Stop Woodside's Pollution Dumping

A Quick and Easy Guide: Make Your Submission in Minutes

(or write your own! We have a comprehensive guide below)

Scott Reef, one of the world’s most pristine marine ecosystems, is under threat from Woodside’s proposed Browse Carbon Pollution Dumping Project. If approved, this project would involve 7 more wells being drilled for CO2 injection and enable over 1.6 billion tonnes of CO2 emissions from the main Browse gas project—a disaster for our climate and marine life.

Help us demand an immediate rejection based on unacceptable environmental impacts.

Submissions close on 31 January 2025!

(The deadline was extended thanks to the movement's ongoing pressure and the sheer level of public submissions!). 

Follow these 5 simple steps to make your submission:

1. Go to the EPBC Act Public Portal [Click here to open the portal].
2. Title your comment: "Full environmental assessment needed for Browse Carbon Capture and Storage project."
3. Provide your details (name and email).
4. Answer YES to the question: "Do you consider this a Controlled Action?"
5. Copy and paste the purple text into your comment (or write your own! We have a comprehensive guide below)

I call for an immediate rejection based on unacceptable environmental impacts, or at the very least, a comprehensive assessment of the project.

Threats to Listed Species: This project directly threatens over 20 listed threatened species and over 30 migratory species, including:

• Endangered Dusky Sea Snake: Highly sensitive to seismic shockwaves causing death.
• Endangered Pygmy Blue Whale: Disrupted by seismic blasting and vessel traffic, which harms communication and feeding.
• Vulnerable Green Sea Turtle: At risk from habitat disturbance, pollution, and potential CO2 leakage.

Seismic Blasting Risks: Seismic blasting creates intense underwater shockwaves that can harm and kill marine life, disrupt food webs (krill, vital for whales), and degrade the acoustic environment essential for species.

Risk of CO2 Leakage: There are significant risks of CO2 leakage in perpetuity! Leaks can result from the storage formation, potentially acidifying marine waters and harming coral reefs.

Cumulative Emissions: The project is linked to the larger Browse gas project, which will emit over 1.6 billion tonnes of CO2. Even if the CCS project succeeds, over 96% of emissions will still be released, contributing massively to climate change.

Unproven Technology: CCS technology is an unproven technology and has a poor track record, with projects failing to meet storage targets.

Precautionary Principle: Given the high risks and uncertainties, applying the precautionary principle is critical. This principle mandates that when an action poses serious or irreversible threats to the environment, a lack of full scientific certainty should not be used as a reason to proceed without thorough assessment and mitigation. This project risks irreversible harm to a globally unique marine ecosystem, contravening Australia’s obligations to conserve biodiversity and reduce emissions.

That’s it! Submit your comment and help us protect Scott Reef and the climate.

Share this guide with friends and family—every voice counts!

A Comprehensive Guide: how to craft a strong comment  

A well-crafted, personal submission has far more impact than a generic comment. Personalising your message shows genuine concern, highlights the breadth of community opposition, and makes it harder for decision-makers to ignore public sentiment. Use this guide to write an informed and compelling submission that stands out.

 Follow steps 1-4 above and then write a strong and personalised comment.

The Environment Minister will review the application and can only use comments that relate directly to protected matters covered by Australia’s main environmental law, the EPBC Act. Therefore, make your comments specific to the proposal. To make your comments as helpful as possible, include the following:

1. Why you believe the proposal is a controlled action: The project threatens numerous Matters of National Environmental Significance (MNES), including listed threatened species, migratory species, and marine ecosystems.
2. How the proposal will have an impact on protected matters: Explain the specific impacts, such as:
   • Habitat disturbance and pollution risks for species like the vulnerable green turtle and endangered dusky sea snake and pygmy blue whale.
   • Potential CO2 leakage affecting marine water quality and coral reefs.
3. Which parts of the proposal will have an impact on particular protected matters: Highlight activities such as seismic blasting, drilling, and the risk of CO2 leakage on different parts of the ecosystem.
4. Sources of key information: Refer to credible research, past CCS project failures, and information in Woodside’s referral document to support your points.

If you believe the referral information provided by Woodside is misleading or incomplete, be sure to highlight this. Explain why it may be inaccurate and, if possible, provide the correct information.

Key Issues to Raise in Your Comment

1. Call for an immediate rejection based on unacceptable environmental impacts, or at the very least, a comprehensive assessment of the project.

2. Threats to Listed Threatened and Migratory Species

This project directly threatens over 20 listed threatened species and over 30 migratory species, including:

• Dusky Sea Snake:

The dusky sea snake, recently listed as endangered, is extremely sensitive to changes in its habitat and faces serious threats from industrial activities on Scott Reef. Increased water pollution, habitat disturbance from drilling, and noise pollution all pose significant risks to its survival in this fragile environment. 

Seismic blasting can kill sea snakes through "fatal barotrauma from intense sound" (DECCEEW 2024 Conservation Advice for Aipysurus fuscus dusky sea snake pg.20). These reptiles have a lung that extends through a third of their body, allowing them to store oxygen for long dives. The air-filled cavity in their lung can be damaged by intense underwater shockwaves from seismic blasting, potentially resulting in severe trauma or death.

• Pygmy Blue Whale:

Endangered pygmy blue whales are particularly vulnerable and face serious risks from Woodside’s proposed activities. The industrial noise from drilling, vessel operations, and other construction could disrupt their migration routes, making it harder for them to navigate safely.

Pollution from the project threatens the krill population—tiny shrimp-like creatures that are essential food for the whales. The infrastructure Woodside plans to build is located in the same area where krill thrive, and any pollution could harm their ability to reproduce and grow.

Additionally, noise pollution from the project can make it difficult for whales to locate and feed on krill, further jeopardising their survival.

Seismic blasting poses a serious threat to krill—key components of the ocean food chain. The potential damage from these blasts has likely been underestimated, and the full extent of the risk remains poorly understood. However, existing research shows that seismic blasting can have significant harmful impacts that disrupt the marine ecosystem. Research suggests seismic blasting can cause deafness in whales. Pygmy blue whales rely heavily on their hearing for navigation, communication, and locating food, any impairment can have serious consequences.

• Green Sea Turtle: Classified as vulnerable under the EPBC Act, it faces severe risks from habitat disturbance, pollution, and potential CO2 leakage.

Green sea turtles rely on the pristine waters around Scott Reef for feeding, resting, and migration. The installation of subsea infrastructure, including the CO2 injection flowline (up to 130 km in length), multiple wells, and supporting facilities, will result in a seabed disturbance footprint of approximately 2.5 km². Such large-scale disturbances could degrade essential habitats.

• Industrial activities such as drilling and seismic blasting generate intense noise and light pollution, which are known to adversely affect marine turtles. Seismic blasting, in particular, produces powerful underwater shockwaves that can:
• Disorient and stress turtles, potentially affecting their navigation and migration routes.
• Disrupt normal behaviour, such as foraging.
• Additionally, artificial lighting from offshore facilities can interfere with the natural behaviour of green turtles, particularly hatchlings, which rely on moonlight for orientation.

3. Marine Ecosystem Impacts

Scott Reef is one of the world’s most pristine and biodiverse coral reef systems. The project poses significant risks, including:

• Seismic Blasting: The powerful shockwaves from seismic blasting can harm marine mammals by disrupting their communication and navigation. Seismic blasting disrupts krill, a vital food source for endangered pygmy blue whales and other fauna, this could have serious cascading effects on food webs and the marine ecosystem.
• CO2 Leakage Risks: There are significant risks of CO2 leakage in perpetuity! There are significant uncertainties around the integrity of the storage formation. Any CO2 leakage could acidify marine waters and cause long-term damage to coral reefs and marine ecosystems.
• Habitat Disturbance: Seabed disturbance from infrastructure would cause sedimentation and turbidity smothering sensitive species, disrupting habitats and reducing light availability that deeper coral communities rely on for survival.

4. Unproven and Risky Technology

Carbon capture and storage (CCS) is experimental and has a poor track record globally. Notably:

• CCS projects, such as Chevron’s Gorgon project in Australia, have consistently failed to meet storage targets.
• Between 1995 and 2018, over 260 CCS projects were undertaken globally, with only 27 completed successfully (~10%) (Zero Carbon Analytics 2022 Carbon Capture and storage: where are we at?).

5. Cumulative Impacts and risk of functional extinction to the reef

The Browse CCS project is not a standalone initiative. It is directly linked to the Browse gas project, which will emit over 1.6 billion tonnes of CO2. Even if the CCS project captures its target of 53 million tonnes, over 96% of emissions will still be released, contributing massively to climate change.

There are multiple stressors at Scott Reef that collectively exert pressure on a fragile ecosystem.

The browse carbon pollution dumping project presents significant impacts and risks to the environment, including:

• CO₂ toxicity
• Risks of earthquakes
• Risks of CO₂ release and leakage (loss of containment)
• Marine impacts of ongoing seismic blasting required for monitoring
• Additional drilling impacts
• Noise and light pollution
• Discharge of hazardous waste
• Mammal collisions
• Seismic blasting
• Water and environmental quality

These impacts are compounded by climate change induced sea level rise, bleaching, cyclones, and acidification. The extent these factors interact remains poorly understood. The reef’s delicate ecosystem is increasingly vulnerable to the direct impacts of Browse and the carbon dumping project as well as the indirect impacts due to climate change. To give Scott Reef the best chance of withstanding climate impacts, we must avoid additional threatening processes associated with this proposed development. 

Oceanwise (2024 Scott Reef, Review of Environmental Values) find that the incomplete data on the threatened species population trends and habitat use, combined with the escalating impacts of climate change, mean the additional cumulative impacts from the browse project would irreversibly harm the endangered species. These findings can be applied to the carbon dumping component of Woodside's plans. 

Combined pressures from climate change and industrial activities could push Scott Reef’s coral ecosystems past their resilience threshold, risking functional extinction of coral reefs.

6. Applying the Precautionary Principle

Given the high risks and uncertainties, applying the precautionary principle is critical. This principle mandates that when an action poses serious or irreversible threats to the environment, a lack of full scientific certainty should not be used as a reason to proceed without thorough assessment and mitigation. This project risks irreversible harm to a globally unique marine ecosystem, contravening Australia’s obligations to conserve biodiversity and reduce emissions.

Last step: Attach any documents that you reference to support your argument and submit your comment.

Additional Resources

Scott Reef, Review of Environmental Values and proposed Browse to North West Shelf Project Environmental Impact Statement/ Environmental Review Document: A scientific assessment by Oceanwise of the environmental values of Scott Reef and evaluates potential impacts from the proposed Browse to North West Shelf (NWS) gas project. 

Why carbon capture and storage is not the solution:  An analysis by the Institute for Energy Economics and Financial Analysis about how carbon capture and storage (CCS) has often been hailed as a potential game-changer in the fight against climate change, but its history is full of over-promising and under-delivering, and this is unlikely to change in the foreseeable future.

Scott Reef, Like Nowhere Else: A photobook showcasing the extraordinary beauty and ecological significance of the reef and the risk Woodside’s projects pose.

List of Threatened and Migratory species using Scott Reef and surrounds:

Threatened

· Scalloped Hammerhead

· Leaf-scaled Sea Snake, Leaf-scaled Seasnake

· Short-nosed Sea Snake, Short-nosed Seasnake

· Curlew Sandpiper

· Blue Whale

· Christmas Island White-tailed Tropicbird, Golden Bosunbird

· Red-tailed Tropicbird (Indian Ocean), Indian Ocean Red-tailed Tropicbird

· Olive Ridley Turtle, Pacific Ridley Turtle

· Loggerhead Turtle

· Leatherback Turtle, Leathery Turtle, Luth

· Dusky Sea Snake

· Abbott's Booby

· Fin Whale

· White Shark, Great White Shark

· Australian Lesser Noddy

· Flatback Turtle

· Green Turtle

· Hawksbill Turtle

· Sharp-tailed Sandpiper

· Whale Shark

· Sei Whale

· Red Knot, Knot

Migratory

· Humpback Whale

· Blue Whale

· Fin Whale

· Bryde's Whale

· Common Sandpiper

· White-tailed Tropicbird

· Lesser Frigatebird, Least Frigatebird

· White Shark, Great White Shark

· Great Frigatebird, Greater Frigatebird

· Streaked Shearwater

· Little Tern

· Flatback Turtle

· Sperm Whale

· Reef Manta Ray, Coastal Manta Ray

· Common Noddy

· Green Turtle

· Olive Ridley Turtle, Pacific Ridley Turtle

· Hawksbill Turtle

· Loggerhead Turtle

· Leatherback Turtle, Leathery Turtle, Luth

· Spotted Bottlenose Dolphin (Arafura/Timor Sea populations)

· Giant Manta Ray

· Narrow Sawfish, Knifetooth Sawfish

· Killer Whale, Orca

· Sharp-tailed Sandpiper

· Whale Shark

· Shortfin Mako, Mako Shark

· Oceanic Whitetip Shark

· Sei Whale

· Pectoral Sandpiper

· Curlew Sandpiper

· Red Knot, Knot

· Longfin Mako

- Thank you for helping save the reef!