Senator David Pocock's Additional Comments
1.1The proposed Middle Arm petrochemical precinct poses unacceptable risks to human health, the climate, biodiversity and cultural heritage. The circumstances surrounding a decision to provide a $1.5 billion federal government equity investment in the precinct without detailed advice from Infrastructure Australia remains shrouded in secrecy and deserves further examination. Australian taxpayers should not be subsidising a petrochemical precinct that poses such significant threats.
1.2Make no mistake, the proposed development at Middle Arm is a plan to build a fossil gas and petrochemical precinct. Although some proponents have proposed projects that do not rely on fossil gas, it is clear that the current design of the precinct is structured in a way that has gas at its core. The attempts by the Northern Territory (NT) and Federal Labor Governments to dress the project up as a ‘sustainable development hub’ are misleading and should be dismissed outright. As long as the export and processing of gas remains foundational to the project, the equity investment from the Federal Government must be called out for what it is: a fossil fuel subsidy.
1.3The precinct would enable gas processing or hydraulic fracturing (‘fracking’) of the Beetaloo Basin and the development of offshore gas reserves in the Timor Sea. These projects are unambiguously incompatible with limiting global warming to 1.5°C. The Intergovernmental Panel on Climate Change (IPCC) and the International Energy Agency (IEA) are clear: this is the critical decade for phasing out gas, and no further gas projects should be opened.
1.4Beyond the climate impacts of this precinct, which will be felt across the globe, the precinct risks having dramatic impacts for the health and wellbeing of Darwin residents and Traditional Owners, as well as local biodiversity.
1.5Substantial academic evidence has been available to the Senate Environment and Communications References Committee (the committee) that shows that the development could have an unacceptable impact on the health of Darwin residents, which may not be able to be controlled or mitigated. The risks to residents living near this gas and petrochemical precinct include higher rates of hospitalisation for cardiovascular disease, increased rate of childhood leukemia, reduced life expectancy from all causes and increased rates of miscarriage.[1]
1.6Advocates of the Middle Arm development claim that it will bring significant economic benefits to the Northern Territory. It is likely that the benefits are overstated, particularly given the experience with the INPEX Ichthys onshore facility, which pays no Petroleum Resource Rent Tax (PRRT)[2] and only contributes a small amount in payroll tax on the few hundred people it employs. At a more local level, it is likely that the health impacts of the project will far outweigh any economic opportunities that the project brings to the Darwin region.
1.7Significant federal investment to build infrastructure and promote industry in the NT is justified. But any investment must have guardrails. It must represent value-for-money for Australian taxpayers, and it must not benefit gas companies or petrochemical manufacturers, given the significant risks that the project presents.
1.8I thank the committee, the committee secretariat, submitters and witnesses for their engagement in this inquiry. In particular, I thank the Chair, Senator Sarah Hanson-Young for the substantial work required to progress the inquiry and produce this report.
1.9The literature exploring the health impacts of unconventional gas operations, Liquefied Natural Gas (LNG) manufacturing and petrochemical manufacturing to nearby communities is now so robust that we have moved well beyond the precautionary principle and can say that an expansion of these industries so close to communities in the Northern Territory will cause harm.[3]
1.10A number of reports were provided to the committee during its inquiry, and these reports themselves drew upon dozens of studies setting out the harms of living near fossil fuels.
1.11There is no feasible scenario where a project that carries the health risks of the proposed Middle Arm development would ever be constructed, for example, 5kilometres from metropolitan Sydney or 3 kilometres from the suburbs of Melbourne. Darwin is being treated as a sacrifice zone for the benefit of the gas industry, jeopardising the health, wellbeing and livelihoods of the 130,000 people that live in the Darwin area. Approximately half of the Northern Territory population lives in or close to Darwin.[4]
1.12As outlined in greater detail in the Climate section below, the lifecycle emissions from the Middle Arm project would contribute further to worsening climate change. A number of submitters raised the unique threats that climate change poses to the Darwin region and the NT more broadly. For example, Australian Parents for Climate Action submitted:
Modelling by CSIRO indicates that without drastic reductions in greenhouse gas emissions, the number of days over 35 degrees in Darwin will increase to 187 days per year by 2050 and 275 days per year by 2070.Combined with high humidity, these temperatures pose a distinct threat to all Territorians, with an increase in severe health impacts and heat-related deaths.[5]
1.13Likewise, Professor Melissa Haswell submitted:
However, if global action now is not sufficient, we will see rapidly escalating changes well beyond what we have already experienced. As noted above, the likelihood of catastrophic (abrupt and irreversible) global impacts will increase with steady deterioration of planetary conditions. Current global policies are leading to a 2.7°C rise, which is beyond catastrophic (IPCC, 2023). According to The Lancet Countdown on health and climate change, under conditions of catastrophic climate change it will no longer be a question of whether we can adapt, but one of fighting for survival, as ‘hothouse’ Earth no longer provides the basic necessities, such as safe, clean and sufficient food, water and air (Costello et al., 2023).[6]
1.14In support of this, I draw attention to the recent synthesis of evidence on the risks of oil and gas developments for human health and wellbeing, prepared in 2023 by Professor Melissa Haswell, Jacob Hegedus and Professor David Shearman (the Haswell, Hegedus and Shearman Report).
1.15The report presents a comprehensive review of the literature on health and wellbeing risks associated with oil and gas developments. There are more than 2,000 peer-reviewed papers now published on this topic, predominantly from the United States where a large, focussed research response has been mobilised to examine growing health concerns being observed in communities living around, downwind and upstream of oil and gas operations and developments.
1.16Haswell, Hegedus and Shearman cite that a large number of studies have now reported health effects among children and adults living in proximity to oil and gas operations. These health effects include:
symptoms and markers of disease, including migraine headaches, chronic nasal and sinus irritation, fatigue, nausea, skin rashes, eye irritation, nosebleeds, asthma exacerbation requiring medication changes and cardiovascular disease indicators;
higher hospitalisation rates among adults for heart disease, including heart attacks and heart failure;
higher hospitalisation rates for respiratory and neurological diseases;
higher hospitalisation rates for those with existing asthma conditions;
higher hospitalisation rates for some childhood cancers and immune deficiency disorders;
increased deaths and reduced life expectancy from cardiovascular disease and respiratory diseases and some cancers and from all causes;
higher incidence of mental health conditions, including depression and anxiety and new onset of internalising disorders (e.g. social withdrawal) among adolescent females; and
increased incidence of sexually transmitted infections, resulting from changes in sexual behaviour that can be associated with an influx of Fly in and Fly Out workers in depressed areas.[7]
1.17Distressingly, there is also increasing evidence that proximity to oil and gas developments is impacting the outcomes of pregnancies and the healthy development of foetuses, which are uniquely sensitive to environmental hazards. As stated in the report, the evidence shows that negative birth outcomes include:
reduced average birth weight;
higher incidence of low-birthweight babies;
higher frequency of preterm and extreme preterm deliveries and spontaneous abortions (miscarriages);
birth defects, including congenital heart valve defects, anencephaly, spina bifida and gastroschisis; and
higher incidence of blood cancers, especially acute lymphoblastic leukemia.[8]
1.18Crucially, the Haswell, Hegedus and Shearman Report synthesises the evidence showing that these health impacts appear after a gas development has commenced—not before. As summarised in the report:
Many studies have demonstrated that these outcomes occurred after, not before, gas development commenced, while others have shown that these outcomes specifically occur downwind and/or downstream (groundwater flow) of gas operations. Most studies have controlled for a wide range of potential confounders (other explanations for the observed differences).[9]
1.19According to Haswell, Hegedus and Shearman, reported health outcomes are similar across different basins, demonstrating the applicability of this evidence to different basins and different oil and gas developments globally:
A substantial quantity of increasingly rigorous research evidence has accumulated from studies across oil and gas basins, especially in the United States. Each gas basin is different in its geography, hydrogeology (underground rock and water systems), chemistry (different mixtures of added and naturally occurring chemicals), weather and air flow characteristics, legislative regimes and regulatory compliance, and social and cultural diversities. Despite these variations, there is a consistency across locations in finding a greater burden of health loss among those most exposed to oil and gas operations and infrastructure.[10]
1.20As stated by Professor Haswell at the public hearing on 11 April 2024, the evidence is applicable to the proposed operations at the Middle Arm development, given the volatile organic compounds and other toxins expected to be emitted through the production of LNG that have been the focus of much of the research conducted in the United States:
We talk about LNG—it's only three letters long, but if you actually dig into what those processes are, they're very complex, particularly in the first section, called the hot section. That's where there's a lot of removal of the contaminants of the gas, during that phase, and that includes volatile organic compounds and sulphur dioxide and hydrogen sulphide, which are all chemicals capable of causing those health effects that are seen elsewhere…So this whole process here happening three kilometres from, and very close to, a large population raises all kinds of concerns about exposure of that population. For mitigation of those health risks, there's evidence that they are unmitigable. They can be reduced but there still is, as we know and as you quoted, 11 [thousand] tonnes of VOCs [volatile organic compounds] already going out into the atmosphere from impacts.[11]
1.21I asked Professor Haswell to update the committee of any developments in the available research that were published after she had prepared that synthesis in 2023. Professor Haswell submitted an additional eight papers.[12] While Professor Haswell’s commentary on all eight papers can be found in the answers to questions on notice, I draw attention to one of the papers in particular—the scoping review of epidemiological studies conducted by Aker, Fiesen and Ronald (2024).
1.22This study synthesised the findings from 52 studies, many of which were also cited in the Haswell, Hegedus and Shearman Report. Reinforcing the conclusions of the latter report, Aker, Fiesen and Ronald’s study reported:
There is a growing body of research, across multiple jurisdictions, reporting adverse effects of unconventional oil and gas development exposure on human health, with an accumulating weight of evidence particularly in relation to birth outcomes and asthma. There is some evidence of disproportionately greater impacts in racialized populations with relatively little research focused on the differential exposure levels and effect modification by systemically disadvantaged populations.[13]
1.23In answers to questions on notice put by Senator Lidia Thorpe, Professor Haswell concluded that the strength of the evidence that already exists shows that gas operations cannot be safely located near a population centre without adverse health impacts:
The only way to avoid direct risks to human health from gas and petrochemical manufacturing plants is ensure that they are not located anywhere near where people live, work and play. The proposed Middle Arm is extremely close to a major population centre, and gas infrastructure beyond the wells, such as pipes and many compressor stations required to push the gas through the pipelines to Middle Arm safely without explosions also pose significant risk of exposure to a wide range of toxic gases (Davis et al., 2023).[14]
1.24Crucially, Professor Haswell has submitted to this Inquiry that there is no evidence demonstrating that regulation can reduce the risks of gas operations to human health:
The science tells us that gas processing and petrochemical manufacture cannot be safely established in populated areas. The increasing body of research from around the world shows with increasing confidence that pollution from the gas industry increases the risk of disease in resident communities 4 and an absence of research that demonstrates effective measures to prevent these health risks. Each location where the gas industry has operated has claimed that they implement world class safety standards, yet we see evidence of health risks and harms across many locations where studies have been completed.
…the enormous experience of the United States, the Compendium provides compelling evidence that regulation in the real world does not protect people nor the environment from the risks of gas operations. LNG production and handling adds substantially more complex chemical, environmental and climate hazards on top of those of gas production and processing. The Darwin and broader Northern Territory environment, and its propensity for extreme weather events including heat waves, downpours and cyclones, likely adds even more to the potential for protections to fail, further increasing the probability for these hazards to impact even more on directly and indirectly on people’s health, including unborn children (Petroni, 2022; Concerned Health Professionals of New York and Physicians for Social Responsibility, 2023).[15]
1.25Many of the same sources within the Haswell, Hegedus and Shearman Report were also summarised and reported in the submissions made to this inquiry by the Public Health Association Australia and NT Paediatricians,[16] Doctors for the Environment Australia (DEA),[17] and the Climate and Health Alliance.[18] While I won’t summarise all of that evidence, I will highlight the alarming evidence on pregnancy outcomes outlined by the Public Health Association Australia and NT Paediatricians:
Living less than 5km from a petrochemical facility is an important risk factor for adverse birth outcomes. Petrochemical air pollutants increase the risk of premature membrane rupture, which can lead to complications and perinatal morbidity and mortality, including placental abruption, foetal distress, and neonatal sepsis.
Long-term complications for the baby include chronic lung diseases, visual or hearing difficulties, and neurodevelopmental disorders. Low birthweight (LBW) and pre-term birth are also a potential outcome. This is concerning given LBW in the NT is higher than the nation’s average and Aboriginal mothers in the NT are more than twice as likely to have a baby with LBW.[19]
1.26In addition to the Haswell, Hegedus and Shearman Report, the Environment Centre NT (ECNT) and the Royal Australian and New Zealand College of Psychiatrists drew the committee’s attention to Dr Michael Petroni’s 2022 report on the potential environmental and human health impacts of the project.
1.27The report found that the Middle Arm project would result in an increase of industrial fine particulate emissions by 513 per cent in the region. This would result in $75 million of additional health impacts, equivalent to 15additional premature deaths, per year. His modelling also found that the project would also increase the industrial cancer hazard in the region four-fold due to releases of formaldehyde, acetaldehyde, polycyclic aromatic compounds, and additional air toxins.[20]
1.28Dr Petroni’s report also outlined the substantial increases in emissions of other toxic gases that would result from the project, summarised in the table below.[21]
1.29Throughout the inquiry, many submitters and witnesses also drew the committee’s attention to the existing unique health challenges within the NT and how these could be made worse by the proposed expansion of the gas industry on Middle Arm. Health care system representatives told the committee, in no uncertain terms, that the NT’s health system cannot cope with any worsening of health or conditions for residents of the NT.
1.30The strain on the NT’s health system was put forward by the Public Health Association of Australia and NT Paediatricians:
There were nine ‘Code Yellow’ incidents at Royal Darwin Hospital and Palmerston Hospitals in the 2022-2023 financial year with Royal Darwin operating over its capacity on a daily basis. This indicates a health system which is not coping with current demand. Putting aside the ethics of exposing populations to harmful toxins, the health system cannot cope with the current burden of disease, let alone an increase due to the pollution predicted to be emitted from [Middle Arm Industrial Precinct].[22]
1.31Ms Catherine Hatcher from the Australian Nursing and Midwifery Federation NT stated that the NT has some extremely vulnerable Indigenous patients requiring treatment that cannot be provided locally:
Eighty per cent of people in the hospitals, currently and ongoing, are Indigenous. They are our First Nations people. They are the sickest; compared to working in South Australia 24 years ago, this cohort is sicker than anyone else I've looked after interstate. Child leukaemia is one of the risks from all this. We have no paediatric oncology service here in Darwin or the Territory; they would all have to go interstate. A lot of people have to go interstate because we don't have the services to offer here.[23]
1.32Ms Hatcher also stated that the NT health system is already struggling to keep up with demand, with nurses and midwives reporting that they are burnt out and have taken extended leave without intending to return to the health system.[24]
1.33Dr Katherine Barraclough, a consultant nephrologist supporting the Climate and Health Alliance told the Committee about her experience working with patients with kidney conditions:
I'm a kidney specialist and I'm based in Melbourne but have worked for extended periods in the NT over my 20 years as a doctor. I continue to provide kidney care to remote communities. The rates of kidney disease in the Northern Territory are just astounding. The ability to care for people with kidney disease there is not to the same extent as in the rest of the country…[25]
1.34Dr Barraclough highlighted a study from Taiwan which showed ‘a 30 per cent increase in odds of chronic glomerulonephritis [a form of kidney damage]…in those who live within three kilometres of a petrochemical processing plant’, with the effect still felt within 10 kilometres. Dr Barraclough told the committee that, with regard to the petrochemical plants in the study, ‘you have these exorbitant rates of kidney disease, exorbitant rates of death from kidney disease compared with the rest of the population…’[26]
1.35Further, existing severe shortages in trying to treat kidney conditions in the NT were also set out for the committee by Dr Barraclough:
At the moment, there are not enough dialysis chairs in the state to provide dialysis, and access to transplantation is appalling on a national standard, yet it's considered reasonable to add in a new insult to kidney health. I say that as a kidney specialist but you can put a cardiologist in this chair, a neonatologist, an obstetrician, a geriatrician or a respiratory physician; it's not one organ system. From a health perspective, this proposal is unfathomable.[27]
1.36Dr Louise Woodward, a practising paediatrician in the NT noted the significant impact that anything that harms health will have on Indigenous people in Darwin and suburban Palmerston. Dr Woodward drew attention to the types of health challenges already experienced in the NT by Indigenous patients, and set out the distressing nature of being away from home for prolonged periods:
The health impacts of gas processing…will exacerbate chronic conditions of all sorts plus increase pregnancy complications as well as the cancer risk. What this means for Aboriginal people is that their kidney disease gets worse, which then they're tipped into dialysis, which means they often have to move to a different place or they need a kidney transplant, which means they need to live in a major city. If a mother goes into labour early with a small preterm baby, she has to be flown interstate for care, which causes enormous disruption and dislocation. If a child is diagnosed with leukaemia, that is a trip interstate for six months to two years of treatment. Can you imagine? It's bad enough for non-Indigenous people, but, for Indigenous people, being taken away from their home for prolonged periods of time for medical care is particularly harmful.[28]
1.37Dr Jenny Summerville from the Aboriginal Medical Services Alliance NT set out how the Middle Arm Precinct’s associated worsening health conditions will ‘exacerbate already very poor outcomes for Aboriginal people in the NT:
There's also the housing crisis that it would create. We know that a lot of poor health outcomes for Aboriginal people in the Northern Territory are related to overcrowded housing. It's an issue already. We saw that with INPEX. Rental stress went through the roof. It wasn't just Aboriginal people living in overcrowded housing; it was a lot of families. That kind of situation then creates stress on the hospital, and it creates stress on our member services who are trying to pick up what the hospital can't or to keep people out of hospital. It's this massive flow-on effect. If we're going to commit to closing the gap and truly do that, to then invest this money in a development that we know will create negative health outcomes is an ultimate irony.[29]
1.38Multiple witnesses and submitters also raised concerns with how the NT Government will be conducting its human health impact assessment for the Middle Arm development.
1.39The Environment Centre NT (ECNT) cited Dr Petroni’s concerns with the methodology used to undertake the health impact assessment:
There appear to be serious deficiencies in the way in which health impacts are being assessed via the strategic environmental assessment. Dr Petroni identified the following requirements:
A robust health impact assessment must occur, including specification of the geographic boundaries of the analysis more precisely, a health baseline study, and a health monitoring plan;
the airshed model requires excellent input data to provide a meaningful picture of the likely impacts of new facilities.
Instead, no health impact assessment appears to have been undertaken as part of the EIS [Environmental Impact Statement], contrary to Federal Health Impact Assessment Guidelines. Furthermore, Dr Petroni has raised concerns about the methodology used for the airshed model, which is that industry voluntarily fill out a one-time survey about their emissions. Given the gravity of known risks associated with industries proposed for Middle Arm, an airshed model based solely on voluntarily reported emissions is entirely inappropriate. Voluntary reporting is likely to lead to an inaccurate representation of the baseline landscape of emissions, and an underestimation of the overall harms that communities face.[30]
1.40DEA shared concerns raised by the ECNT, and in particular: that the referral documentation included limited detail regarding the actual developments planned; that the methodologies for the strategic assessment for the calculation of baselines and impact assessments have not been released to the public; and, that the strategic assessment area has not been clearly defined or justified. DEA further stated that these are ‘major information gaps’ which ‘prevent meaningful public engagement with the Middle Arm development’:[31]
It is unacceptable that details about what is proposed may not be available to the public until the environmental impact statement is publicly released, leaving only a few weeks for the public to become informed about the project and provide comment on it.[32]
1.41Likewise, Dr Louise Woodward raised concerns with the omission of a health impact assessment from the initial Environmental Impact Statement (EIS), and called on the committee to:
…prioritise the health and safety of the people of the Greater Darwin Region by:
(1)ensuring the Middle Arm EIS is not released for public exhibition until a comprehensive Health Impact Assessment (HIA) is completed for all nominated industries.
(2)Ensuring that the HIA is undertaken with robust methodology approved by a panel of independent public health experts.
(3)Ensuring that the health impacts of climate change are included in the HIA.
(4)Ensuring that the risks of extreme weather, storm surges, and sea level rise are considered in the EIS.[33]
1.42The Climate and Health Alliance similarly stated that the EIS for the Middle Arm Precinct should not be released until a comprehensive HIA has been undertaken, but added that it should also include completion of:
assessment of the contribution to climate change through scope 1–3 emissions generation; and
direct consultation with nearby communities to be affected by the development, including First Nations communities.[34]
1.43While I recognise that the NT Government is conducting a strategic assessment, the concerns raised in this inquiry centre around the transparency of that process and the ability of experts to properly scrutinise the methodologies being used to assess the potential health impacts.
1.44Evidence presented to the Committee that the proposed development would not have an adverse impact on the health of Darwin residents was thin.
1.45While the NT Government stated that the Middle Arm development is ‘back [sic] by 200 technical studies assessing its impact’[35] none of them were provided to the committee when requested. Therefore, no judgement can be made about their contents or any of the conclusions they may draw on the impacts of the development to human health. The NT Government declined to provide these technical studies to the committee, on the grounds that the assessments were ‘still underway’.[36]
1.46The only parties to submit to the inquiry that there were either no health impacts from oil and gas developments to human health, or that the impacts could be well-controlled, were the gas industry - an industry that stands to benefit the most from this development.
1.47During the third public hearing of this inquiry, I tabled four high-quality peer-reviewed papers which included studies from:
researchers at the Harvard T.H. Chan School of Public Health and Lund University, which found a statistically significant higher mortality risk associated with living in proximity to and downwind of unconventional oil and gas wells;[37]
researchers at the Yale School of Public Health and the Georgetown Lombardi Comprehensive Cancer Centre, which found that children living within 2 km of an unconventional gas well had 1.98 times the odds of developing acute lymphoblastic leukemia than those who did not live near a well;[38]
researchers from the University of California, Columbia University and San Francisco State University, who concluded that proximity to higher production oil and gas developments was associated with adverse birth outcomes for mothers residing in rural areas;[39] and
the University of Warwick and the University of Leicester, which concluded that the risk of developing leukemia appears higher in people living near a petrochemical facility.[40]
1.48When asked to respond to just this sample of peer-reviewed studies, Tamboran submitted a general critique, stating:
It is concerning that several studies, often cited in opposition to the gas industry, contain several limitations and variability across years, location, duration and frequency of sample collection. A large portion of the literature overlooks primary data collection, instead presenting findings based on observational methodologies, which lack the objectivity needed to establish causation. Further limitations include no standardisation of metrics of symptoms, no confounding variables used in analysis, no consideration that population is not generalisable to broader population, and failure to adjust for pre-determined health factors, additional exposure sources and social economic factors.[41]
1.49In the same answer, Tamboran pointed to reports from the Pennsylvania Department of Health and the Colorado Department of Public Health and Environment (CDPHE) as evidence that there have been no credible studies reporting an association between oil and gas developments and adverse health outcomes:
We point to an assessment undertaken by the Pennsylvania Department of Health and the Colorado Department of Public Health and Environment (‘CDPHE’) that assessed studies purporting a link between oil and gas and health. Using a scientific method for evaluating the weight of evidence, the two state health agencies concluded that none of the studies alleging cancer were sufficient and it is probable that there are social characteristics and differing access to medical care that would explain the findings. The agencies highlighted a range of insufficient evidence, or in some cases, a lack of evidence for the possibility of harmful health effects.
An additional assessment by the CDPHE found no substantial or moderate evidence for any health effects and significantly limited evidence for skin symptoms and exacerbation of asthma. Several studies classified as low quality evidence by the CDPHE are cited to support allegations in the documents tabled by Senator David Pocock in this inquiry.[42]
1.50Tamboran also drew attention to the 2017 Pepper Inquiry:
The Scientific Inquiry into Hydraulic Fracturing in the Northern Territory (‘Pepper Inquiry’) referred to the CDPHE’s assessment as a useful summary by a competent US Public Health authority and included a summary of this review in the Panel’s Final Report. Tamboran acknowledges the 15 months of work by the Pepper Inquiry to finalise the 135 recommendations, all of which the NT Government has implemented.[43]
1.51I asked Professor Melissa Haswell, as a recognised expert in environmental health, to provide a critique of this response in a recent question on notice:
I find that [Tamboran’s response] provides no critique of high-grade peer-reviewed articles, there is no analysis of methods or findings which is required in a critique.Instead…There is a listing of various shortcomings that occur in early research in any field. There is no matching of criticisms with actual aspects of the papers presented by Senator Pocock, as these studies are of the highest possible quality and do not contain those limitations. Every field of research on highly complex operations like oil and gas is that early papers, such as the 2014 paper by McKenzie mentioned in Table item 5 ofTamboran’s response, are needed to build the foundation for more sophisticated papers that emerge later. That has certainly occurred in the relevant literature on the health risks associated with shale gas.
It is remarkable that one 2014 paper (the McKenzie paper) is included in [Tamboran’s response] in a research field that has grown rapidly. The 2014 paper is the only one of many much newer papers that did not find that proximity to oil and gas wells is associated with lower birth weights.
Incidentally, the 2024 paper by Professor Elaine Hill explained this anomaly in the 2014 McKenzie paper (higher birth weights closer to drilling). Hill found that in Colorado which has had oil and gas activity since 1904, unlike Pennsylvania which only began in 2008, nearness to drilling activity is linked to higher socioeconomic status, which is linked then to heavier babies. This explains why McKenzie et al. (2014) found higher birth weights than expected, a confounder which the earlier studies did not control for but certainly all subsequent papers have done.
Unfortunately what we see in the information provided in [Tamboran’s response] is the problematic ethics of attempts at downgrading descriptions of evidence on matters which pose barriers to the application of the precautionary principle on significant human health concerns. In my QON Submission 8, I state: “This is inconsistent with the Ethics Guidelines recently published by the International Society for Environment Epidemiology (Hetzel et al., 2024) which state that the epidemiologist should present the nature and extent of available evidence in a clear and objective manner, and in such a way as to avoid interfering with or obstructing a precautionary approach. In their “Toolkit for detecting misused epidemiological methods”, Soskolne et al. (2021) identify “Demanding an usually high degree of certainty for the public health problems to be addressed; claims that more data are needed for proof of elevated risks” are frequent ways that epidemiological methods are misused to obstruct a precautionary approach and cause confusion in communities”.
[Tamboran’s response] also referred to a review by Bamber et al. (2019) which concluded that, “Studies of populations living near ONG operations provide limited evidence (modest scientific findings that support the outcome, but with significant limitations) of harmful health effects including asthma exacerbations and various self-reported symptoms. Study quality has improved over time and the highest rated studies within this assessment have primarily focused on birth outcomes. Additional high-quality studies are needed to confirm or dispute these correlations”.
I can say that indeed, both study quantity and quality has continued to improve over time. In the interim years since 2019 when there were approximately 1,902 published studies on the direct and indirect health impacts of oil and gas developments, today there are at least 2,303 such peer reviewed publications. Eight studies indicating negative health associations in the last ten months are described above. I urge the Senators to consult the papers by Caron-Beaudoin et al (number 2 above) and Aker et al. (paper 7), both reviews conducted in 2024 not 2019.
[Tamboran’s response] also mentioned the Pepper review was conducted in 2017, when only 1,377 papers were available (one thousand less than today) and is significantly out of date.
Furthermore, the judgement of the Pepper Inquiry was theoretical, it was not grounded in, especially today’s, evidence and experience about what actually happens in oil and gas developments. Indeed, as noted in the Hansard, there have already been multiple incidents and violations occurring in the exploration phase of gas developments, as well as a report of 11,000 tons of VOCs being emitted by the existing LNG facility in Darwin, 22 times the expected level of emissions in their Environmental Impact Statement. To say what might happen versus what actually will happen is an important distinction.
Furthermore, I have presented serious new concerns about the potential heavy metal mobilisation into marine foods consumed by the people of Darwin, from the dredging and acid sulphate soils associated with Middle Arm development. These concerns add a new potentially significant health dimension, adding to our serious air pollution concerns, related to the development of LNG export facilities in Darwin Harbour.[44]
1.52Despite the rebranding as a ‘sustainable development precinct, the strongest evidence that the proposed Middle Arm precinct is focussed on gas is from the NT Government itself. As part of the NT Government’s Strategic Assessment process, several precinct industry scenarios were considered for use as the basis for the scope of development. Ultimately, the ‘Balanced Scenario’ was used for modelling[45] which used one each of the following industry types:
liquified natural gas plant
gas to liquids plant
blue hydrogen plant
green hydrogen plant
ammonia plant
green ammonia plant
urea and derivatives
methanol plant
ethylene (ethane cracker) plant
minerals processing plants.[46]
1.53Ms Louise McCormick, NT Infrastructure Commissioner, confirmed that an expanded gas industry was included in this ‘worse case’ scenario.[47] Indeed, the NT Chief Minister, the Hon Eva Lawler MLA, told the committee: ‘we absolutely support the onshore oil and gas industry in the Northern Territory’.[48] Ms Lawler refused to rule out petrochemicals processing at the proposed Middle Arm Industrial Precinct.[49]
1.54Separately, the former NT Chief Minister, the Hon Natasha Fyles, stated in November 2022 that the proposed Middle Arm Industrial Precinct was ‘not a petrochemical plant’.[50] However, the Stage 1 submission from the NT Government to Infrastructure Australia noted:
The potential recovery of natural gas liquids from the onshore Beetaloo Sub-basin project means there is also an opportunity for future production of ethane-based products such as plastics, paints, polymers and rubbers as well as the production of liquid fuels to help address Australia’s energy security. Some of the potentially suitable natural gas downstream products are shown in Figure 3. Downstream gas processing in Darwin will create a new gas demand centre and open up opportunities for related industrial development, employment, education and training.[51]
1.55The MOU, signed by the Commonwealth and NT Governments in 2018, and EIS documentation from 2022, provide further evidence of the sustained focus on gas:
In November 2018, the NT and Commonwealth governments signed an MOU recommending the creation of a “Middle Arm Industrial hub” which has the aim of “establishing the NT as a world class gas production, manufacturing and services hub”, including “establishing gas based manufacturing and services”. The parties agree to “delivery of infrastructure and programs in support of the Northern Territory Gas Industry and gas leveraged industries”…[52]
In EIS documentation submitted to the NTEPA in January 2022, the Middle Arm Sustainable Development Program (MASDP), the following list of industries are included as part of the assessment: “Liquefied Natural Gas (LNG), Ammonia and derivatives, Urea and derivatives, Ethylene and derivatives, Methanol and derivatives, Gas to liquids (GTL), Hydrogen, Carbon capture and storage, Minerals processing, Advanced manufacturing, Support service industries”. These industries remain in the scope of the strategic environmental assessment…[53]
1.56The ECNT submitted that, as the Stage 2 submission to Infrastructure Australia sets out, with ‘close to three quarters of the site dedicated to gas-based industries’,[54] funding promised by the Commonwealth is nothing more than a fossil fuel subsidy which will directly fund the gas industry:
Freedom of information documents demonstrate that the $1.5 billion in federal funding is for dredging the harbour and the construction of up to five jetties and wharves labelled for shipping of LNG, methanol, ethylene, ammonia and “clean petroleum”. The remaining wharf is labelled “hydrogen”.[55]
1.57Other submitters also saw through the greenwashing. Vets for Climate Action argued that:
…this project is, and always has been planned as, a fossil fuel project; specifically to facilitate gas expansion and transport of fracking gas in the Beetaloo Basin and the Barossa Gas Project.[56]
1.58Parents for Climate Darwin expressed their disappointment at this subsidy for the fossil fuel industry:
We find it disingenuous when our parliamentarians say this funding is not for the benefit of fossil fuel companies and it ultimately undermines public trust in our decision makers. As members of the public and as a community representative group, we are telling this committee that there is a broad public perception that the $1.5 billion is a fossil fuel subsidy and the wider Australian and international community will not look favourably on the government if they pursue their support for this project.[57]
1.59The NT Government, and gas industry proponents, argued that carbon capture and storage (CCS) technology will enable the Middle Arm precinct to be sustainable even if there are substantial gas export and petrochemical manufacturing elements within the site.
1.60According to the NT Government, the CCS hub is ‘central to emissions reduction technologies at the Middle Arm precinct, and ‘will enable existing infrastructure and LNG production to operate and grow with a significantly lower carbon footprint’, and claims that the hub will capture ‘at least 90 per cent of LNG plant emissions at source’ and even have excess capacity to offer to other industries.[58]
1.61Carbon capture and storage is a figleaf for the expansion of the fossil fuel industry. Many submitters raised concerns about issues with the technology and noted it as an enabler of greenwashing.[59] For example, the Center for International Environmental Law (CIEL) submitted that, on the global stage, there are just two projects off the coast of Norway, known as Sleipner and Snøhvit, with neither particularly successful:
At Sleipner, the CO₂ migrated upwards from its intended storage point into a different layer of the subsurface, while the Snøhvit project turned out to have significantly less storage capacity than expected…[60]
1.62CIEL set out that CCS projects onshore have been plagued by cost overruns and technical problems.
While many CCS projects have promised to achieve the 90 percent capture rate promised by the Middle Arm Industrial Precinct developers, very few, if any, have ever actually achieved that rate consistently. In fact, CCS projects have repeatedly overpromised and under-delivered.[61]
1.63CIEL gave the example of the Chevron Gorgon Project on Barrow Island, which has fallen far short of its targeted volumes every year of operation.[62]
1.64Others noted that the Gorgon CCS facility is only sequestering between 30 and 50 per cent of what Chevron originally projected and ‘a far smaller percentage of the project’s total emissions’.[63]
1.65The Australia Institute, Greenpeace, and Parents for Climate Darwin argued that the use of CCS is considered ‘greenwashing’ while the Australian Marine Sciences Association argued that using CCS to achieve net zero emissions is ‘ineffective’.[64]
1.66CIEL noted that the unreliable nature of CCS technology had been noted globally:
This repeated underachievement of CCS led the International Energy Agency (IEA) to acknowledge, in its recent Net Zero Roadmap, that the history of CCS has largely been one of “underperformance” and “unmet expectations.” The IEA also downgraded its estimates of the potential contribution CCS could have towards reaching net zero in the power sector by around 40 percent compared to the agency’s 2021 roadmap scenario.[65]
1.67Given the repeated failure of CCS projects to deliver promised capture rates, and the additional risks and impacts they entail, new fossil fuel industrial facilities and supply projects should not be approved in reliance on CCS.[66] Likewise, the Australian Conservation Foundation argued that:
CCS is a false solution. It is unproven at scale and over long timeframes, and it has consistently failed or underperformed when attempted as a solution for fossil fuel emissions. At best, CCS would only capture a portion of a project’s emissions, leaving the remainder to fuel climate change. CCS should only be used as a last resort for hard-to-abate emissions, not to enable and greenwash new fossil fuel projects.[67]
1.68As currently proposed, Middle Arm is likely to unlock fracking of the Beetaloo Basin and offshore gas projects in the Timor Sea. The result would be a huge and potentially catastrophic increase in greenhouse gas emissions. The Wilderness Society argued that it ‘holds a firm and unequivocal opposition to this project on the grounds that it poses a significant climate risk’.[68]
1.69According to the ECNT, the emissions from the project would far outweigh any carbon reduction efforts of the NT Government and contribute to worsening climate change:
The expansion of the onshore and offshore gas industries in the Territory will drastically increase greenhouse gas emissions, undermining the NT’s emissions reductions targets and increasing the risk of catastrophic climate change.[69]
Dr Petroni found that the Middle Arm industrial precinct couldincrease the Northern Territory’s emissions by 15 million tonnes per annum (or 75%), and could be the single highest greenhouse gas emitter in the NT. When indirect, cumulative and life cycle emissions are included (including the opening up of the Beetaloo, Barossa and Verus gas fields), the carbon footprint of Middle Arm is likely to be indefensibly high.[70]
1.70Similarly, the Australian Conservation Foundation argued that the Middle Arm precinct could generate ’15 million tonnes of carbon emissions per year’, which would increase the NT’s emissions ‘by 75 per cent’. The emissions associated with the fracking of the Beetaloo Sub Basin, and the Barossa offshore gas development, would ‘substantially impact Australia’s climate emissions and ability to achieve international climate commitments’.[71]
1.71Worryingly, predicted sea level rises as a direct result of climate change means that much of the Middle Arm area will be inundated by sea water by 2050, with some data predicting much of the precinct could be exposed to sea level rise and annual flooding as soon as 2030.[72]
1.72DEA argued:
It also identified that the Middle Arm Precinct is proposed for a stretch of Australian coastline that is cyclone prone for 6 months of the year. This makes the risk of accidents at the site resulting from storm surges, high winds, and flying debris far higher than it would be elsewhere. Furthermore, according to CSIRO, sea levels are likely to rise by 20-40 cm across northern Australia in the coming decades due to climate change. Modelling suggests that this and flooding events will lead to regular inundation of the Middle Arm area by 2030, further increasing accident risk. To date, no consideration has been given to this and associated health risks in the planning process.[73]
1.73The ECNT submitted:
Furthermore, the site itself is likely to be at considerable risk from climate change. Middle Arm is extremely low-lying, with rises in sea levels and flooding endangering Middle Arm itself, which is predicted to be regularly inundated by as early as 2030. In addition, there is a significant risk of accidental releases resulting from storm surge, cyclones and climate change induced sea level rise.[74]
1.74Perhaps more worrying is that Infrastructure Australia and the Northern Territory government appear unaware of this risk.
1.75Climate Analytics modelled the impact of Tamboran’s project on Australia’s domestic emissions. They found that the modelling undertaken by CSIRO’s Gas Industry Social and Environmental Research Alliance (GISERA), a government-industry collaboration, ‘underestimated annual onshore emissions by up to 84% from the scenarios used’, and also ‘underestimated the cumulative total emissions over 25 years, including those occurring overseas, by close to 1.5 times Australia’s 2021 emissions’.[75] Climate Analytics also submitted that :
Using updated emission estimates, we find that Tamboran Resources’ plan to develop a 6.6 million tonnes per annum LNG plant at the Australian taxpayer funded Middle Arm gas precinct in the Northern Territory this decade would generate [onshore] emissions equivalent to 2-3% of Australia’s 2021 emissions. This figure translates to adding 6 to 8 million new cars to Australia's roads.
Tamboran Resources’ announced plan to expand capacity to 20 million tonnes per annum would generate emissions equivalent to 10-13% of Australia’s 2021 emissions, equivalent to having 30-38 million additional cars on Australia’s roads.
1.76Climate Analytics modelled how the lifecycle emissions of the project would dwarf Australia’s total 2021 emissions, modelling both current and expanded project emissions:
Cumulatively, over the 25-years life of the project and including exported emissions, Tamboran Resources’ plans to frack the Beetaloo and produce LNG would generate between 0.8 to 3.2 GtCO2e, when the IPCC and the IEA make it clear that existing fossil fuel infrastructure set us on track to exceed the remaining 1.5°C compatible carbon budget.
The emissions from Tamboran’s plans are 8-51% of Australia’s cumulative emissions from 2024 to 2050, if Australia’s emissions were to decline consistently to become net-zero by 2050.[76]
The lifecycle greenhouse gas emissions resulting from Tamboran's current development plans…would amount to between 33 and 47 million MtCO2e annually, accounting for 7 and 10% of Australia's 2021 total emissions.
A larger scale development of the Beetaloo sub-Basin would generate significantly higher emissions… [T]he building of a 20 Mt [per annum] LNG plant would generate domestic emissions of 49 to 62 MtCO2e per year... Over the course of 25 years, including overseas emissions, this would release up to 2.9 to 3.2 GtCO2e in the atmosphere…six to seven years’ worth of Australia’s current emissions levels.[77]
1.77The Australian Conservation Foundation argued that:
As we outline below, the current Middle Arm precinct plan and the Commonwealth’s equity investment to support it, is inconsistent with responsible climate action and the Australian government’s commitments under the Paris agreement, including its central objective of pursuing a 1.5-degree limit to global warming.[78]
….As such, the Middle Arm Industrial Precinct must not proceed because it is a key enabler of the ongoing use, development of and exploration for, fossil fuels.[79]
The International Energy Agency warned, in 2021 in their Net Zero by 2050 report, that new coal, oil and gas projects need to stop immediately.[80]
1.78Of particular concern is the high CO2 content of the Barossa and Verus gas fields. This means that development of those gas fields, enabled by the Middle Arm petrochemical precinct, is extremely likely to result in a huge increase in emissions.
1.79The Australian Conservation Foundation argued that:
The proposed Barossa offshore gas project, 285km north of Darwin in the Timor Sea, contains one of the largest carbon dioxide reservoirs in the world, and is one of the world’s dirtiest gas projects. If it proceeds, it is projected to release millions of tonnes of greenhouse gases each year, put the marine environment at risk and disrupt traditional Tiwi practices…Conservative estimates project that Santos’ Barossa gas project would be responsible for around 469 million tonnes of carbon emissions over 20 years. For every tonne of LNG produced Barossa is expected to produce 1.4 tonnes of CO2-e, triple the level as other similar gas projects. Gas from Barossa is intended to be piped to the existing Darwin LNG liquefaction facility where additional emissions will be generated through the liquefaction process. As an indication of the scope of these emissions, the INPEX and Darwin LNG facilities emitted 7.98 million tonnes in 2021-22, half of the NT's emissions.[81]
1.80The Middle Arm development presents a significant risk to biodiversity. The area has been identified as a biodiversity hotspot and the proposal seeks to clear 1,500 hectares of the peninsula, leading to significant impacts on threatened species. According to the ECNT, the precinct has the potential to impact ‘a number of key threatened terrestrial species’ such as black-footed tree rats, northern brush-tail possums, and rare and endemic plants. In fact, Lot 1817, which has been allocated to Tamboran’s new LNG facility, ‘is in the centre of a population of Black-footed Tree-rats, and is an important site for other species:
The site allocated to Tamboran’s LNG facility is a known roosting site for the critically endangered far eastern curlew. In fact, the Middle Arm peninsula as a whole meets the criteria for being considered nationally significant with reference to the abundance of four species of migratory shorebird and also with reference to the diversity of migratory bird species. The Middle Arm industrial precinct will impact the availability and integrity of habitat for these and other species.[82]
1.81The NT Government is aware of the significance of the area, and made it a site of conservation significance:
The mangroves of Darwin Harbour support a highly specialised fauna and 14 bird species that are entirely restricted tomangrove environments (e.g. Chestnut Rail, White-breasted Whistler and Mangrove Golden Whistler). TheHarbour itself supports a diverse range of marine speciesincluding dugongs, dolphins, marine turtles and a largevariety of fish. A total of 15 threatened species arereported from within the Site.[83]
1.82Several threatened marine species are reported to inhabit or travel through the waters in and around the proposed Middle Arm Industrial Precinct area including the Flatback, Loggerhead and Green Turtles; Scalloped Hammerheads; Blue Whales; and Whale Sharks.[84]
1.83Relatedly, the Public Health Association of Australia and NT Paediatricians submitted:
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.[85]
1.84The ECNT explained how dredging the harbour would pose unacceptable risks to water quality and marine life in the area. The NT Government is proposing to allow a six-kilometre navigational channel to connect to the proposed offloading facility and jetties, requiring a dredge volume of 20 million cubic metres.:
Dredging releases sediment that can remain suspended in the water in turbid blooms and travel long distances before settling. The INPEX EIS for the Ichthys plant predicted that under some tidal conditions, plumes could reach concentrations up to 50 mg/L and distances up to 10 km from the dredging area, in violation of the water quality objectives for Darwin Harbour, which prescribe a 10 mg/L limit for suspended-sediment concentrations. Turbidity is particularly problematic for hard-coral communities because the particles smother the coral and reduce the availability of light, which can reduce growth and calcification rates and ultimately cause coral bleaching and death. Increased turbidity can also affect fish by impacting their feeding ability, causing gill damage, and giving rise to behavioural alterations like changes in habitat choice and altered predator-prey relationships. Invertebrates are impacted as well; increased suspended sediment can cause abrasion, decreased respiration rates due to clogging of filtration mechanisms, and behavioural changes. It is possible that dredging impacts from the Middle Arm 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.[86]
1.85The background to the Commonwealth’s decision to provide $1.5 billion equity investment into Middle Armremains unclear. The case for Federal Government investment is shaky, and has not been substantiated by Infrastructure Australia. Worryingly, there is evidence that the funding was announced following a significant lobbying effort from the Northern Territory Government and a web of lobbyists and lobbying firms. Middle Arm’s history of lobbying and deal-making is even the case study for the Centre for Public Integrity’s call for reforming the NT lobbying regime.
1.86Several submitters raised concerns regarding the lobbying for funding of the precinct, and in particular the practices of the lobby groups. For example, the Australian Conservation Foundation submitted:
FOI documents reveal questionable lobbying strategy and practices that are worthy of investigation, consideration of whether revision is needed to lobbying rules, and potentially an ICAC referral.[87]
1.87ECNT provided an overview of their concerns about the integrity of the project, and highlighted the interconnected relationships between the main players:
At the heart of the initial design and promotion of the precinct, and attempts to secure funding for the precinct, is former Dow Chemicals boss Andrew Liveris, and former Labor Chief Minister and current lobbyist Paul Henderson.[88]
Liveris sits on the boards of energy and chemicals giants Worley and Saudi Aramco. Both companies are involved in gas and petrochemical production and could benefit from the federal Middle Arm funding.[89]
Liveris has a senior role with Dragoman, a controversial lobbying consultancy. Worley and the Saudi Arabian government have both been registered lobbying clients of Dragoman in the past. During Liveris’ federal government advisory role, Dragoman provided Liveris with behind the scenes “pro bono advice” and support.[90]
Paul Henderson (former Co-Chair of the TERC) was directly involved in the decision to engage Dragoman, advising the NT Government that Dragoman was the appropriate firm to deliver the contract and no local firms would be appropriate.[91]
In November 2020, the Tertiary Economic Reconstruction Commission, co-chaired by former Dow Chemicals boss and SaudiAramco director Andrew Liveris, released its final report recommending investment in “onshore and offshore gas developments and manufacturing, including low emissions petrochemicals”…[92]
1.88According to media, lobbying firm Dragoman was paid around $150,000 in fees for its services under a select tender process,[93] to ‘provide deep political insight, analysis and strategic guidance in the execution of an engagement strategy to influence the Commonwealth Government to support the establishment of gas-based manufacturing in the NT’.[94]
1.89The Centre for Public Integrity used the Middle Arm Industrial Precinct as a case study in its report In Whose Interest: The case for reforming the Northern Territory Lobbying Regime.[95]
1.90The NT Government set out Dragoman’s role was to:
…understand the motivations of the government of the day and the alternative government and where those motivations might align with our vision for Middle Arm.[96]
1.91It is concerning that an overseas consulting firm was appointed, with hazy terms of reference and little public oversight, to provide advice. The circumstances under which the appointment was made should be further securitised.
1.92On a separate note, the ECNT expressed concern that Commonwealth funding for the Middle Arm precinct was provided without Infrastructure Australia oversight:
The Middle Arm Industrial Hub has been on the Infrastructure Australia priority list since February 2021. However, the Federal funding commitment for Middle Arm circumvented Infrastructure Australia’s own Assessment Framework, including the requirement for a business case prior to the funding being committed (Stage 3 of the Infrastructure Australia Assessment Framework). Extraordinarily, the funding appears to have been committed without advice at all from Infrastructure Australia. Infrastructure Australia told the Senate (page 45) that they were not involved in the funding commitment. The funding was initially committed when the project was at Stage 1 of the Infrastructure Australia Assessment Framework. The project by the Northern Territory Government recently progressed to Stage 2.[97]
1.93Likewise, DEA was concerned that the Commonwealth’s commitment of funding was provided:
…in the absence of a completed environmental or health impact assessment, a detailed business case or cost-benefit analysis, or input from Infrastructure Australia, a body expressly stablished to take the politics out of infrastructure project selection and funding.[98]
1.94The committee heard that there has been little consultation with the Larrakia community on the Middle Arm development. This is extremely disappointing from both the Northern Territory and Federal Governments.
1.95The Larrakia Reference Group explained:
It is hard for us to talk about the true depth of the cultural heritage impacts when we have been given so little information about the Middle Arm Industrial Precinct. The Northern Territory Government has not prepared culturally appropriate information to help us understand. When you go on the Middle Arm website and listen to the Northern Territory Government presentations, the project is described in a highly technical way. How is an everyday person meant to understand what is being proposed? Why are they calling it a sustainable development if there are plans to export fossil fuels? Our lack of understanding is not our consent. We deserve to have information presented to us so we can fully participate in the decisions and approvals around the Middle Arm Industrial Precinct at every stage. How can we tell you how our cultural heritage will be impacted if we do not know what is happening at Middle Arm?[99]
No one from industry has spoken to us about their plans for the Middle Arm Industrial precinct. We note that the Northern Territory Government announced the five proponents without speaking to us about it. We do not feel like we have been a part of this process. If and when they do speak with us, we would like them to provide information in plain English that is culturally appropriate.[100]
The members of the Larrakia Reference Group appreciate the opportunity to provide our perspective on the Middle Arm Industrial Precinct. As a group, we have not had a chance to have our voices heard about this project happening on our country. Governments often ask for our input about major projects but never genuinely take our advice on board. Many of us on this Reference Group would veto this project if we could. As we do not have that power, we hope that the Senators on this Committee take our concerns seriously. This is a rare opportunity for you to listen to us when we have no voice.[101]
1.96The Aboriginal Medical Services Alliance Northern Territory (AMSANT) submitted that:
The project also poses environmental and cultural risks including disruption of the only remaining Larrakia rock art in the area and potential damage to middens which are of high cultural significance. Furthermore, there has been a lack of engagement of local Aboriginal leaders /organisations in the development process to date which is extremely disappointing.[102]
There is considerable evidence of inadequate consultation with Aboriginal communities by fossil fuel companies…Consultation with Larrakia people on the current Middle Arm development has again been completely inadequate…this has resulted in the absence of free, prior and informed consent. The project should be now halted until genuine and thorough consultation has been conducted and this consultation should occur in partnership with the key Larrakia organisations. Once consultation has been conducted, the outcome should be respected.[103]
…we believe that the negative impacts from the Middle Arm project far outweigh any potential benefits to Aboriginal people across the NT and should not proceed.[104]
1.97The Australian Conservation Foundation submitted that:
Both NT and federal government planning guidelines advise early engagement with First Nations people about development proposals on their country, but senior Larrakia people say that has not happened for Middle Arm. Serious concerns have been voiced by First Nations people that Middle Arm industrial development could cause irreversible harm to cultural artefacts at Middle Arm including nearby precious rock art, as well as to stories, dreaming and rituals. Further concerns have been raised about the effects the development would have on the harbour, its marine life and traditional sites used by Larrakia people for camping and fishing. The $1.5bn commitment for common user infrastructure occurred without a cultural heritage assessment as required by Infrastructure Australia’s Assessment Framework, or consultation with the Larrakia people. Despite the establishment of a ‘cultural consultative committee’ by the NT government there is still much that needs to be done to assess impacts to cultural heritage and to receive the free prior and informed consent of First Nations people. A Larrakia-led and designed cultural heritage and cultural values assessment should be completed, endorsed by the Larrakia people, and incorporated into the Environmental Impact Statement and environmental assessment process for the Middle Arm precinct. See further recommendations on the EIS above. Commonwealth funding related to Middle Arm should be made contingent upon free, prior and informed consent of Larrakia people.[105]
1.98The Wilderness Society argued that:
The absence of genuine consultation with communities and the failure to obtain free, prior and informed consent from Traditional Custodians is evidence of integrity lapses and questionable decision making regarding this proposal. Free, prior, and informed consent is a globally endorsed standard for Indigenous lands and resources. In this case, the Larrakia Traditional Owners have unique internationally-recognized rights that should be enshrined in Australian law and practice, as set out by the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and other UN agreements.[106]
1.99Lock the Gate Alliance submitted that:
The NT government has a poor reputation for consulting with Indigenous people in relation to development approvals and this has led to a lack of trust in government and in the government’s ability to regulate the gas industry.
Middle Arm is one of the most important parts of Darwin Harbour to the Larrakia people as it contains middens, sacred sites, rock carvings, stories and rituals.
The Larrakia were not properly consulted in the early stages of Middle Arm planning.
The federal government committed $1.5 billion to the project without a cultural heritage assessment as required by Infrastructure Australia’s own assessment framework.
Samuel’s Review of the EPBC Act recommended that a National Environmental Standard for Indigenous engagement and participation in decision-making be developed. Although the Government has accepted these recommendations, neither the NT nor the Commonwealth Government have provided for this in their Strategic Assessment of Middle Arm.
In the Beetaloo Basin, consultation with indigenous communities that was to commence in 2018 was delayed until 2022, meaning that Recommendation 11.8 from the Pepper Inquiry has not been met, and the risk to Aboriginal people and culture from gas development remains unacceptable.[107]
1.100There is significant concern that the development could lead to the destruction of culturally significant sites.
1.101Senior Larrakia Elder, Mr Bill Risk OAM argued:
The Middle Arm project will clear 1,500 hectares of the Middle Arm peninsula. There is also potential for remaining areas of the peninsula, as well as the Harbour itself, to be adversely impacted by the project, because of the toxic runoffs, discharges, and pollution. This could be the most impactful development on Larrakia land that I have seen over my lifetime. Clearing this peninsula to make way for industrial expansion has the potential to irrevocably destroy Larrakia cultural values, including our tangible and intangible cultural heritage. In fact, the whole Darwin Harbour catchment, in its great ecological diversity, is vital to the continuity of Larakia culture and society and is at grave risk from this project. The pre-contact archaeological record of the Middle Arm Peninsula is exceptional on a national level; shell mounds/middens and archaeological scatters are located throughout the peninsula. Additionally, petroglyphs located there constitute the only remaining Indigenous rock art in the entire Darwin region. Darwin Harbour contains important sacred sites, primary spiritual responsibility for which rests with Larrakia custodians. In addition, there are innumerable intangible stories, dreamings, rituals, practices and ecological knowledge held by Larrakia people about Middle Arm. Assessments have previously been made of the cultural heritage values present at Middle Arm, as part of various native title and land claim processes, and in response to development applications. I have been involved in some of these reports, as a key informant and knowledge holder. These existing reports cannot be used to make decisions about Larrakia cultural heritage as part of the Middle Arm project proposal. Cultural heritage processes have typically been driven by non-Larrakia agendas and written by non-Larrakia people. As a result, they do not capture the extent of the cultural values associated with the peninsula and they cannot be used to understand what is at risk today.[108]
…I have sat back and watched as developments occur without Larrakia consultation, much less consent. I have put up with it, and tried to achieve what I can for my people from the scraps thrown from the table. However, the time has now come to draw a line in the sand. I am overwhelmed by the scale of what the NT and Australian Governments are pursuing at Middle Arm, one of the most precious places to Larrakia people. The plans for this area exceed anything that has ever been developed on Larrakia Country.[109]
1.102Larrakia Elder, Mr Eric Fejo gave similar evidence:
Make no mistake, the gas industry in Darwin has been constructed at Middle Arm on a foundation of profound distress and tragedy for Larrakia people. Our loss has been used as leverage in the service of gas company profits that has already destroyed so much and wants to destroy more. It is not just the gas industry. The so-called “renewable energy transition” is already tarnished by the brush of a new and pervasive kind of green colonialism. Only a few kilometres away from Middle Arm is a lithium mine, which has been recently touted for its agreement with Tesla to supply the raw materials for electric vehicles. Core Lithium’s mine is located in the southern part of the pristine Cox Peninsula, at the narrowest part of the peninsula, with waterways discharging into Darwin Harbour on one side, and Bynoe Harbour on the other. Core Lithium leveraged the absence of native title to their advantage, pushing through a mine without Larrakia consent. They picked off a few key people to sign a deal with them when the public pressure began to mount. This mine was revealed on Four Corners last year to be already polluting Darwin Harbour. There is unfinished business for the Larrakia people, and it must be addressed. The Middle Arm gas and petrochemical hub is the latest incarnation of the violence by the state on Larrakia people. It is no accident that it was recommended by former Labor Chief Minister Paul Henderson and is being pursued by the NT Labor Government without the consent of Larrakia people, given this history. It should not be progressed in any way shape or form, until our claims are addressed. Enough is enough. That means, first of all, a recognition of the sovereignty of Larrakia people. Second, it means a treaty with Larrakia people. Middle Arm must not proceed without the free, prior and informed consent of Larrakia people.[110]
Governments, politicians, political lobbyists, and public decision makers who have the power to make decisions about Larrakia country need to understand that Larrakia cultural heritage is grounded in the woodlands, monsoon forests, mangrove country, tidal flats, rock outcrops, the ridge country, and the underground freshwater springs. Destroying the natural environment also destroys Larrakia culture. The natural and cultural environment is not valued nor appreciated, as Middle Arm has become a site for major industrial development. It will become an industrial dump producing toxic pollutants on the doorsteps of Darwin Harbour, the city of Darwin and the town of Palmerston. The Northern Territory Government chose Middle Arm as a site for industrial development because it does not value the natural environment nor recognise Larrakia people and our identity and human rights. Areas like Middle Arm that surround Darwin Harbour play an important role in maintaining the ecology and health of the Harbour. Clearing the land and destroying the ecology of the Middle Arm not only affects the Harbour but it also has a psychological impact on us. When we see our country being destroyed by governments and development proponents, it destroys our spirit. Governments and developers who only see our estates as a commercial resource to be exploited, not a living breathing interconnected ecosystem that must be protected. We worry that our country is not valued by governments and society. The actions of the Federal and Northern Territory governments, development proponents and political lobbyists show clearly that they consider our rights to be non-existent and my culture and religion as worthless. We worry that destroying our country will eventually mean destruction of us as a people.[111]
1.103During a hearing, Ms Mary Williams, of the Larrakia Nation, raised similar concerns:
As traditional owners, custodians and descendants of the Middle Arm precinct, we express our deep concerns regarding the proposed developments in this significant area. Our connection to this land is ancient and profound. It is rooted in generations of stewardship and spiritual reverence. The Middle Arm precinct is not merely a piece of land; it's our cultural heritage and traditional identity. Our ancestors have lived, hunted and performed sacred ceremonies on this land for countless generations, leaving behind a tapestry of history and wisdom. The proposed development threatens to desecrate this sacred landscape, endangering culturally significant sites, disrupting ecological balance and eroding the spiritual essence of the land. The impacts of such actions extend far beyond the physical realm. They strike at the heart of our people and our community, undermining our cultural continuity and collective wellbeing. We implore the Senate committee to hear our voices and take decisive action to protect the Middle Arm precinct. We call for comprehensive consultation with traditional owners, custodians and descendants affected.[112]
1.104The Larrakia Reference Group told the committee that:
We know that Middle Arm is Larrakia country irrespective of the native title outcome. This feeling of loss equally applies to us even if our native title claim was unsuccessful. We have obligations to protect and care for our country and the Middle Arm Industrial Precinct is in conflict with this.[113]
1.105The proposed Middle Arm precinct is not a ‘sustainable development precinct’. It is a thinly-veiled plan to develop a petrochemical precinct. Despite recent attempts to rebrand the project, its primary function is to enable expansion of the gas industry.
1.106The proposed Middle Arm petrochemical precinct risks significant damage to the climate, the environment, cultural heritage and the health and wellbeing of residents who live nearby.
1.107The $1.5 billion of taxpayer funding committed to the project is a fossil fuel subsidy designed to enable gas export and petrochemical manufacturing. It should be withdrawn and restructured in a way that ensures it cannot be used to process or export gas. It should only be recommitted if a convincing case is made for the public value of the investment.
1.108The Middle Arm proposal is based on a significant expansion of the gas industry to export and process large quantities of gas in the precinct. Claims that the precinct is ‘sustainable’ are not credible and appear to be a cynical attempt to greenwash the proposal. The potential for CCS to offset emissions generated by projects within the precinct should be viewed with scepticism and dismissed for what they are–a smokescreen for the expansion of the gas industry.
1.109While I have remained open-minded to all perspectives, the evidence presented to this committee has overwhelmingly demonstrated that gas developments located near communities result in unacceptable health impacts to those communities, and that those impacts cannot be mitigated through effective industry regulation.
1.110Indeed, the recent reporting that the INPEX Icthys site emitted 22 times more volatile organic compounds into Darwn’s air in 2022 than it had originally planned shows already how ineffective regulations are in preventing the gas industry from releasing known carcinogens into the air.
1.111From the evidence presented to this committee, it is difficult to see how any human health impact assessment could reasonably find that the expansion of a gas development so close to a population centre will carry an acceptable risk to human health.
1.112The evidence has also shown that the NT population already carry a greater burden of chronic disease, making this population more vulnerable to the harms associated with gas operations.
1.113The only substantive response that offered any evidentiary basis, from Tamboran, amounted to a small number of selected studies that have become outdated in a rapidly evolving area of research. As stated by Professor Haswell above, Tamboran’s response to the mounting evidence of harms caused by the oil and gas industry represents an attempt to ‘[downgrade] descriptions of evidence on matters which pose barriers to the application of the precautionary principle of significant human health concerns.’[114] This same approach was deployed by the tobacco industry decades ago. Tamboran’s response shows precisely why policymakers must be sceptical of claims submitted by the fossil fuel industry on how their operations can, and do, impact the health of our communities.
1.114In line with the available evidence, I remain sincerely concerned for the health and wellbeing of those residents who will have to live alongside this new unconventional gas supply chain - from where it is fracked in the Beetaloo Basin through to where it is processed and exported at the proposed Middle Arm development. The health and wellbeing of Australian residents should be the primary concern of any government, and I urge decision-makers to seriously consider the substantial evidence in front of us and to not make any decision that would put the Darwin and Palmerston populations in harm’s way.
1.115I agree with the submissions and evidence from the environmental health experts and medical professionals that both the NT and Federal Governments must rigorously evaluate the evidence in line with the established best practice guidelines: the Environmental Health Standing Committee (enHealth) Guidelines for assessing human health risks from environmental hazards.
1.116I further agree that given the gravity of the issues being considered, that process must be as transparent as possible and must be conducted under the supervision of a public health professional.
1.117In a biodiversity crisis, we cannot afford to put threatened species at further risk. The Middle Arm proposal poses a risk to a significant number of threatened species. It is clear that the development of the project is incompatible with the government’s stated objectives for zero new extinctions and to conserve Australia’s unique biodiversity so that it can be enjoyed for generations to come.
1.118The decision to commit $1.5 billion of Australian taxpayers’ money to a petrochemical precinct without clear value for money and without a proper evaluation of the significant risks of the project high risks to the climate, the environment and the health of those living in the vicinity requires further explanation. The government must clearly articulate the reasons behind the decision and provide evidence for why it was in the public interest.
1.119There has been inadequate consultation with Larrakia Traditional Owners. The evidence given to the committee was that there is no free prior and informed consent for development of the Middle Arm precinct. This is not acceptable and the project should not proceed without consent.
Recommendation 1
1.120Any investment by the Commonwealth into the proposed development of the Middle Arm precinct should be structured in a way that prevents benefit from the investment flowing to any gas or petrochemical processing facility.
Recommendation 2
1.121Commonwealth funding for the Middle Arm precinct should not proceed until the results of the human health impact assessment, covering each operation proposed to operate at the precinct, are known.
1.122The assessment must be conducted under the supervision of a qualified public health physician and must be made available for genuine public scrutiny and critique before being accepted.
Recommendation 3
1.123The circumstances in which $1.5 billion in Commonwealth funding was committed for the Middle Arm precinct should be investigated. Any investigation should determine the role of lobbying firms, and Commonwealth and Northern Territory Government members and officials, and ascertain how the decision to spend such a significant sum of taxpayer money was made without a clear articulation of the cost and benefit.
Recommendation 4
1.124Federal Government funding commitments for the Middle Arm precinct should be withdrawn or put on hold, pending a completed environmental impact assessment and approval by Infrastructure Australia in accordance with its Assessment Framework.
Recommendation 5
1.125Free, prior and informed consent of Larrakia Traditional Owners must be obtained before any development of the Middle Arm precinct commences.
Senator David Pocock
Participating Member
Footnotes
[1]See, for example, Professor Melissa Haswell, Submission 85, pp. 1, 7−11.
[2]The Australia Institute, Australian governments suck up to Japanese fossil fuel companies. Again.
[3]Professor Melissa Haswell, Mr Jacob Hegedus, Emeritus Professor David Shearman, The risks of oil and gas development for human health and wellbeing, 2023.
[4]NT Government, Submission 24, p. 4.
[5]Parents for Climate Action, Submission 64, p. 8.
[6]Professor Melissa Haswell, Private Capacity, Submission 85, p. 5.
[7]Professor Melissa Haswell, Mr Jacob Hegedus, Emeritus Professor David Shearman, The risks of oil and gas development for human health and wellbeing, 2023, p. 54.
[8]Professor Melissa Hawel, Mr Jacob Hegedus, Emeritus Professor David Shearman, The risks of oil and gas development for human health and wellbeing, 2023, p. 64.
[9]Professor Melissa Haswell, Mr Jacob Hegedus, Emeritus Professor David Shearman, The risks of oil and gas development for human health and wellbeing, 2023, p. ii.
[10]Professor Melissa Haswell, Mr Jacob Hegedus, Emeritus Professor David Shearman, The risks of oil and gas development for human health and wellbeing, 2023, p. ii.
[11]Professor Melissa Haswell, Member, Public Health Association of Australia, Proof Committee Hansard, 11 April 2024, p. 43.
[12]Professor Melissa Haswell, answers to questions on notice from Senator Pocock, 8 August 2024 (received 15 August 2024).
[13]Amira Aker et al, The human health effects of unconventional oil and gas development (UOGD): A scoping review of epidemiologic studies, Canadian Journal of Public Health Canadian Journal of Public Health, 2024.
[14]Professor Melissa Haswell, answers to written questions on notice from Senator Thorpe, 26 April 2024 (received 16 May 2024).
[15]Professor Melissa Haswell, answers to written questions on notice from Senator Thorpe, 26 April 2024 (received 16 May 2024).
[16]Public Health Association Australia and NT Paediatricians, Submission 46.
[17]Doctors for the Environment Australia (DEA), Submission 35.
[18]Climate and Health Alliance, Submission 56.
[19]Public Health Association Australia and NT Paediatricians, Submission 46, p. 10.
[20]Environment Centre NT, Submission 198, p. 23; Royal Australian & New Zealand College of Psychiatrists, Submission 70, p. 2.
[21]Environment Centre NT, Submission 198, p. 23.
[22]Public Health Association of Australia and NT Paediatricians, Submission 46, p. 12.
[23]Ms Catherine Hatcher, Branch Secretary, Australian Nursing and Midwifery Federation NT, Proof Committee Hansard, 11 April 2024, p. 44.
[24]Ms Catherine Hatcher, Australian Nursing and Midwifery Federation NT, Proof Committee Hansard, 11 April 2024, p. 44.
[25]Dr Katherine Barraclough, Member, DEA, Proof Committee Hansard, 18 June 2024, p. 9.
[26]Dr Barraclough, DEA, Proof Committee Hansard, 18 June 2024, p. 9.
[27]Dr Barraclough, DEA, Proof Committee Hansard, 18 June 2024, p. 9.
[28]Dr Louise Woodward, Private capacity, Proof Committee Hansard, 11 April 2024, p. 46.
[29]Dr Jenny Summerville, Employee, Aboriginal Medical Services Alliance Northern Territory, Proof Committee Hansard, 11 April 2024, pp. 46–47.
[30]Environment Centre NT, Submission 198, p. 25.
[31]DEA, Submission 35, p. 5.
[32]DEA, Submission 35, p. 5.
[33]Dr Louise Woodward, Private Capacity, Submission 125, p. 1.
[34]Climate and Health Alliance, Submission 56, p. 11.
[35]Chief Minister for the Northern Territory, the Hon Eva Lawler MLA, 'Opening Statement' (Tabled 11 April 2024, Darwin).
[36]NT Government, answers to questions on notice, 11 April 2024 (received 23 May 2024).
[37]Li et al,Exposure to Unconventional Oil and Gas Development and All-cause Mortality in Medicare Beneficiaries, Nat Energy, 2022.
[38]Clark et al, Unconventional Oil and Gas Development Exposure and Risk of Childhood Acute Lymphoblastic Leukemia: A Case–Control Study in Pennsylvania, 2009–2017, Environmental Health Perspectives, 2022.
[39]Tran et al, Residential Proximity to Oil and Gas Development and Birth Outcomes in California: A Retrospective Cohort Study of 2006–2015 Births, Environmental Health Perspectives, 2020.
[40]Jephcote et al, A systematic review and meta-analysis of haematological malignancies in residents living near petrochemical facilities, Environmental Health, 2020.
[41]Tamboran Resources, answers to questions on notice, 17 June 2024 (received 17 July 2024), p. 3.
[42]Tamboran Resources, answers to questions on notice, 17 June 2024 (received 17 July 2024), p. 3.
[43]Tamboran Resources, answers to questions on notice, 17 June 2024 (received 17 July 2024), p. 4.
[44]Professor Melissa Haswell, answers to questions on notice from Senator D. Pocock, 8 August 2024 (received 15 August 2024).
[45]NT Government, answers to questions on notice, 11 April 2024.
[46]NT Government, answers to questions on notice, 11 April 2024.
[47]Ms Louise McCormick, NT Infrastructure Commissioner, Proof Committee Hansard, 11 April 2024, p. 14.
[48]The Hon Eva Lawler MLA, Chief Minister, Northern Territory Government, Proof Committee Hansard, 11 April 2024, p. 12.
[49]The Hon Eva Lawler MLA, Chief Minister, Northern Territory Government, Proof Committee Hansard, 11 April 2024, p. 9.
[50]Jano Gibson, ‘NT government deletes references to 'petrochemicals' from Middle Arm website, rejects 'greenwashing' claims’, ABC, 26 November 2023.
[51]Infrastructure Australia, FOI 23-066 Document, p. 10.
[52]Environment Centre NT, Submission 198, p. 5.
[53]Environment Centre NT, Submission 198, p. 6.
[54]Environment Centre NT, Submission 198, p. 8.
[55]Environment Centre NT, Submission 198, p. 14. This was also noted by the Australian Conservation Foundation, Submission 30, p. 1 and Beyond Gas Network, Submission 27, p. 2.
[56]Vets for Climate Action, Submission 55, p. 2.
[57]Parents for Climate Darwin, Submission 199, p. 7.
[58]NT Government, Submission 24, p. 12.
[59]Environment Centre NT, Submission 198, p. 3; Australian Conservation Foundation, Submission 30, p. 14.
[60]Center for International Environmental Law, Submission 71, p. 3.
[61]Center for International Environmental Law, Submission 71, p. 3.
[62]Center for International Environmental Law, Submission 71, pp. 3 and 4.
[63]See for example: DEA, Submission 35, p. 12; Lock the Gate Alliance, Submission 51, pp. 11 and 12; Institute for Energy Economics and Financial Analysis, Supplementary Submission 45.1, p. 2.
[64]Australian Marine Sciences Association, Submission 1, Attachment 1, p. 6.
[65]Center for International Environmental Law, Submission 71, p. 4.
[66]Center for International Environmental Law, Submission 71, p. 16.
[67]Australian Conservation Foundation, Submission 30, p. 14.
[68]The Wilderness Society, Submission 9, p. 1.
[69]Environment Centre NT, Submission 198, p. 20.
[70]Environment Centre NT, Submission 198, p. 20.
[71]Australian Conservation Foundation, Submission 30, p. 7.
[72]Environment Centre NT, Submission 198, p. 20.
[73]DEA, Submission 35, p. 7.
[74]Environment Centre NT, Submission 198, p. 20.
[75]Climate Analytics, Submission 11, p. 2.
[76]Climate Analytics, Submission 11, p. 2.
[77]Climate Analytics, Submission 11 Attachment 1, p. 52 (emphasis added).
[78]Australian Conservation Foundation, Submission 30, p. 2.
[79]Environmental Defenders Office, Submission 33, p. 3.
[80]Peoples Climate Assembly, Submission 6, p. 1.
[81]Australian Conservation Foundation, Submission 30, p. 11.
[82]Environment Centre NT, Submission 198, p. 34. The four migratory species are the Grey-tailed Tattler, Terek Sandpiper, Whimbrel and Far Eastern Curlew, all of which are listed as migratory species under the EPBC Act,SPRAT EPBC Migratory List.
[83]NT Government, Sites of conservation significance: Darwin Harbour.
[84]DCCEEW, Protected Matters Search Tool.
[85]Public Health Association of Australia and NT Paediatricians, Submission 46, p. 9.
[86]Environment Centre NT, Submission 198, p. 33.
[87]Australian Conservation Foundation, Submission 30, p. 15.
[88]Environment Centre NT, Submission 198, p. 15.
[89]Environment Centre NT, Submission 198, p. 15.
[90]Environment Centre NT, Submission 198, p. 16.
[91]Environment Centre NT, Submission 198, p. 16.
[92]Environment Centre NT, Submission 198, p. 6.
[93]Anne Davies and Lisa Cox, 'Revealed: documents detail key players behind vast Australian fossil fuel expansion’, The Guardian, 19 June 2023.
[94]Jano Gibson, ‘NT government enlisted lobbying firm Dragoman to push for federal funding for Middle Arm precinct’, ABC, 20 June 2023.
[95]Centre for Public Integrity, In Whose Interest: The case for reforming the Northern Territory Lobbying Regime (tabled by Lock the Gate Alliance 11 April 2024).
[96]Mr Alister Trier, Chair of the Gas Taskforce, NT Department of Chief Minister and Cabinet, Proof Committee Hansard, 11 April 2024, p. 11.
[97]Environment Centre NT, Submission 198, p. 13.
[98]DEA, Submission 35, p. 15.
[99]Larrakia Reference Group, Submission 194, p. 1.
[100]Larrakia Reference Group, Submission 194, p. 4.
[101]Larrakia Reference Group, Submission 194, pp. 5 and 6.
[102]AMSANT, Submission 12, p. 2.
[103]AMSANT, Submission 12, p. 5.
[104]AMSANT, Submission 12, p. 3.
[105]Australian Conservation Foundation, Submission 30, p. 17.
[106]The Wilderness Society, Submission 9, p. 2.
[107]Lock the Gate Alliance, Submission 51, p. 4.
[108]Mr Bill Risk OAM, Submission 193, p. 3.
[109]Mr Bill Risk OAM, Submission 193, p. 2.
[110]Mr Eric Fejo, Submission 112, p. 4.
[111]Mr Eric Fejo, Submission 112, p. 7.
[112]Ms Williams, Private capacity, Proof Committee Hansard, 10 April 2024, pp. 1–2.
[113]Larrakia Reference Group, Submission 194, p. 3.
[114]Professor Melissa Haswell, answers to questions on notice from Senator D. Pocock, 8 August 2024 (received 15 August 2024).
An inquiry into the Middle Arm Industrial Precinct.
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