This is an extract from the submission presented by Counsel Robert White to the Independent Planning Commission panel for the NW Alliance on Thursday 23 July 2020.

The introductory presentation is here.

Environmental issues: Ecological impacts

Independent expert advice commissioned by NWA and its members has identified that uncertainty about the location of gas infrastructure as well as the scale of direct and indirect impacts has made a transparent assessment of the biodiversity impacts of this Project impossible.

The Pilliga Forests constitute an important refuge area for wildlife, containing high conservation-value small remnant patches, which are part of a recognised National Biodiversity Hotspot with endemic species and high levels of ongoing threat, whose irreplaceability is of the highest order. The threat and serious and irreversible harm is clear.

The evidence will demonstrate that the installation and operation of the 850 gas wells will result in the following detrimental impacts:

  • Increased fragmentation of a landscape already under severe environmental stress;
  • increased sedimentation of ephemeral waterways and the reduced availability of surface water essential to the maintenance of many vertebrate populations;
  • increased disturbance from an increase in vehicle movements, dust, noise and lighting associated with gas mining operations;
  • cumulative impacts resulting from the exacerbation of perturbations already operating in the project area due to intensive forestry operations and climate change, particularly the loss of hollow bearing trees, vegetation loss and increased fire frequency.

There are significant deficiencies in the way the impact assessment is presented in the environmental assessment. These include:

  • The scale of the direct impact of the project through vegetation removal is not certain. Figures provided by the proponent are likely to be under-estimates.
  • The magnitude of ‘indirect impacts’ has been grossly under-estimated and does not take into account the variety and magnitude of expected impact types. A number of threatened fauna species will be disproportionately impacted by indirect means which are not accounted for in the methodology. For example, the increase in feral predator activity in the gas field that will result from the internal fragmentation cannot be offset.
  • Cumulative impacts have been inadequately considered.
  • The survey effort undertaken for the environmental assessment was insufficient and this has inhibited a proper assessment of impacts on these species.

The proponent has failed to establish the likely environmental consequences of the Project and the precautionary principle should be engaged.


The likely environmental impacts are so significant that the Project should be refused development consent.