Chapter 4Climate, health and environmental impacts
Introduction
4.1This chapter examines concerns raised by some submitters about the potential climate, human health, and environmental impacts of the proposed Middle Arm Industrial Precinct development.
Climate change impacts
Contextual information
4.2As part of its pledge to the Paris Agreement, Australia committed to reducing net greenhouse gas emissions to 43 per cent below 2005 levels by 2030 and to further reduce its emissions to net zero by 2050. Australia’s emissions reduction targets are set out in the Climate Change Act 2022 (Climate Change Act).
4.3The proposed Middle Arm Industrial Precinct development is proposed to house facilities such as a new Liquified Natural Gas (LNG) export facility, and potentially petrochemical manufacturing. Other proposed uses are not settled, and the Stage 3 business case has not yet been provided to Infrastructure Australia.
4.4The Commonwealth Scientific and Industrial Research Organisation (CSIRO) is undertaking research on the future potential abated and unabated emissions in various Middle Arm industrial development scenarios; however, at the time of writing, the project was still underway. The findings are due to be released in October 2024.
4.5However, in August 2024, the ABC reported that an NT Government-commissioned report had ‘found the gas industry would be the biggest contributor to NT emissions increases up to 2050’, and that ‘even with no new projects, an increasing amount of greenhouse gas coming from Darwin's two existing gas plants [run by Santos and INPEX] was expected to increase the NT's emissions by 25 to 50 per cent…above historical levels due to higher CO2 content of new offshore gas supplies in 2025 and 2035’. According to the ABC, the report identified that the addition of LNG production from the proposed Beetaloo Basin (via the proposed Tamboran LNG facility at the Middle Arm Industrial Precinct) on top of the small expansion to Darwin's existing LNG processing plants could potentially raise NT emissions 100 per cent above historical levels, and that a large expansion could cause a potential unabated increase of 150 per cent.
4.6Climate Analytics reported that the proposed Middle Arm Industrial Precinct, due to the inclusion of a 6.6 million tonnes per annum LNG plant, ‘would generate emissions equivalent to 2–3% of Australia’s 2021 emissions’ equivalent to ‘adding 6 to 8 million new cars to Australia’. It further noted that Tamboran Resource’s (Tamboran) plans to expand capacity to 20 million tonnes per annum would increase emissions generation ‘equivalent to 10–13% of Australia’s 2021 emissions, equivalent to having 30–38 million additional cars on Australia’s roads’.
Concerns raised by submitters
4.7Some environmental groups expressed concerns about the climate impacts that could arise from the proposed Middle Arm Industrial Precinct. For example, the Wilderness Society described the site, and all onshore gas projects, as posing ‘asevere and immediate climate risk’.
4.8Likewise, the Environment Centre NT (ECNT) highlighted research by DrMichael Petroni, an environmental scientist with expertise in environmental health and risk assessment, which identified that the proposed precinct could be ‘the single highest greenhouse gas emitter in the NT’, increasing the NT’s emissions by 15 million tonnes per annum (or 75 per cent).
4.9Following a trip to Australia, the UN Special Rapporteur on Toxics and Human Rights raised concerns about the emissions of the Middle Arm development, specifically, that the ‘greenhouse gas emissions of natural gas for export, so‑called scope 3 emissions, have not been quantified.
4.10In a similar vein, the Australian Conservation Foundation (ACF) argued that the proposed development is ‘inconsistent with responsible climate action’ and Australia’s Paris Agreement targets. Some submitters pointed out the International Energy Agency (IEA) had expressly recommended ceasing exploitation of new oil and gas fields if the world is to stay within safe limits of global heating.
4.11In addition to concerns about the proposed fossil fuel facilities at Middle Arm, the site’s facilitation of the Beetaloo and Barossa gas projects and their associated emissions were also criticised. For example, 350 Australia stated that the Beetaloo and Barossa projects ‘would release over a billion tonnes of climate pollution’, expressing concerns that ‘the proposed petrochemical manufacturing, which relies on gas as a feedstock, would be used to justify fossil fuel expansion’.
4.12Indeed, Climate Analytics gave evidence that its independent evaluation of the CSIRO and Gas Industry Social and Environmental Research Alliance (GISERA) assessments of potential greenhouse gas emissions showed that the predicted emissions for the Beetaloo have been underestimated.
4.13More broadly, some submitters expressed strong opposition to increasing emissions through enabling hydraulic fracturing (fracking).
Subsequent impact of climate change on communities
4.14Due to the broader human health risks that are associated with a warming climate, the inquiry received some opposition to the proposed Middle Arm Industrial Precinct.
4.15For example, Doctors for the Environment Australia (DEA) submitted that:
…climate change is a particularly urgent threat for the NT itself, given the region has already experienced temperature rises greater than the global average. Research suggests that with further temperature rises, there is the potential for [the NT] to be uninhabitable within decades.
4.16On a similar note, the NT branch of the Australian Education Union noted the extreme heat effects of climate change on the NT. It noted a significant 38 day increase in daytime temperatures of 35°C and above per year from the 1970s to 2019. It then highlighted stark predictions of 275 days per year over 35°C by 2070.
4.17Similarly, the UN Special Rapporteur on Toxics and Human Rights voiced concerns that ‘scientific reports suggest that temperatures in the Northern Territories could make the region uninhabitable for humans’, yet despite this, ‘petrochemical and oil and gas industries are lining up massive projects in the region’ which threaten ‘to make Darwin and the region a climate change sacrifice zone’.
4.18Indeed, the joint submission from the Public Health Association of Australia and NT Paediatricians drew attention to research which indicated that, under Australia’s current emissions trajectory, Darwin will continue to get warmer, rainfall and drought events will become more intense, sea levels will continue to rise, and tropical cyclones will be more intense.
4.19Climate change is also expected to affect sea levels. For example, the DEA highlighted CSIRO advice that ‘sea levels are likely to rise by 20–40 cm across northern Australia in the coming decades due to climate change’, and that modelling has suggested that there will be regular inundation of the Middle Arm area by 2030, yet ‘no consideration has been given to this and associated health risks in the planning process’.
4.20In a similar vein, the ECNT expressed concern that the peninsula is likely to be severely affected by climate change by 2030, with predictions of regular flooding as a result of rising sea levels.
4.21Some submitters explained there are additional expected impacts of climate change to human health. For example, the Royal Australasian College of Physicians (RACP) submitted:
Climate change poses a significant health threat through impacts related to increasingly more frequent and intense extreme weather events, increasing temperatures, changes to vector-borne disease patterns, and worsening food and water shortages. Health consequences include heat stress; respiratory, gastrointestinal, and cardiovascular illness; injury; malnutrition, and psychological distress.
4.22Relatedly, the Public Health Association of Australia and NT Paediatricians explained that climate change has ‘significant implications for healthcare, emergency services, housing, energy, and disaster preparedness’, explaining that:
Extreme weather events can cause loss of home, livelihood, health services, community and pets, helplessness, worry for personal and family safety, separation from loved ones, and physical injury. People who have experienced disaster often experience anxiety, depression, exacerbation of existing conditions, post-traumatic stress disorder and disrupted sleep. Also increases in cognitive impairment, suicide, conflict and violence.
4.23It further pointed out that some cohorts are more vulnerable to the impacts of climate change, such as ‘children, elderly individuals, people with pre-existing illnesses, socially disadvantaged individuals, First Nations people’, explaining that:
Young people experience stress from disasters more acutely than adults, and feel pessimistic, afraid, and depressed about the world climate. These feelings long-term can lead to decreased mental health…
First Nations people’s health and well-being is closely connected to the health and well-being of the environment, the community, and important cultural traditions and places. Climate change may result in the disruption, displacement, and destruction of these key elements to good health and well-being.
4.24The Aboriginal Medical Services Alliance Northern Territory (AMSANT), RACP and DEA expressed similar concerns that a warming climate would have a disproportionate impact on the health of First Nations peoples residing in the NT.
4.25For example, AMSANT argued that social disadvantage increases the impact of climate change on communities, for example, through overcrowded housing, lack of air‑conditioning, homelessness, lower incomes, and barriers to healthcare. AMSANT ‘strongly recommended’ that the Middle Arm proposal not proceed due to the risk of emissions increasing global warming and the subsequent expected impacts on Aboriginal people’s health in the NT.
Industry views
4.26Conversely, the inquiry received evidence from the gas industry that the proposed development at Middle Arm would facilitate Australia’s climate commitments by allowing Australia and other countries in the region to transition away from coal.
4.27For example, Tamboran argued that natural gas can support global emission reduction targets by displacing coal:
Achieving global emission reduction targets and developing new supplies of natural gas are not mutually exclusive and despite the negative sentiment towards fossil fuels in some quarters, natural gas offsetting coal-fired power generation will deliver a fundamental step-change in reducing GHG [greenhouse gas] emissions.
4.28Tamboran submitted that its Middle Arm facility would ‘significantly contribute to the Australian Government’s goal of achieving Net Zero emissions by 2050’ and meeting the Paris Agreement targets.
4.29According to Tamboran, gas from the Beetaloo will ‘offer a dependable route for Australia’s energy transition’, and ‘provide neighbouring economies with access to reliable gas as an alternate to coal imports for their heavy emitters’.
4.30Tamboran argued that ‘reliable gas supply from the Beetaloo used at NTLNG [Tamboran’s proposed Middle Arm LNG project] means Australia can remain a reliable trading partner…and have access to reliable energy supply or chemical feedstock to major industry investments, such as Middle Arm’.
4.31Tamboran argued that gas from the Beetaloo has generally lower CO2 content than the industry average for gas fields in north-western Australia, and sought to reassure the committee that its facilities would be focused on achieving Net Zero:
Under the Commonwealth’s new Safeguard Mechanism and our own long-term plan, natural gas production in the Beetaloo Basin is required to have Net Zero Scope 1 greenhouse gas emissions and is expected to be the lowest Scope 1 greenhouse gas intensity natural gas sourced anywhere the world.
4.32Additionally, as discussed in Chapter 2, some parts of industry highlighted the role that the proposed CCS hub at Middle Arm could play in reducing emissions in Australia and internationally.
NT Government views
4.33The NT Government stated that master planning for the Middle Arm Industrial Precinct drew in the NT policy framework for addressing climate change and would support the needs of the energy transition by providing flexibility for suitable industries.
4.34According to the NT Government, the precinct is ‘underpinned by a rigorous engineering, design and analysis processes including more than 200 studies and technical assessments to date’, and has been ‘master planned to enable a pathway to transition from today to a net zero emissions economy by 2050’.
4.35When asked to provide the 200 studies, the NT Government stated that, as the draft Environmental Impact Statement ‘is incomplete and still underway, the environmental studies that inform these statutory assessment processes cannot be tabled with the Committee at this time.’
4.36The NT Government acknowledged that ‘climate change and associated potential impacts resulting from large atmospheric volumes of greenhouse gas emissions are not confined by state or national boundaries’.
4.37The NT Government sought to reassure the committee that ‘energy transition is a priority for the Territory, as is assisting nearby jurisdictions in efforts to maintain energy security and reduce environmental impacts in collectively transitioning away from the use of fossil fuels’.
4.38As an example, the NT Government explained that the proposed hydrogen production on the Middle Arm site would support the technological response to climate change, advising that, while hydrogen would be produced using gas at first, it would later be produced using hydrolysis powered by emissions free renewable energy.
4.39Separately, the NT Government highlighted the lower level of emissions from natural gas when compared to coal, arguing that capacity to export gas to coal‑using Southeast Asian nations was an additional reason for the development of the precinct.
4.40The NT Government further emphasised that the Territory does not use coal for domestic energy requirements, making it an ‘inherently lower emission energy producer’.
4.41Regarding potential exacerbation of climate change and the subsequent risks to the health of the population, the NT Government advised that a cost-benefit analysis of the Middle Arm proposal would need to ‘consider all aspects of risks for human health, with the overriding principle of doing no harm while attempting to improve other societal issues’.
4.42The NT Government pointed out that the research by Dr Petroni, the author of the report commissioned by the ECNT, had acknowledged ‘the uncertainty in the estimates as there is currently no specific details of industries, and the actual industries and potential for emissions is as yet unknown’.
4.43The NT Government advised that the Environmental Impact Statement (EIS) being prepared and the commitment to individual health impact assessments for each proposed industry ‘will allow the Territory and the population to assess the cost benefit in a considered manner’. The EIS is discussed in the next chapter. Regarding the individual health impact assessments, the NT Government committed to ensuring that:
…each industry that proposes to operate at MASDP [the proposed Middle Arm Industrial Precinct] will be required to…assess specific emissions, the proposed mitigation including the emission abatement technology, cumulative impacts to human health and the likely human health impact based on Australian and international guidelines.
4.44According to the NT Government, ‘any proposed industry that poses an unacceptable risk to human health, either individually or cumulatively, will not be permitted’ in the proposed Middle Arm Industrial Precinct.
Human health impacts
4.45The inquiry received some opposition to the proposed development due to potential health risks associated with potential petrochemical operations.
4.46Several submitters were specifically concerned about potential air pollution, noting the proximity of the site to the suburbs of Palmerston and the Darwin CBD.
4.47For example, the DEA submitted that the petrochemical facilities proposed for the Middle Arm Industrial Precinct would ‘emit a range of air pollutants including particulate matter, carbon monoxide, sulphur dioxide, volatile organic compounds and nitrogen oxides [which are] associated with a range of adverse health outcomes in exposed populations’.
4.48In a similar vein, the UN Special Rapporteur on Toxics and Human Rights raised several concerns with the proposed precinct:
The Middle Arm project in Darwin, and the toxic substances it would release, raise health concerns in neighboring communities, such as asthma, heart disease and various forms of cancer.
Industry views
4.49Some gas industry stakeholders argued that the human health risks of the proposed development are not underpinned by credible evidence. For example, at a public hearing, Tamboran rejected concerns regarding potential health risks associated with its fracking and shale gas extraction project in the Beetaloo Basin, arguing that in the US ‘over a million wells…have been drilled safely over the course of the last 15 years’, and that reports raising concerns ‘are littered with misinformation’. Tamboran implored the committee to ‘look at the real engineering and science based reviews that have been done by a range of subject matter experts’, arguing that ‘unconventional [fossil fuel] development is safe’.
4.50Likewise, the Australian Energy Producers (AEP) referred to ‘over 200 studies’ which had been undertaken in relation to shale gas extraction. The AEP submitted that:
…much public discussion relating to health appears to be influenced by a limited survey of studies applicable to the United States (Mississippi River and the Gulf of Mexico). Additionally, several sources used within this public discussion on health appear to reference studies that have been discredited by government state health departments due to poor methodology and an absence of credible findings.
4.51However as outlined above, when asked to provide the 200 studies referred to by the AEP, the NT Government declined to provide them.
4.52Nevertheless, Tamboran argued that there is a body of evidence that ‘ought to be weighed against academic literature alleging adverse effects associated with gas developments’ such as its proposed shale gas extraction in the Beetaloo.
4.53Tamboran highlighted a range of reports which suggest the risks to health from fracking are minimal, for example:
a 2015 WA Department of Health, Human Health Risk Assessment report which found that ‘hydraulic fracturing can be executed without jeopardising drinking water sources, attributing this assurance to the depth of gas resources, adherence to industry standards, implementation of best practices, and strategic site selection’;
a 2017 CSIRO report which found that the ‘employment of chemicals in the coal seam gas industry poses minimal risks to both the community and the environment. CSIRO has determined that residual chemicals, remaining underground following hydraulic fracturing, are unlikely to impact people or ecosystems in concentrations that would elicit concern, thereby rendering the risks negligible’; and
a 2018 scientific Inquiry into Hydraulic Fracturing in the NT which identified that ‘the risk was generally ‘low’ for likelihood and ‘low-moderate’ for consequence’.
4.54Tamboran also highlighted that there are regulatory requirements in the Northern Territory to help to minimise risk:
…one of our core values is to ensure that the health and safety of our people and of the communities in which we operate are protected. We feel very strongly about that given the comprehensive regulations that we operate under in the Northern Territory. These are regulations that are governed by the comprehensive study with the Pepper inquiry that took place.
4.55Contrary to Tamboran’s arguments, the Public Health Association of Australia and NT Paediatricians set out that ‘living near petrochemical facilities and fossil fuel refineries [has] serious implications on a range of health issues’. For example:
petrochemical air pollutants increase the risk of adverse birth outcomes and pose long-term complications for the baby include chronic lung diseases, visual or hearing difficulties, and neurodevelopmental disorders and neonatal sepsis;
residential proximity to petrochemical facilities increases incidence of respiratory conditions such as coughing, wheezing, and bronchitis which become greater with longer exposure;
children living near petrochemical facilities are at higher risk of decreased working memory function;
living in close proximity to petrochemical sites increases the risk of developing cardiovascular diseases due to air pollution containing heavy metals such as mercury, arsenic, and chromium that are released into the atmosphere during the sites' operation;
cancer rates significantly increase for residents near petrochemical facilities, particularly for those who have had longer term exposure to the pollutants (like children); and
living close to and working in petrochemical facilities may also cause decreased ability to concentrate, and increased forgetfulness, anxiety, and depression.
4.56The ECNT noted that Dr Petroni’s modelling, which focused on the potential impacts of the petrochemical and large manufacturing components of the proposed precinct, suggested ‘an increase in industrial fine particulate emissions by 513 per cent, and a four-fold increase in the industrial cancer hazard’.
4.57Similarly, the DEA also drew attention to Dr Petroni’s findings that harmful air pollutants in the Greater Darwin region would result ‘in an additional $75million of health impacts and 15 premature deaths annually.
4.58Indeed, Dr Petroni’s research indicated that cancer-causing air toxics such as formaldehyde, acetaldehyde, polycyclic aromatic compounds, benzene, arsenic and others may be emitted by the proposed facilities:
…industrial emissions from the [Middle Arm Industrial Precinct] will increase dramatically compared to the levels seen in the Darwin area over the past decade. Annual fine particulate emissions may quadruple, and carbon monoxide emissions may increase by 705%.
4.59Figure 4.1 shows Dr Petroni’s comparison of air pollutant emissions estimated from the precinct, the regional average, the combined emissions, and the per cent increase.
Figure 4.1Criteria air pollutant emissions comparison
Source: Dr Michael Petroni, Expert Opinions Related to Potential Environmental and Human Health Impacts of the Middle Arm Sustainable Development Precinct as well as the Adequacy of the Draft Terms of Reference for Strategic Assessment, 2022, p. 58.
4.60Raising similar air quality concerns as other submitters, AMSANT submitted that ‘petrochemical industrial developments cause high levels of air pollution’ and that Darwin ‘already has poor air quality, particularly during the dry season’.
4.61Likewise, the RACP expressed concern about the human health impacts of gas extraction, advising that the organisation had written to the Prime Minister and the NT Chief Minister voicing its concerns.
4.62Indeed, the committee heard that INPEX’s existing facilities had released approximately 6000 tonnes of benzene, a known human carcinogen, into Darwin’s air in 2022 due to malfunctioning acid gas incinerators. Despite this, INPEX was still found to be compliant with the terms of its licence by the NT Environment Protection Authority (NT EPA), which was unable to detect any level of benzene at its monitoring stations.
4.63Dr Paul Vogel, Chairperson of the NT EPA, advised that the NT EPA measures ambient levels of benzene but was unable to confirm what level of benzene was considered acceptable for human health. The NT EPA subsequently advised that it ‘does not measure benzene at its air quality monitoring stations… Benzene is measured quarterly by INPEX…on a voluntary basis when the AGRU [acid gas removal units] are offline. Results are provided to the NT EPA’.
4.64According to INPEX, the first of its two acid gas incinerators was offline for a total of 1209 days between January 2019 and June 2024, whilst the second was offline for 1235 days during the same time period.
4.65The NT EPA advised that INPEX’s Environment Protection Licence only requires it to:
conduct monthly monitoring for Benzene, Toluene, Ethylbenzene and Xylene (BTEX) at the ‘hot vent’ authorised discharge points.
notify the NT EPA when the AGRUs are offline for any reason.
take all reasonable and practicable measures to minimise fugitive (unintended) volatile organic compound emissions.
ensure that venting of AGRU acid off gas will be infrequent and only when the incinerator is shut down for maintenance.
4.66As there had technically been no breach of its licence conditions, the NT EPA had not investigated INPEX for its release of 6000 tonnes of benzene.
4.67Dr Shaun Watson, a neurologist and NSW Co-Chair of DEA, expressed frustration that ‘fossil fuel executives…fly into the NT, wreak havoc on the health and wellbeing of the people and land, then fly out’ but ‘for the children of the NT there is nowhere else to go’.
4.68The NT Department of Infrastructure, Planning and Logistics (DIPL) advised that there will be a ‘precinct authority’ which officials speculated may be the appropriate mechanism for receiving concerns and establishing steps for remediation.
Additional health risks
4.69Some submitters argued that there are further health risks that could arise from the operation of the proposed precinct as well as its associated projects, such as shale gas fracking in the Beetaloo Basin.
4.70For example, the joint submission from the Public Health Association of Australia and NT Paediatricians advised that reliance on fly-in-fly-out workers for industrial and mining sites has been found to be associated with an increased rate of violence against Indigenous women and children.
4.71Some raised health concerns arising from fracking. For example, the DEA stated that ‘over 2200 peer-reviewed papers provide evidence of harms to human health from fracking operations’, and that fracking chemicals ‘are potentially carcinogenic and toxic to the human nervous, endocrine, and reproductive systems, and can adversely affect child development’.
4.72AMSANT also outlined further health risks associated with the fracking industry, including:
higher risk of low birth weight, pre-term delivery and spontaneous abortion, severe birth defects, acute lymphoblastic leukaemia; and
injuries and fatalities from increased large truck traffic volumes.
4.73Concerns were also raised over the risk of water contamination. For example, the DEA argued that studies have identified there are direct threats to water supplies from fossil gas developments due to over-extraction and chemical contamination.
4.74Indeed, the DEA was concerned that ‘toxic run-off, accidental spills and leakages and intentional releases of wastewater into nearby bodies of water could pollute a very large area of connected aquifers, impacting water supply across the NT’.
4.75The DEA argued that ‘the quality of drinking water across the NT is already a significant health concern’, with ‘tens of thousands of people living in communities where the level of minerals or chemicals [contained in] drinking water…exceed guidelines’.
4.76Similarly, the Public Health Association of Australia and NT Paediatricians argued that ‘petrochemical plants and gas refineries pollute…water during their whole lifecycle… It is unacceptable to locate these sites close to residential areas, sensitive ecosystems, and waterways’.
Calls for a Health Impact Assessment
4.77Several submitters raised concerns that a Health Impact Assessment (HIA) had not been conducted for the proposed precinct, calling for its commissioning.
4.78For example, the joint submission from the Public Health Association of Australia and NT Paediatricians suggested that the NT Government’s ‘Strategic Environmental Assessment (SEA) should not be approved for public exhibition until a Comprehensive HIA has been undertaken’.
4.79DEA also expressed concern that the Australian Government had committed $1.5billion in funding despite the absence of a HIA. DEA alerted the committee to the Health Impact Assessment Guidelines published by the Environmental Health Standing Committee, which draws expertise from Australian, state and territory health departments and research council. These official guidelines, which are published on the Australian Government Department of Health and Aged Care website, stipulate that an HIA should be completed ‘if a development has the potential to result in changes to the health of communities if it were to be implemented…[and] the outcomes of a HIA would add value to the decision‑making process’. By doing so, the DEA argued that the Australian Government has made ‘the approval of the project appear to be a foregone conclusion’.
4.80DEA also argued that the HIA should utilise ‘robust methodology approved by a panel of independent public health experts’, include ‘HIAs for all nominated industries’, and assess the ‘flow on health risks, from climate change induced extreme weather and sea level rise’.
4.81The DEA further set out that individual projects at Middle Arm, under the SEA method, would be able to receive a business licence from the NT EPA within as little as 60 days following an application, provided they were an approved ‘class of action’ under the overarching umbrella approval provided by the Commonwealth and NT Governments. The DEA argued that this ‘makes it fundamentally important that a HIA is incorporated at this point…as part of the [SEA]. Otherwise, highly polluting projects may be rapidly approved in the future without any prior consideration of health impacts’.
4.82On a similar note, the Public Health Association of Australia and NT Paediatricians expressed concern that, due to the SEA format, ‘HIAs for proposed businesses at [the Middle Arm Industrial Precinct] only need to be conducted at the discretion of the NT Chief Health Officer, which does not need to be accepted by the NT Government’.
4.83In addition to calls for a HIA, the committee received calls for development of a health baseline study and a health-monitoring plan to improve the existing data set and better understand the level of risk.
NT Government views
4.84As mentioned earlier, the NT Government advised that it had commissioned a human health impact assessment as required by the terms of reference for the EIS issued by the NT EPA. This study models the potential cumulative impacts of multiple proposed industries, including the potential impacts of discharges to air, water and soil.
4.85The NT Government confirmed that individual health assessments for every project will be undertaken as part of the NT EPA process.
4.86These human health impact assessments had not been published at the time of writing. They may be published when the broader EIS documents are released.
4.87The NT Government stated that any industry that poses an unacceptable risk to human health, either individually or cumulatively, will not be permitted in the precinct.
4.88Regarding air pollution, the NT Government acknowledged that improving existing air quality and reducing air quality exceedances of particulates ‘is an important factor in risk mitigation from the proposed industries at [the Middle Arm Industrial Precinct] as well as for the broader health impact’. According to the NT Government, ‘attributing toxicity arising from human exposure to environmental and industrial chemicals, agents, substrates or toxicants is a matter of risk assessment’.
4.89The NT Government also acknowledged that undertaking ‘baseline and ongoing health research, using both routinely collected health data and specifically commissioned health studies will be an important component of monitoring, along with the regular monitoring of air, water, soil and seafood for chemical contamination’.
4.90At a public hearing, NT Health explained that the NT EPA would be required to seek input from NT Health when reviewing the HIA:
…in the discussions that I've had with government colleagues, we've talked about the criticality of having individual human health impact assessments. Under our existing EPA legislation, the EPA will be required to seek advice and input from Health and the Chief Health Officer to inform the terms of reference and the reviews of those health impact assessments.
4.91Regarding the potential health impacts of the development, NT Health acknowledged that ‘many industries…can produce emissions and…cause harm’, and that ‘there's been a significant increase in research [on the adverse health impacts of industrial emissions]…in the United States’. However, according to NT Health, ‘studies for health impact assessments are…challenging because they need to be done at population levels…to determine if there is any impact…that then brings in a whole lot of confounding factors’. Additionally, NT Health explained that ‘one of the challenges for us is determining the relevance…those industries that are being examined in the United States are very intensive industries, which is not what's being proposed for Middle Arm’.
4.92In response to questions regarding when these assessments are expected to be undertaken, what the process will involve, whether assessment findings will be made public, and how the findings will be used, NT Health advised:
There has been modelling undertaken on proposed proponents…but we actually need each individual industry…until we have individual industries so that we can really interrogate the potential emissions from that industry and also the mitigation strategies and the monitoring strategies, it's hard to give specific details.
Environmental impacts
4.93Darwin Harbour (including Middle Arm) is an NT Government Area of Conservation Significance. The area is dominated by mangrove forest, ‘which largely remain in undisturbed condition’, and represent more than five per cent of the NT’s entire mangrove area.
4.94Indeed, the NT Government advised that the harbour ‘has one of the richest coastal environments anywhere in the Asia Pacific region’, explaining that:
The mangroves of Darwin Harbour support a highly specialised fauna and 14 bird species that are entirely restricted to mangrove environments... The Harbour itself supports a diverse range of marine species including dugongs, dolphins, marine turtles and a large variety of fish. A total of 15 threatened species are reported from within the Site [Darwin Harbour].
4.95The ECNT gave evidence that the proposed development area is a ‘key terrestrial biodiversity hotspot’ that contains savanna and rainforest and is ‘one of the most significant in the entire Territory’.
Concerns raised by submitters
Terrestrial impacts
4.96Several environmental groups expressed concerns about the potential environmental impacts of the proposed precinct on the terrestrial environment and its dependent species.
4.97For example, the ECNT explained that industrialisation would impact multiple species, some of which were already endangered:
Loss or degradation of habitat at the Peninsula has the potential to impact the viability of a number of key threatened terrestrial species, including black-footed tree rats, northern brush-tail possums, and rare and endemic plants such as Typhonium praetmissum and a newly-discovered range restricted species of Typhonium (pers comm NT Herbarium).The near‑threatened bare-rumped sheath tail bat is reported to also be present at Middle Arm...The site allocated to Tamboran’s LNG facility is a known roosting site for the critically endangered far eastern curlew.
4.98In addition, the ECNT noted that the centre of a population of Black-footed Tree‑rats is in a lot which has been granted to Tamboran for its LNG facility’.
4.99Additionally, the ECNT argued that the area is also nationally significant due to ‘the abundance of four species of migratory shorebird’, and that the proposed precinct ‘will impact the availability and integrity of habitat for these and other species’.
4.100Likewise, Lock the Gate Alliance was concerned that the ‘structurally intact landscapes and diversity of significant species in the NT may be particularly susceptible to cumulative impacts’.
4.101During the public hearing, the committee heard that the Department of Climate Change, Energy, the Environment and Water (DCCEEW) had met with Tamboran to discuss Matters of National Environmental Significance (MNES) and how they potentially linked to the activities that company is undertaking. However, according to evidence from Tamboran, DCCEEW had not raised the issue of threatened and migratory species with the organisation.
Marine impacts
4.102Several threatened marine species are reported to inhabit or travel through the waters in and around the proposed Middle Arm Industrial Precinct including the Flatback, Loggerhead, Green Turtles, Scalloped Hammerheads, Blue Whales, and Whale Sharks.
4.103Some environmental groups raised concerns regarding the impact of the proposed development on marine environments. For example, the ECNT noted NT Government estimates of ‘a dredge volume of 20million cubic metres, to allow a six-kilometre navigational channel to connect to the proposed Modular Offset Facility…and product jetties’.
4.104The ECNT explained that dredging would have negative impacts on marine health through increasing turbidity, and could overlap with other negative effects from industry:
It is possible that dredging impacts from the Middle Arm Industrial Precinct may overlap or add to the cumulative impacts associated with maintenance dredging for the Darwin Port, which could intensify or prolong the impacts described above [coral destruction and death, and fish and invertebrates damage and behavioural changes].
4.105In addition to the immediate impacts of dredging, the joint submission from the Public Health Association of Australia and NT Paediatricians raised concerns about the impact of petrochemical wastewater on mangroves:
Wastewater from petrochemical facilities can contaminate mangrove ecosystems, causing accumulation of heavy metals in the plants. This not only damages the plant, but also puts the animals living within the mangroves at a higher risk of consuming increased levels of heavy metals, such as lead.
4.106In a similar vein, the Australian Marine Sciences Association pointed out that mangrove habitats face additional threats from development:
It is not just the impact on the mangroves and, once again, the resuspension of pollutants in the sediments; we also need to factor in climate change, and this is a critical factor. We're talking about a very shallow system here. Even small rises in sea level can have major impacts in terms of inundation of mangroves. As we know, mangroves migrate with rising sea levels. When sea levels start to rise, you get what's called coastal squeeze and the mangroves literally have nowhere to move to.
4.107On a separate note, the Australian Marine Sciences Association expressed concern about the lack of research and mapping of the ecological and cultural values of Darwin Harbour:
My greatest concern with the whole of the Darwin Harbour project is the enormous knowledge gaps that we have within the harbour. I don't think many people are aware just how understudied that harbour is, particularly in terms of its biology and its ecology and as an ecosystem. For instance, we haven't even done any acoustic or satellite tracking of any of the animals, so megafauna [such as dolphins and dugongs]. We have very little understanding of the movement of the animals. We have also, as I said, very few bioaccumulation studies looking at the consequence of pollutants. At the same time we also know very little about the benthic habitats [associated with or occurring on the bottom of the harbour] within the region, particularly some of the coral reefs within the area.
Industry monitoring of the harbour
4.108According to the NT Government, INPEX’s marine monitoring program aims to ‘enhance research and monitoring activities undertaken in the harbour’, with habitat monitoring focusing on mangrove habitats. Other monitoring is conducted on sediment, water quality and anthropogenic pressures (such as land clearing, foreshore development, shipping, dredging and other stressors on the harbour).
4.109However, some submitters raised concerns over the integrity of INPEX’s funding of marine monitoring of the Darwin Harbour. For example, the ECNT was concerned this may represent a conflict of interest and that the gas industry was able to control what information from the program is released:
…much of the marine research undertaken in Darwin Harbour has been funded and controlled by the gas industry. For example, the Darwin Harbour Integrated Monitoring and Research Program (funded by INPEX) has become the default long-term marine monitoring program for Darwin Harbour, and INPEX retains a veto over the public release of this data.
4.110Similarly, the Australian Marine Sciences Association was concerned about the adequacy of the monitoring program itself, arguing that there has been minimal monitoring of ecological values and impacts:
Essentially, the integrated research and monitoring program set up under the partnership between INPEX and the Northern Territory government was an offset program. It has kind of evolved into this monitoring program that has now rolled out to stakeholders to suggest the harbour is somehow being monitored to protect its ecosystem values and that's clearly not the case. We see very minimal monitoring of ecological values of biota and megafauna. These are some of the critical conservation values. Recreational fisheries are one-third of the catch in Darwin. We see very little monitoring of the cultural values, particularly the seafood harvesting by local [First Nations] people. The heavy metal monitoring that is done is primarily looking at what's in the sediment because that's easy to monitor. What we don't see is any monitoring of bioaccumulation or impacts on the food chain in general, particularly on edible species.
4.111As a result, the Australian Marine Sciences Association called for independent marine monitoring, research and monitoring of the impacts of dredging, as well as a dredging strategy for Darwin Harbour.
Use of environmental offsets
4.112Some inquiry participants expressed concerns about the proposed Middle Arm development’s intended use of environmental offsets.
4.113For example, DEA noted that the NT Government’s Middle Arm Industrial Precinct Draft Program recognised ‘the inevitability of ecosystem damage and biodiversity loss from industrialisation’, ‘that these [impacts] will be significant’, and ‘that offsets will therefore be required’.
4.114DEA further outlined some of the key concerns with using these types of offsets:
Biodiversity offsets are highly controversial. Indeed, in a 2020 review of Australia’s key environmental legislation [the Samuel Review], offsets in Australia were overall found to be poorly designed and implemented, too often delivering a net loss for the environment. There has been particular criticism of the biodiversity offset scheme in the NT on the grounds that a lack of local biodiversity data makes it near impossible to assess the extent to which a compensation will adequately address biodiversity lost.
4.115Similarly, Mr James Richardson, a mathematical ecologist at the University of Queensland, argued that offsets cannot possibly offset the specialised populations and ecosystems at Middle Arm:
Offsets for biodiversity have been heavily criticised by ecologists, economists and policy specialists; biodiversity is fundamentally not a commodity that can traded, it is a single metric reflecting a complex system of interactions that are inherently tied to a given location. Nonetheless, in the case of Middle Arm’s small mammal populations, even if offsets were plausible in theory, given their central importance to the overall survival of the species, offsets for these populations are manifestly impossible.
Calls for impact methodologies to be released
4.116Arising from concerns regarding the potential climate, human health, and environmental impacts of the proposed development, several submitters expressed concerns that the methodologies for baseline calculation and impact assessments have not been released.
4.117Some argued that this ‘makes it extremely difficult for stakeholders to be informed and participate meaningfully in the process’. Indeed, Humpty Doo Barramundi noted that the Strategic Environmental Assessment (discussed in Chapter 5) means that the Middle Arm Industrial Precinct ‘could be approved as whole for 50 years, and then individual projects could be subjected to a quicker/less rigorous environmental approval process’.
4.118The DEA, ACF and ECNT argued that the proposed methodologies for climate risk assessment, cultural heritage and cultural values assessment, health impact assessment, and cumulative impact assessment should be peer-reviewed and publicly disclosed.
Next chapter
4.119The following chapter considers the differences between the Commonwealth and Territory approvals processes, as well as concerns raised by submitters in relation to these approvals.