listed species,
    - 19 Flora and Fauna Guarantee Act listed species;
    - 30 Department of Environment, Land, Water and Planning Advisory List species
    - 5 EPBC Act listed migratory species
    – totalling 36 threatened species potentially impacted.
  • The existence and ongoing maintenance of this pipeline is a serious threat to the survival of the nationally-endangered Southern Brown Bandicoot (listed under the EPBC Act) that has received major investments by governments and community over a long period time. The project will directly result in removal of vegetation from sites of likely habitat of the Southern Brown Bandicoot. This could result in local extinctions of this species.
  • The pipeline directly impacts on one of only four-five populations in Victoria of the threatened Merran’s Sun-orchid.
  • The pipeline is proposed to go through Warringine Park, a covenanted Council reserve of > 100 hectares between Hastings and Crib Point.

MARINE IMPACTS – from LNG floating gas facility involving 300-metre long storage ship (FSRU) at Crib Point, and up to 40 additional ships into Westernport Bay per year.

Failure to address catastrophic events and threats – explosions, oil/fuel spills, and marine pest invasions

The EES fails to directly address catastrophic threats and events, particularly when similar events have occurred previously in the region, for example:

  • Major oil spill – such as the Iron Barren spill in the Tamar Estuary in 1995. Although the FSRU and supply vessels may not carry large quantities of fuel, their operations interact with tankers that do, especially given tankers will pass the FSRU to get to Long Island Point.
  • Gas release or gas explosion incident – such as the ethane pipeline rupture in Port Phillip Bay in 2008. Although the ethane rupture event did not lead to catastrophic outcomes, it proves that events such as this can occur are not necessarily rare or unlikely.
  • Marine pest invasions with permanent alterations of ecosystems ­– such as Japanese Kelp or Northern Pacific Sea Stars, which have devastated swathes of habitat types in Port Phillip Bay already.

Up to 40 additional ships into Westernport Bay will increase shipping activity by up to 25-40% every year. This increases the risk of these events significantly, as well as risk of ship grounding on sensitive habitats.

It should be openly acknowledged and planned for that the FSRU introduces additional (cumulative) incident risk in Westernport Bay.

Wetland birds and Ramsar values wetland values ignored
  • Both the terrestrial and marine impact assessment reports dismiss the potential for impacts on wetland birds and Ramsar ­wetlands of international importance (recognised for containing representative, rare or unique wetlands, or wetlands that are important for conserving biological diversity).
  • The EES discounts any impacts on wetland birds by saying that because they are not in the direct project vicinity, they will not be impacted. It is well known that wetland birds have sensitivities to disturbance i.e. visual light, noise and predators. These disturbances can alter behaviours and translate to a reduction in energy reserves for the animals. Any depression of prey populations from other environmental impacts can also have an immediate effect on the survivorship of birds, particularly those breeding or building reserves for migration.
  • The combined effects from noise, visual disturbance, and movement barriers for feeding (cumulative impacts) are not considered. This is a huge issue because wetland and migratory birds are well known to be particularly sensitive to combined pressures.
  • The EES does not address biological impacts on Westernport Bay’s Ramsar ecological values and has no direct assessment of the key sensitivities for these habitats and significant species.
  • There are no predictions of degrees of change in ‘ecological character’ of Westernport Bay’s Ramsar site i.e. the combination of the ecosystem components, processes, and benefits and services that characterise the wetland.
Chlorine discharge
  • Chlorine released from the discharge points on the FSRU ship (produced for cooling operations) at its peak will release up to 47 kg/day.
  • The FSRU ship will be releasing more than the identified safe levels identified by CSIRO for marine waters. It will be releasing 100 micrograms per litre, when the safe levels to protect 99% of species is set at just 6 micrograms per litre. This is over 16 times higher than safe levels for marine waters.
  • This pool of chlorine, identified as being over safe limits for marine waters, is modelled to extend over an area of 5 hectares around the FSRU ship.
  • Assumptions are made that it will be dissolved in no time, but the EES does not take into account the other contaminants (secondary products from the chlorine) which can be produced, pending what other particles are in the water.
  • These contaminants have the potential for irreversible damage to the ecosystem.
  • The EES does not address how these toxicants can travel to other ecological sensitive areas, for example with the movements of tides.
  • In some cases, evidence of contaminants dispersing further afield are excluded in the EES. For example, in FSRU operations in other parts of the world toxicants can be distributed to wider areas.
Marine biodiversity field studies – no scientific backing
  • For all the types of marine and wetland impacts that could occur, the EES does not provide enough supporting evidence for its predictions, and therefore it downplays major issues, such as toxicants, oil spills and marine pests.
  • In many cases there was no supporting evidence for the predictions of impact of the project on biodiversity. For example, the risk of plankton being sucked up into the FSRU intake pipes, the EES says it will be reduced by making an assumption that plankton would float above the FSRU intake pipes – there is no supporting evidence to back this up.
Underestimate spatial impacts of the project

  • The biological impact assessment for the FSRU was spatially limited to just the region around the FSRU, and there was little consideration of ecological processes and linkages that can extend impacts over a larger area i.e. from tides and fish and bird movements travelling through these areas.
  • The EES discounts impacts by saying habitats aren’t close enough to be impacted, when the modelling clearly shows they are. For example, there are statements that a major oil spill could be transported to those habitats, yet this was ignored.
  • The EES states that impacts from the project will only be in the ‘general project area’, but there is no science to support this claim, or to say that there will not be further impacts further away i.e. proper assessment of contamination from chlorine discharge and its dispersion.
Lack of assessment for significant marine species – whales and others

  • The impact on whales from the up to additional 40 ships per year entering Westernport Bay, a 25-40% increase, is not addressed anywhere near adequately enough.
  • Peak shipping would coincide with the peak whale season. The EES understates the risk of whale strike by LNG carriers, and therefore understates adequate measures to reduce this impact.
  • Westernport Bay is visited by the endangered Southern Right Whale during winter. Its population has failed to recover post-whaling, with an estimated maximum of 300 individuals making up the south-east Australia population (Victoria, South Australia, Tasmania and New South Wales).
  • A study needs to be done to determine whale numbers and movements to ascertain baseline knowledge.
  • Modelling of physical and chemical impact pressures, such astemperature, toxicants and noise, was not assessed with respect to maps of sensitive species, communities or ecosystem features.

A good submission may only include raising one or two key points, and asking lots of questions around any uncertainties. Remember, we don’t have to have the answers – that is AGL’s job to figure out. Asking questions is a good thing!


Step 2 – Submit

  1. Visit the Victorian Government’s Engage website to submit online: engage.vic.gov.au/crib-point-IAC
  2. Scroll to the bottom of the page and you will see the heading ‘Make your Submission’. Tick the boxes, and fill out the required fields with your details. You can either copy and paste your submission if under 500 words, or attach a file.
  3. If you have specific expertise and want to heard at the public hearing or called as an expert, make sure you indicate this in the required box.
  4. Click ‘Lodge your submission’. You are done – thank you!

Your submission will go to the joint Inquiry and Advisory Committee (IAC), who will also consider other permits and approvals and advise the Minister for Planning, who then make the final decision.

The due date for submissions is Wednesday 26 August.