Xx Street Name
Suburb
xxxx
xx February 2013
Work Approvals
works.approvals@epa.vic.gov.au
EPA Victoria
GPO Box 4395
Melbourne
Victoria
3001
EPA WA71437 ESSO CONDITIONING PLANT
I write to register my objection to the application for an EPA Works Approval 71437 that has been
put forward by Esso Australia Pty Ltd.
As a landowner in the region I take particular interest in the activities and development of industries
in my back yard, particularly if they threaten the health and wellbeing of my immediate family,
neighbours and friends. Combined with the recent environmental disasters by Esso and the long
history of ill health and associated cancers in Esso workers, it surprises me that the expansion and
continued operation of such a primitive industry is supported by our environmental regulators and
local government.
I wish to raise a number of environmental concerns which are detailed in WA71437:
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Environmental Effects Statement
Works Approval Application Process and Community Engagement.
Environmental and Biodiversity Act 1999
Major Hazard Facility Licence
Existing EPA Approvals
Fossil fuel use and the Gippsland Environment
CO2 Emissions
Mercury Recycling
Water usage
Noise Levels
Future developments and the processing of Onshore Gas
Environmental Effects Statement
On 27 August 2007, the then minister for planning deemed an Environmental Effects Statement
unnecessary for the development of the Longford Conditioning Plant project. Subsequent residential
expansion approvals by local government between 2007 and 2012 nullifies the then planning
ministers decision. Furthermore, the lack regard for Esso’s ‘Major Hazard Facility’ status in the
decision making process indicates irresponsible governance and disregard for the health and safety
of local residents.
The Hon Matthew Guy must ensure that an Environmental Effects Statement process is put in place
to ensure that ESSO meets the requirements of current day planning and legislation and ensures the
wellbeing of all life forms within the Esso Longford Major Hazard Facility Boundary zone.
Works Approval Application and Community Engagement
Although a works approval application was handed to the EPA on 4 Dec 2012, this was not well
publicised. Additionally, local stakeholders were denied 7 days of access to the WA once it came
within the 21 day objection period for closure on 20 Feb 2012. If local stakeholders had not
requested a copy of the WA, this period may have extended beyond 7 days.
Local stakeholders have requested parliamentary assistance in having the closure date extended to
remedy the delayed publishing of the WA. It is requested that the process of public consultation be
improved and the 21 day objection period recommence once the public consultation with
immediate stakeholders has taken place.
Environmental and Biodiversity Act 1999
Longford and the surrounding areas are home to several indigenous plant and animal species, some
listed as threatened species. These include the New Holland Mouse, Wellington Mint-bush, Trailing
Hop-bush, Dwarf Kerrawang and the Green and Golden Bell Frog. Referral under the Environment
Protection and Biodiversity Conservation Act 1999 (Cth) must occur without consideration. Failure to
do so reinforces ExxonMobil’s total disregard for the environment
Major Hazard Facility Licence
For decades, Esso has held a Major Hazard Facility License. No public consultation has taken place
regarding this fact. Esso is in breach of several OHS Work Safe Victoria guidelines regarding Major
Hazard Facility policies of the Work Health and Safety Act 2011. Consultation with Work Safe Victoria
must occur prior to the consideration of this Works Approval.
Existing EPA Approvals
Due to several breaches since November 2011 of the existing EPA Environmental Licence EM31686
and the Environment and Resource Efficiency Plan (EREP), ExxonMobil/Esso’s, these licenses must be
withdrawn and reconsidered. The current safety and environmental protocols are not being met and
the fit and proper status as the holder of these licences must be reviewed.
Fossil fuel use and the Gippsland Environment
Gippsland relies predominantly on it’s agricultural output to sustain it’s economy. Food related
activity in the Gippsland region generates more than $2 billion in exports, more than 14,000 jobs and
is responsible for more than $1.3 billion in expenditure on goods and services within the region.
Increased Global Demand for Food – the global demand for food is projected to increase significantly
in the next 30 years as is the demand for food types in which Gippsland has strengths. Food Security
and Availability – food security is not the issue in Australia that it is in other locations in the world;
however Gippsland is well placed to contribute to such demands, particularly through its commodity
exports. Environmental Sustainability – the Gippsland food system is highly dependent on the
region’s natural resources; as demand for food increases there is an ongoing need to reduce the
negative impact of the food system on natural resources and improve the health of the region’s
ecosystems. Climate Change – climate change will have an impact on the food system, and in
particular on horticulture. While the Gippsland region has relatively good rainfall compared to many
other locations there is a need to build climate change resilience.
For all of these reasons, highlighted in the Regional Development Australia Gippsland (RDAG)
Committee ‘Gippsland Food Plan’, Gippsland must strive toward a Carbon Zero future and invest in
renewable energy resources if we are to maintain our agricultural output and survive the
devastation of an ever warming climate.
CO2 Emissions
“Carbon Management at Work”. Although the EPA has acknowledged, ‘Climate change is an issue of
critical importance to business.’ and has itself implemented a Carbon Management Plan, the EPA
fails to apply Carbon Management Targets to big polluters such as Esso who rather than reducing
Green House Gas Emissions in future developments will be increasing Victoria’s Carbon Dioxide
emissions considerably. The estimate of 1 million tons of Carbon Dioxide must be considered an
average, which infers that there will be periods of exceeding that output. Will an independent
monitoring agency be tasked in monitoring CO2 output at industry expense? Will this help Victoria
and Australia in achieving their 2020 carbon goals?
Mercury Recycling
Processing of waste mercury to a level ‘as far as is reasonably practical’ cannot meet the level of
scrutiny for consideration of this Works Approval. Exact data of waste levels must be provided.
Water usage
Southern Rural Water must reconsider the importance of the fossil fuel industry versus creating a
sustainable environment for human, animal and plant life in Gippsland. The loss of 2.6 million
litres/day is unacceptable. Prioritising industry over life is unacceptable.
Noise Levels
The noise level projections detailed in the Works Approval are estimations only. Compounding
effects such as air flows, vibration and reflection within the natural and man-made environment
have not been considered. The EPA has not provided current noise data sampling to the local
residents and neighbours as a comparison and the Works Approval does not indicate a noise
monitoring program and independent review for compliance purposes. Until such processes are in
place and current noise studies have been conducted, the Works Approval projections remain
invalid.
Future developments and the processing of Onshore Gas
Esso’s recent involvement in the exploration of Onshore gas is clearly an indication of it’s future
intent. Recent press statements release by Lake Oil also detail local processing of onshore gas at the
Esso Longford plant. The Works Approval makes no mention of onshore gas processing and
therefore onshore gas processing should be excluded from and not considered for processing at
Longford in the future.
Summary
The evolution of climate and environmental science since 2007 must be noted. It is irresponsible of
the EPA and the current planning minister, the Hon Matthew Guy not to apply current expert
scientific data to new fossil fuel developments which will continue to exacerbate the pressure they
already apply to our fragile eco-system.
Sincerely
Name Surname
youremail@address.com