John Englart

Submission to WA EPA: Woodside’s Browse Gas drilling at Scott Reef

The Western Australian EPA has re-opened consultation on Woodside’s Browse Gas project. The successful Extension of Woodside North West Shelf depends upon Browse Gas project approval at both State and Federal levels.

At the State level, the consultation by the EPA has been reopened till June 10.

You can write your own submission, or you can add your name to existing group submissions:

The latest proposed amendment by Woodside Energy, according to the WA EPA, “includes a reduction in development envelope size to no longer overlap the Scott Reef shallow water benthic habitats or Sandy Islet, modifications to remove or relocate drilling units to avoid green turtle habitats, and the adoption of technology to minimise the risk of a loss-of-well control event.”

Potential Impacts of the Browse to NWS Project

This project provides threats to Scott Reef’s unique ecosystems. The project proposes the installation of gas wells, floating production storage and offloading (FPSO) vessels, subsea infrastructure, and a 900 km pipeline. Multiple risks include:

Pollution from Industrial activity. This includes Vessel discharges, drilling activities, and the release of produced water containing contaminants like mercury which could degrade water quality. Underwater noise from drilling, vessel movements, and other industrial activities could disrupt migratory marine mammals. Light pollution from flaring and operational lighting may disorient sea turtles and migratory seabirds. We note this amendment proposes moving TRD drilling centre further east to reduce impact on Green turtles, and also to restrict flaring to daylight hours to reduce potential migratory disturbance.

Habitat Disturbance: The construction and operation of subsea infrastructure, such as mooring lines, pipelines, and anchors, will disturb the seabed, potentially damaging benthic habitats. Drilling infrastructure will be restricted to locations deeper than 75 m water depth. There has been little research into biodiversity of these habitats at these depths and how construction may impact species. Sensitive species could be smothered by increased sedimentation.

Scott Reef is isolated. Genetic isolation of its corals and other marine organisms, rely on local spawning events. Industrial impacts on habitat can impact reef organism reproduction and replenishment. Increased turbidity, incidental industrial pollution, or an oil spill, may threaten ongoing viability of isolated self-sustaining marine populations, as well as when combined with the impacts of climate change indirectly attributable to fossil fuel extraction.

Subsidence. Extracting gas underneath Scott Reef is likely to lead to geological subsidence, which, when combined with the impacts of climate change of rising sea levels and increasing acidification, accelerate the decline of coral reef ecosystems. There has been little research on the ecosystem impacts and long-term effects in this region.

Oil Spill Risk. While Woodside have advanced an increased technological response to reduce oil spill risk, which is part of this amendment, the fact remains that ANY oil spill in this pristine ecosystem and biodiversity hotspot would be an ecological disaster. Impacts would be difficult to monitor and manage. Even for small oil spill, residues would likely persist in the environment for decades, bioaccumulating into food webs and into apex predators like demersal fish, sharks and marine mammals. It would also likely have catastrophic impacts for sensitive coral species and reef ecosystem.

Species and Ecological communities under threat

  • The Sahul Shelf reefs, and Scott Reef in particular, are considered biodiversity hotspots, including a range of important pelagic and benthic ecological communities and habitats.
  • approximately 1500 species of invertebrate have been recorded at Scott Reef, including 305 hard corals, ~200 soft corals, 96 sponges, 372 macro molluscs, 125 echinoderms and 388 crustaceans. Despite the high biodiversity of invertebrates known at Scott Reef, there is a severe lack in survey effort, for many groups only one or two surveys have been conducted, highlighting that the biodiversity known is likely to be an underestimate. Scott Reef could be a speciation hotspot for corals, due to the unique spawning biology and isolation of the reef.
  • A number of conservation significant fish fauna are present or are likely to be, including the IUCN listed critically endangered Southern bluefin tuna, vulnerable oceanic sunfish and endangered humphead maori wrasse. 31 species of EPBC act protected Sygnathids (bony ringed fish) are likely to occur at Scott Reef, including 2 IUCN listed vulnerable species, however only eight Sygnathids have been recorded at Scott Reef likely due to a paucity of studies.
  • Whale sharks migrating from Australia to Indonesia every year have been tracked passing the eastern perimeter of South Scott Reef. Great White, Tiger, Northern River, Hammerhead, Mako and other Reef Sharks are known or are likely to occur within or around the Scott Reef complex.
  • North-West Australia is one of the last remaining regions with viable sawfish populations, two species of which are known to occur at Scott Reef.
  • Several species of rays are known or are likely to occur at Scott Reef including manta, eagle and devil rays.
  • There are 9 species of reef dwelling sea snake species are found at Scott Reef with a further 11 whose habitat likely to occur here and 3 more than the Proponent has listed, all of which are listed Marine species under the EPBC Act. Of this, the Dusky sea snake is listed as endangered; the Short-nosed and leaf – scaled sea snake is listed as Critically Endangered under both the EPBC Act and the IUCN Red List. A further 2 are listed as data deficient. The dusky sea snake, Aipysurus fuscus, has not been seen anywhere other than the Scott Reef Complex since 2002 and has been listed as endangered under the EPBC Act.
  • Green turtles are an Endangered species under both the IUCN Red List and EPBC Act. They are highly migratory and frequent a range of different habitats and localities across the durations of their lifespans. The green turtles nesting at Sandy Islet at Scott Reef and Browse Island comprise a relatively small, but nevertheless unique, genetic stock. The hawksbill turtle is considered a Critically Endangered species by the IUCN (IUCN 2020). It has experienced significant and extensive population declines in all major oceans due to overexploitation, degradation of marine and nesting habitats and fisheries related mortalities. It is known to nest on Sandy Islet. Several other turtles with varied conservation status are known to be migratory through the area of Scott Reef.
  • At least twenty-nine species of marine mammal occur or are likely to occur near Scott Reef, including two Endangered, three Vulnerable, one Near Threatened and several Data Deficient species. This included : Pygmy blue whale, Bryde’s whale, Humpback whale, Dwarf Minke Whale, Minke Whale, striped and Australian humpback dolphins, rough-toothed, fin whales, sei whales, pilot whales, killer whales, melon-headed whales, sperm whales. Dugongs have also been recorded in proximity to Scott Reef. Mixed species feeding aggregations are not uncommon in the region, with upwelling areas in particular that found at Scott Reef providing sources of food for species migrating through the area.
  • The reef supports 31 seabird species, including the endangered Hutton’s Shearwater and the vulnerable Matsudaira’s Storm-petrel. Critically endangered species, such as the Curlew Sandpiper, Eastern Curlew, and Red Knot, may potentially occur at Scott Reef. This underscores the importance of Scott Reef as a potential conservation priority under the EPBC Act. Sandy Islet, within Scott Reef, is a key breeding and roosting ground for species like Abbott’s Booby, Brown Boobies, and Common Noddies. The region is considered important for various life history stages, including breeding and foraging, for several EPBC Act-listed seabird species, such as the Brown Booby (Sula leucogaster), Common Noddy (Anous stolidus), Lesser Frigatebird (Fregata ariel), Wedge-tailed Shearwater (Ardenna pacifica), and Roseate Tern (Sternula dougallii)

5 reasons to reject Woodside’s disastrous plans

  1. Scott Reef is one of Australia’s most amazing – and untouched – underwater wonders. It’s home to hundreds of species, including fish, sea snakes, sharks, rays and sawfish. It’s also a vital habitat for protected species, including endangered pygmy blue whales and green sea turtles. It is a unique marine biodiversity hotspot. It nurtures over 1,500 species of invertebrates, nearly 900 species of fish, and multiple species of sharks, rays, and turtles. And more species are likely to still be discovered, especially in the deeper benthic environments where the Gas drilling rigs will be located. There is a lack of research on these deeper benthic environments and their relationship to the shallower environments.
  2. The WA EPA has found in its preliminary advice that Woodside cannot manage the profound risks to Scott reef and its marine life. Woodside will be pressuring the EPA and governments to approve its outrageous proposal but the EPA’s role in protecting the natural environment must be respected.  
  3. Woodside wants to drill up to 50 gas wells around Scott Reef. Some of the wells would be just over 2km from the reef itself. It wants to pump the gas to shore through a 900km long pipeline, running through two marine parks and straight past the Rowley Shoals, another of WA’s spectacular coral reefs.
  4. Woodside’s safety record has been described by unions as ‘diabolical’. If something went wrong, a well blowout could devastate Scott Reef – and the pollution could spread for hundreds of kilometres. Woodside argue a hydrocarbon leak is only a theoretical risk, yet these spills happen all to regularly. For example on 26 May 2025 it was reported that Woodside spills 16,000 litres of oil into ocean north of Ningaloo Reef. In previous project proposal the ‘worst case credible’ scenario for a hydrocarbon spill arising from Torosa drilling activities could result in a 77 day loss of containment event, releasing up to 142,154 m3 of condensate. Woodside in this amendment is proposing the provision pyrotechnic shear ram technology that might reduce duration of a blowout to 12 hours, resulting in release of up to 887 m3 of condensate. The company that thinks a damaging oil spill from its planned drilling near Scott Reef is “only a mere theoretical possibility” just weeks ago accidentally released a cocktail of hydrocarbons, chemicals and water into the Indian Ocean. 
  5. The gas Woodside wants to exploit is a dangerous fossil fuel that would be a climate bomb, adding between 4 and 6.1 billion tonnes of emissions to the atmosphere – causing more deadly storms, floods, bushfires and heatwaves. Energy experts from the International Energy Agency, and climate scientists, have been saying since 2021 we do not need any more new gas projects to meet the Paris Climate Targets.
Test drilling at Scott Reef in 2008. Photo: Woodside

Deeper discussion

Oceanwise Australia have published 1 November 2024: Scott Reef. Review of Environmental Values and proposed Browse to North West Shelf Project Environmental Impact Statement/Environmental Review Document.

In the Discussion section of this document the authors highlights:

“The proposed Browse to NWS project would add approximately 1,602 MtCO2e over 31 years, exacerbating climate change impacts while also introducing additional threats to this vulnerable system. The wells and vessel based infrastructure will be located varying distances away from scott reef but extract gas from below it and will introduce a number of impacts associated with the construction and operation of the facilities. It will contribute amongst other impacts:

  • Pollution including vessel discharges, such as treated sewage, putrescible waste, sullage and desalination brine;
  • Disturbance of the seabed with installation of anchors, mooring lines, umbilicals, flowlines, manifolds within the well field and Installation of 900 km long pipeline in deeper continental rise waters
  • Underwater noise during drilling of up to 24 wells, potential piling, vessel dynamic positioning, valve release at each well,
  • Drill cuttings and fluids increasing turbidity and sedimentation in the water column,
  • Impacts from routine operations throughout lifetime including; release of production water containing contaminants such as mercury; release of control fluids at wellheads containing contaminants; light emission from flaring, vessels and infrastructure; noise from facilities, vessel traffic and helicopter flights;
  • Operations of the FPSO include emissions from storage, CO2 and production water removal, compressing and transmitting along the pipeline to Karratha.
  • Gas reservoir subsidence contributing potentially adverse effects on benthic habitats and critical turtle nesting habitat.
  • Risk of oil spill which would be catastrophic to the Scott Reef environment.

“In many instances the cumulative effects of these impacts in addition to current pressures are poorly understood. And; while the impact of light on wildlife is well understood in some locations; because information on the spatial and temporal habitat use for many species that inhabit Scott Reef and surrounds is sparse, assessment of risks here are difficult.”

The last paragraph of the Executive summary invokes that the precautionary principle should be applied to the Browse to NWS project:

Multiple likely and potential impacts are understood and are known to pose unacceptable risks to the Scott Reef ecosystem and the broader marine environment. Without more thorough baseline research, particularly in deeper habitats and on migratory species, it is challenging to make confident predictions about the risk of long-term impacts of the project on Scott Reef particularly in the context of cumulative impacts. The findings of this report underscore the environmental significance of Scott Reef; the adverse nature of risks posed by the Browse to NWS project; the need for further research before any large scale industrial activity is considered; and the need for comprehensive environmental monitoring to protect Scott Reef from the compounding threats of climate change and industrial development. For these reasons we conclude the information is not adequate to assess the risks. Given the known threats and significant knowledge gaps, the precautionary principle should be applied. Approving this project risks irreversible harm to one of Australia’s most unique marine ecosystems, contravening our global obligations to conserve biodiversity and reducing our climate change emissions.

Submission by Climate Action Merribek

Executive Summary

We note Woodside Energy changes to the development proposal with a reducing development area, modifications to remove or relocate drilling units to avoid green turtle habitats, minimise flaring to daylight hours, and the adoption of technology to minimise the risk of a loss-of-well control event.

Climate Action Merribek objects to the Browse to North West Shelf Development on several grounds including:

The development will add industrial pollution to a relatively pristine environment and ecosystems. This includes incidental chemical pollution from ships and drilling platforms, light pollution, and sound pollution. While the amendments include upgraded technology to prevent spill accidents, there still remains a risk of accident, and in the event of an accident could be catastrophic to the marine environment.

We note Scott Reef and the waters around provide a habitat which is a unique biodiversity hot spot with many species, some of whom are listed as vulnerable or threatened with extinction. Some of these species such as some of the whales and turtles are migratory and are likely to be impacted by even industrial infrastructure in the vicinity.

We note that extracting gas from the Browse Gas basin is likely to cause subsidence. This combined with climate change driven sea level rise poses an existential threat to the habitat on Sandy Islet of all species that rely on this island, and especially species such as the Green turtle that nest on the island. Subsidence under the reefs will also impact coral reef ecosystems that rely on light penetrating from the surface.

We note that opening a new Gas field such as Browse is not consistent with climate science targets of the Paris Agreement and Australia’s commitment at COP28 to transition away from fossil fuels. The science clearly says no new fossil gas projects are needed to meet the Paris Climate Targets.

2025-05-09-WA-EPA-Submission_ Browse to NWS DevelopmentDownload

References

Oceanwise Australia, 1 November 2024: Scott Reef. Review of Environmental Values and proposed Browse to North West Shelf Project Environmental Impact Statement/
Environmental Review Document https://assets.nationbuilder.com/ccwa/pages/16127/attachments/original/1736391111/Scott_Reef_Update_2024_Oceanwise.pdf

ABC News Explainer: Woodside’s proposed changes to Browse gas development explained as public consultation opens

WA EPA reopens submissions to 10 June on Woodside’s $30 billion Browse gas export project.

Related: see our submission in January on Carbon capture and storage associated with Browse Gas project.

Leave a comment