Dear Bennett Resources Pty Ltd (Black Mountain Energy) and Minister for the Environment Senator Murray Watt,
We object to the Valhalla Gas Exploration and Appraisal Program.
We believe Black Mountain Energy’s Proposal does not demonstrate to the standard the EPBC Act requires that Valhalla fracking can proceed without significant and potentially irreversible impacts on water resources, nationally listed threatened species and the Martuwarra Fitzroy River.
The implications of this Proposal must be considered in full
The Proponent frames Valhalla as a standalone exploration program. However, its own stated purpose is to determine whether commercial unconventional gas production in the Canning Basin is viable. The Proposal is a critical enabling step towards full-scale fracking development in the Kimberley. The significance of this Proposal must be judged in the context of the development pathway it opens.
The Proposal poses risks to water resources and groundwater ecosystems
The Valhalla fracking Proposal poses significant risk to water resources and groundwater-dependent ecosystems. The Proposal involves hydraulic fracturing and substantial groundwater use over several years in an arid, ecologically sensitive and remote region, yet it does not adequately show that impacts to groundwater, surface water, stygofauna, the Martuwarra Fitzroy River system and downstream users can be avoided, minimised or reliably monitored.
The Proposal poses risks to threatened species
The Proposal poses direct, indirect and cumulative risks to threatened species from around-the-clock drilling and hydraulic fracturing, flaring, clearing of forage habitat, vehicle strike, heightened fire risk and the spread of weeds and pathogens.
Species that may be affected include the greater bilby, ghost bat, Gouldian finch, northern blue-tongued skink, largetooth sawfish and EPBC-listed migratory birds.
Risks to stygofauna have not been considered
Stygofauna, small subterranean animals found in groundwater, are at risk from the Proposal. The Proponent's own Hydrological Assessment acknowledged stygofauna may be present, yet these animals are not addressed in Black Mountain Energy’s Preliminary Documentation at all. Groundwater abstraction and contamination create risks to stygofauna that are not accounted for in the Proposal.
Climate impacts have been ignored
The purpose of this Proposal is to facilitate fossil fuel extraction, yet climate implications have largely been ignored. These implications include lifecycle and downstream greenhouse gas emissions, fugitive methane and the compatibility of new gas projects with Australia’s climate goals.
The Valhalla project cannot proceed
On the evidence provided, the Proponent has not demonstrated that Valhalla can proceed in compliance with the objects and requirements of the EPBC Act.
Black Mountain Energy should withdraw the Valhalla Proposal in light of the failures set out above and the serious, potentially irreversible risk it poses to the Kimberley and its communities.
The Minister for the Environment, Senator Murray Watt, should refuse the Proposal.
Industrialisation of the world-renowned Kimberley is unacceptable.
