Port Kembla Gas Terminal

To the DP&E,

I write in support of the proposed Port Kembla Gas Terminal. There is
an overwhelming and compelling need for new and substantial gas
supplies for the NSW energy market. It can be assumed that increased
gas supply into NSW should ease price pressures for all consumers,
both private and business alike. Environmental protection as well as
consumer benefits should be equal considerations during Determination.
This project also provides excellent industry diversification within
the port precinct and also for those local businesses who could
support the terminal throughout its life.

In addition, a proposed Port Kembla fuel storage terminal approved in
2015 (SSD 15_7264) has similar features and environmental protection
measures as the gas terminal, hence there is an analogous precedent
than can be used as part of Determination.
Thank you

I am pleased to make a submission in support of the proposed Port
Kembla Gas Terminal, pending a positive assessment of the
Environmental Impact Statement by the NSW Government.

Since the proposal was announced Australian Industrial Energy (AIE)
have shown a strong commitment to stakeholder engagement, ensuring
that local community, business and interest groups are well informed
about the project and the approval process. I am unaware of any major
community concerns about the proposed gas terminal and I believe this
reflects the quality of the engagement undertaken by AIE.

I note that the proposal at Port Kembla is to link gas into the
existing gas transmission infrastructure for distribution. Myself, and
many in the Wollongong community, would not support gas being trucked
through the City. I believe this is another reason the project has not
attracted opposition and has support.

The Port Kembla Gas Terminal has the potential to boost our local
manufacturing and heavy industry by creating competition in the energy
supply chain and putting downward pressure on energy costs for local
businesses. This is likely to strengthen existing businesses and
encourage others to establish operations near Port Kembla to access
cheaper energy and the other competitive advantages which the area
offers.

Port Kembla is an important international gateway and an economic
driver for the Illawarra region. The establishment of a gas terminal
could greatly enhance the activities of the port and provide
significant economic benefit to the region. I commend AIE for pursuing
this project and for their excellent work in engaging key stakeholders
during the approval process.

Lord Mayor
Cr Gordon Bradbery AM
Wollongong City Council

As both the Deputy Premier and the Minister for Planning have declared
the Port Kembla Gas Terminal as "Critical State Significant
Infrastructure" and it is likely to be determined as a Major Hazard
Facility, it is proposed that the following be included as a
'Condition of Consent':

"Prior to completion of the detailed design of the facility, the
proponent must consult with the Terrorism Protection Unit and the
Major Hazard Facilities Unit of the Counter Terrorism and Special
Tactics Command with the NSW Police Force in relation to the ongoing
security of the facility. The proponent must ensure that regard is
taken of any advice received from the Terrorism Protection Unit and
the Major Hazard Facilities Unit of the Counter Terrorism and Special
Tactics Command with the NSW Police Force as part of the `Condition of
Consent' issued by the NSW Department of Planning and Environment."

I object to the proposal for a gas hub at the Port Kembla port for the
following reasons.

1. The piping up to Port Kembla and shipping out of gas is not good
for either the environment or climate change. It is inconceivable that
such massive transporting of energy around states and the world is
necessary. Surely there are other non-destructive ways to solve
supposed energy problems rather than such a mad and radical idea. Why
not use a mad and radical idea to bring the supposed needed energy to
NSW via renewable channels which would cost less and create more
direct and indirect jobs within NSW.

2. I grew up here in the Illawarra. I have seen the shape and size of
Port Kembla change in all ways. I grew up used to the view of large
ships waiting in queue to load up at the port. Wollongong has overcome
the reputation of being a rough and dirty and polluted place dominated
by the steel industry. Multiculturalism and the University are now
equal partners in providing Wollongong with a unique and different
character and a place where tourists will find not only a beautiful
environment but interesting events to experience. We don't want more
big ships here. We don't want more industry here. Where are the
advantages for the fast growing population who live here and intend
staying and settling here. I don't mean jobs. There will always be
ways of expanding the economy. I mean as an attractive place to bring
your family and grow your children. This whole plan seems such a crazy
way to expand the energy sector and its so destructive.............to
the well being of the living environment and also to the visual beauty
of the area.

3. Who benefits in the long term........not the people from
Wollongong. Once the Port has been expanded and the infrastructure has
been completed, the jobs on hand will dwindle.

From a long long term resident who loves and is connected to this
area......this development plan should not go ahead.

NSW Department of Planning and Environment
14 December 2018
SUBMISSION: PORT KEMBLA GAS TERMINAL
Julie Marlow
Berkeley 2506
Thank you for the opportunity to make comment on Australian Industrial
Energy's proposed project to establish a natural liquid gas import
terminal at Port Kembla. I object to this proposal.
Introduction
This is a large and complicated project involving four components, as
listed in the EIS Executive Summary: LNG carrier vessels (about 2
shipments monthly for life of the project, sourced worldwide);
Floating Storage and Re-gasification Unit (FSRU); berth and wharf
facilities; and about 6.3 km of new gas pipeline connecting the
terminal to the Jemena gas transfer station at Cringila. An idea of
the project's local scope is given in the proposal's Capital
Investment Value Report Section 2:
- demolish and dispose of the existing berth 101, disconnect services,
remove all furniture, decommission wharf, remove and dispose of deck,
piles and fenders;
- dredge the berth 101 area and dispose of the dredged material to
construct the new berth 101 and wharf facilities;
- excavate and dispose of the excavated material to construct the new
berth 101 and wharf facilities (dredged and excavated material is
estimated to total about 720,000 cubic metres);
- construct revetments including the supply and placement of rock
armour, gravel drainage layer and engineering fill;
- construct quay wall including the supply and installation of piles,
tie back rods and also cast capping beam;
- construct the new berth 101 and wharf including backfilling,
compacting and constructing the pavements;
- supply and install mooring facilities including mooring dolphins,
fenders, quick-release hooks, and miscellaneous items;
- supply and install jetty facilities including HP gas transfer
system, hydraulic power unit, gangway with access tower, nitrogen
package, pig launcher, natural gas odorant injection facilities,
diesel oil, fire water, instrument and utility air;
- supply and install onshore high-pressure gas receiving facilities at
Jemena Pipeline;
- construct a DN450 carbon steel high pressure pipeline about 6.1km in
length ... ;
- commission the gas import terminal including onshore receiving
facilities and pipeline.
This is also an expensive project. The cost is estimated at AUS$0.25
billion. As with most complex undertakings, there is likely to be a
blow-out in costs.
The project will be responsible for supporting, if not increasing, gas
production, transport and consumption and the concomitant resource
loss and pollution this entails. Locally, construction of the terminal
will further disturb an already highly disturbed environment. About
720, 000 cubic metres of material will be dredged or excavated from
harbour floors, mobilising heavily contaminated sediments. Acid
Sulphate Soils are likely to be exposed. In the Outer Harbour alone,
16.5 hectares of benthic habitat and associated benthic communities
will be lost (to be offset by new infrastructure providing opportunity
for colonisation by biofouling communities: Is this good environmental
marine management?)
Water quality will decline, at least in the short term. EIS authors
are relying on the presence of species evolved over the decades of
industrialisation to cope with turbidity and suspended solids,
although no such species have been identified in the document. Blooms
of a toxic dinoflagellate fatal to some fish are a possible result of
sediment disturbance. Once operations commence, cold water and some
residual clhorine will be released from the FSRU, with the potential
to adversely affect nearby marine life. Construction noise levels may
be loud enough to cause hearing loss in susceptible fauna. In the
Marine Ecology document (Appendix G), an impressive number of fauna
species listed as of national significance or threatened under
relevant legislation were identified in the vicinity of the project:
69 threatedned species; 56 migratory species; 83 other marine species;
12 whales and other cetaceans. The well-being of these animals are at
various levels of risk from this proposal.
Once operational, the project poses the hazards, identified in the
EIS, of "loss of containment of liquid natural gas from carriers or
FSRU or loss of LNG from FSRU, gas pipeline or connecting unloading
arms and pipes at the berth and wharf facilities; ... [gas]
propagation risk to and from adjacent industrial sites ...; and ...
collision of LNG carrier and another vessel." As claimed in the EIS,
these may not be `probable' risks, but they exist, and if control of
these hazards fail, the consequences would be extreme.
The terminal, expected to be operational by 2020, has an estimated
life of only 10 to 15 years (at a public consultation session
conducted by AIE staff, the local community was advised that it the
terminal life may be as short as 5 years). I have included the above
far-from-exhaustive lists of risk to give background to the following
question: Given the degree of risk, the cost in resources, inevitable
pollution and local disruption, as well as actual dollars, is the
project justifiable?
Not needed, not justified
My primary objection to the proposal relates to the Secretary's
Environmental Assessment Requirements , in particular the requirement
that the proposal is justified "as opposed to other alternatives". In
the EIS, it is stated that the project will introduce `a new industry
to NSW'. It may be `new' for NSW but it must be emphasised that it is
an arm of the worldwide fossil-fuel industry which on all
grounds--social, economic, environmental--is redundant. Expansions of
this industry to NSW is unnecessary. Study after study has shown that
the world, including Australia and NSW, can step-by-step and with
relatively little pain overcome its dependence on fossil fuels. We do
not need this project with all its complexity, guesstimates, high
resource use, risks, hazards and pollution.
Production, transport and use of gas, whether conventional or
unconventional, contributes to the carbon emissions that are posing
what is widely considered by climate experts to be the highest and
most urgent risk facing humans and our planet -a global temperature
increase of 1.5 degrees centigrade or more . Recent US research
(Nature energy 2 939-945 [2017]
https://www.carbonbrief.org/solar-wind-nuclear-amazingly-low-carbon-footprints)
found the emissions life-cycle footprint of gas (with carbon capture
and storage) is 78gCO2e/kWh compared to 4g for wind and 6g for solar.
To be justified, the proposal t must show that it in no way delays the
replacement of human dependence on fossil-energy with renewable
sources of energy.
In the EIS, the project claims justification on economic bases: "In
recent years, gas supplies to Australia's east coast market have
tightened, resulting in increased prices for both industrial and
domestic users.". EIS authors appeal to predictions made by AEMO and
EnergyQuest. These predictions are hotly contested. For example,
serious doubt about uses made of AEMO's report has been raised by Tim
Forcey and Dylan McConnell of the Australian-German Climate and Energy
College (Uni of Melb) in their May2017 `A short-lived gas shortfall.
Review of AEMO's warning of gas supply `shortfalls'. The researchers
found a shortage of `cheap' gas but no gas shortage. "Our research
finds that although a "gas-price crisis" exists in eastern Australia,
a gas supply shortfall is very unlikely." http://apo.org.au/node/90356
Forcey and McConnell found that the size of AEMO's forcast shortfall
amounts to no more than around 0.2% of annual supply of either gas or
electricity. Why does NSW need a project whose proponents boast will
provide an annual supply of 100 petajoules of gas per year which
represents >70% of the State's gas needs? AEMO itself has in the past
recommended that an annual diversion of 0.3% of Australian export gas
would close the domestic supply gap. It is also relevant to note that
at least 4 gas import terminals are planned for Australia's east
coast.
EIS authors also boast that the project will introduce a new source of
competitively priced gas, helping to put downward pressure on prices.
This is a claim that is not, and probably cannot be, justified: the
opacity of the gas industry and volatility of its markets makes such
predictions very unreliable. What is more likely is that the
importation of globally-sourced gas into NSW will delay the deployment
of cleaner, cheaper renewable energy projects.
Further, as commentators have pointed out, AIE, to make its investment
worthwhile, will have to "... sell the gas for a price above the cost
of buying the gas, transporting it to Australia and making a return on
the infrastructure required to get it into the Australian gas market"
https://rogermontgomery.com/will-new-lng-import-terminals-cut-the-price-of-gas/
AIE claim that their project is `transitional', helping to fill the
gap until renewables are more widely available and able to provide
base load. However, this `gap' can no longer be used as justification.
Arguably, there is no gap. Forcey and McConnell note "Gas has often
been characterised as a `transition fuel' on the pathway to a
zero-emissions power system. The falling costs of renewable energy and
storage technologies, the increasing gas cost and climate change
objective suggest this transition is no longer necessary, and indeed a
detour". The Port Kembla Gas Terminal is such a detour.
For me as a Wollongong resident, a particularly irksome aspect of this
project is the opportunity cost it represents for my home town. An
injection of $250 million dollars in local renewable energy projects
would form the basis for a thriving local industry - an industry with
a strong economic future, secure clean jobs, and one that would be
supportive of exciting research and development work in renewable at
the local university. To meet SEARS, this proposal must consider what
could be achieved if AIE were to put equivalent effort and cost into a
renewable energy scheme. After all, we only have to look for
inspiration as far as Whyalla, where a $700 million solar, battery and
pumped hydro project is planned to power the local steel works.

Thankyou for the opportunity to comment on the AIE Regasification Plant
proposal for Port Kembla.

I would like you to note that the length of the public exhibition time
is inadequate for this proposal which requires a great deal of time to
read the proponents documents let alone for the research necessary to
understand the footprint and the potential risks that could come with
construction & operation of a regasification plant at Port Kembla. I
also feel there has been no proper consideration that this exhibition
has coincided with the pre Christmas time when most of us in the
community are extremely busy. I can only express my frustration that
because of that lack of time I am unable to comment more
comprehensively.

1/ However my major concern is that this enterprise is blatantly
unsustainable given that we are at a time when the earth is faced with
catastrophic climate change. It is just weeks since the International
Panel on Climate Change released their most comprehensive & alarming
report. Given its message that fossil fuels must be phased out by 2050
if we are to have any chance of protecting the climate for future
generations it is decidedly not the time for any government to approve
a project that will burn an unknown amount of fossil fuel in just
shipping the gas from anywhere in the world, & then liquefying &
regasing perhaps an unknown number of times. All of this producing
unnecessary greenhouse gases released to the atmosphere additional to
that released when the gas is used for its original intended purpose -
manufacturing, heating, cooking etc.

2/ My second concern is the dredging of Berth 101 at Port Kembla,
which appears to be necessarily deep, will disturb old industrial
toxins in the sediments & the disposal of the dredge spoils to the
Outer Harbour will impact the surrounding coastal area & Lake
Illawarra which is now permanently open to the sea. I have noted no
proper caution in this proposal.

3/ My third concern I'm am unconvinced that there will not be
significant fugitive emissions from this project that will impact the
immediate Port Kembla area & residents' health as well as adding to
greenhouse gas emissions.

4/ Fourthly it is worth noting that the Australian Energy Market
Operator has been clearly called out on their prediction of the cause
of Australian domestic gas price rise. Australia does not have a
domestic shortage of gas. Successive governments & regulators
knew/were advised for some years before Australia had operational gas
export facilities that the price of gas would triple to match
international prices if there was not a domestic reserve allocated at
time of start of export. Like all fossil fuels & minerals, gas is a
national resource owned by Australians however our governments have
chosen to sell out our Australian gas to a cartel of gas companies
that not only have been given the go ahead to sell it back to us at
outrageously inflated rates but continue to demand more gas fields
threatening our water, food production & natural areas. Similarly if
the Port Kembla Regasification plant is approved AIE will be given
governmental approval to increase the threat to a liveable climate for
our kids & the generations after.

I do not support AIE's proposal and urge an assessment of its long
term environmental/climate sustainability. It is time for progressive
projects that preserve our environment and the liveability of Port
Kembla, Wollongong and the state of NSW.
Yours sincerely Annie Marlow

I have a few concerns, regarding the proposed Pt Kembla gas Terminal.
1) To consider importing gas 'from around the world' I find quite
bewildering. And also could this include shale gas or other
unconventional gas? I am aware that unconventional gas mining has
caused problems in some communities (including Australia) and would
not like to think that we were buying in gas from anywhere that has
been adversely affected. How will we know where the gas is coming from
and how far it has travelled to reach our port? Why are we not able to
reserve supplies of Australian conventional gas in the short term, to
satisfy the eastern states until other renewable sources of energy can
fulfill the needs?
2) However, should this project go ahead, would it then be possible to
not go ahead with Santos' Pilliga project, to which there is a lot of
opposition?
3) The dredging to make the extra beirth at the port raises some
worries. The soil would be heavily contaminated and dumping it in the
outer port or elsewhere could be risky. I doubt it is possible to
guarantee there will be no problems in the dumping areas and no
spillages along the way. Also could there be potential risks to Lake
Illawarra?
Can it be guaranteed that the change in temperature of the water being
taken from the harbour and then recirculated will have no adverse
affects?
I am not convinced that this proposed project is the best way forward
to fulfill short-term needs in NSW.

Please see attached submission

It is my pleasure to write a letter of support for the LNG import
terminal at Port Kembla proposed by Australian Industrial Energy Group
(AIE). I am writing this letter on behalf of the Illawarra Innovative
Industry Network - i3net.

The i3net is a network of industry based companies working from the
Illawarra. The network was established to promote the collective
capability of Illawarra Industry to local, national and international
markets. Industry in the Illawarra continues to be a key foundation of
the local economy.

There is an overwhelming need for new and substantial gas supplies for
the NSW energy market, and any increased supply into NSW will ease
price pressures for industry.

The proposed LNG import terminal project will be a significant
investment for the region. The key benefit of the AIE project is lower
gas costs. This will provide the following benefits to the region:

* Increasing the competitiveness of local manufacturing companies
* Retention/increase of local manufacturing jobs
* Attraction of new industrial and manufacturing clients to the
region.

At a local level, Australian Industrial Energy (AIE) have already
shown their commitment to the Illawarra region by joining i3net,
attending our events and speaking. The openness and approachability of
the AIE team is appreciated and to be commended.

It should also be noted that the project also provides positive
industry diversification within the port precinct, and also for those
local businesses who could support the terminal throughout its life.

As the premier network of industry based companies working from the
Illawarra, i3net fully supports AIE in developing the LNG import
terminal at Port Kembla, NSW. i3net is engaged and willing to support
this initiative to ensure its success.

We are looking forward to working with AIE to ensure that Illawarra
Industry maximises any opportunity to be part of this valuable supply
chain.

Yours sincerely,
Illawarra Innovative Industry Network - i3net

Bianca Perry
Executive Officer, i3net.

Please see attached letter from our General Manager Asset Management.

Please see attached.

Regional Development Australia (RDA) Illawarra affirms our support for
the Port Kembla Gas Terminal Project, as outlined in our attached
submission.

Please see attached

See attached

See attached

Please find the NSW Business Chamber's Submission to the Port Kembla EIS
attached

As per attached letter.

See attached

See attached

See attached