10 February 2007Environmental Protection Authority
PO Box K822
PERTH, WA 6842
Attention: Richard Sutherland

PER Assessment No 1632. Pluto LNG Development, Burrup Industrial Estate. Woodside Energy Ltd.

Two weeks before the submissions commenting on the above application by Woodside closed, on 5 February 2007, Woodside began destroying rock art sites at the Pluto A Site at Dampier, i.e. without having obtained clearance from the EPA. On 7 February, the state Indigenous Heritage Minister met representatives of all relevant native title claimants on site and was asked to stop Woodside’s destruction of sacred rock art sites. Premier Carpenter had promised that if the Aborigines objected to the siting of the Pluto plant at Dampier, he would locate it elsewhere. Woodside have an alternative site at Onslow, next to the one BHP Billiton will use for a similar plant, and there are no significant environmental or heritage issues there.

At Dampier, this development will destroy another part of the largest art gallery in the world, the largest cultural heritage property in Australia, the world’s largest rock art site, Australia’s largest site of stone arrangements. The Dampier Cultural Precinct is one of the most sacred and outstanding monuments, yet we have already destroyed 24.4% of the Burrup rock art sites since 1963 (DIA figures). As a nation we are truly cultural barbarians. We appeal to the EPA to reject the Woodside application on the following grounds:

1. The further destruction of the Dampier monument is strenuously opposed by the Wong-Goo-Tt-Oo, the Ngarluma and the Mardudhunera-Yaburrara.
2. A monument of such world significance should never have been degraded, it does not morally belong to the state, it is a part of the patrimony of all of humanity. The state can only be its manager or caretaker.
3. The Australian Heritage Commission has determined that Dampier should be on the World Heritage List, as well as on the National Heritage List.
4. Our discussions with the Cultural Heritage Branch of Unesco in France have shown conclusively that Unesco is expecting Australia’s nomination of Dampier, and will approve it, yet here we have a company needlessly proposing to cause further damage to the monument.
5. The continuing destruction of a monument larger than 100 Stonehenges is an affront to the civilised people of the world and must be discontinued. It is in fact illegal (Article 6, Unesco Convention concerning the Intentional Destruction of Cultural Heritage).
6. The more than 30,000 signatures already collected and the thousands of individual comments on the Web leave no doubt that the public is enraged by the Burrup vandalism.
7. Woodside, in pre-emptying your decision, has shown its contempt for the EPA’s authority.
8. Already the equivalent of 100 Hiroshima bombs is stored in energy at the NW Shelf site, the Pluto project would add another 120 Hiroshima bombs equivalent and should therefore be built elsewhere because such concentration of volatile substances is dangerous (Dampier fact sheets).
9. The high concentration of acidic atmospheric emissions is destroying the rock art, further acidic emissions (a doubling of the current 12,000 t/yr NOx, plus others) need to be located elsewhere (Dampier fact sheets).
10. The most suitable site for the Pluto Project is at Onslow, where even construction costs would be significantly lower (Astron Report).

We comment specifically on Woodside’s proposal:
a. Item 2.1, Consultation of Stakeholders to Date: Numerous false claims are made. For instance the consultation of Traditional Custodians has been a farce in every possible respect. In Table 2-1, we, the International Federation of Rock Art Organisations, are listed as having been consulted. We have never, in any form or fashion, been consulted by Woodside. The proponent should provide documentary evidence for all claims. Similarly, we believe that several of the other groups listed therein have not been consulted. Even local community consultation was at best cosmetic.
b. 4.3.1 Aboriginal Heritage: It is noticeable that there are excellent maps of vegetation regimes and details on previous pages, even though these ecosystems are repeated in numerous places. The cultural contents of Site A, which are unique in the world, are considered only cursorily, there is no mapping of them, only an inadequate summary of previous surveys.
c. 5.11.1 Potential Impacts: The impact of the construction of the Pluto plant in this location will totally destroy the ambience of this sacred cultural precinct at Holden Point, and will result in the destruction of hundreds of rock art and stone arrangement sites. At the former, any boulders that can be transported will be, and already are presently, removed and dumped in a compound (we have thousands of boulders in such graveyards of rock art already, where they are of no value to either Aborigines or scientists). What cannot be moved, and that includes all stone arrangements, will be bulldozed.

The Woodside application is of course a Trojan Horse: approval of it will lead to the construction of a massive LNG Plant, therefore approval of this application will pre-empt most further decisions by the EPA. The proponent, having been encouraged to expend resources at the site, will reasonably expect that all further applications will be approved. Therefore, with this application, the EPA requires technical details of the Pluto plant, especially of proposed emissions of greenhouse gases, acidic emissions and carcinogens. The EPA also requires estimates of the quantities of volatile, flammable and explosive substances to be stored next to the existing NW Shelf plant.

We recommend that the EPA request the following from Woodside:
1. To provide evidence of proper consultation of all stakeholders, especially those who are likely to oppose the project being located at Dampier.
2. To provide fully documented evidence on the number of rock art motifs to be destroyed and moved, of the number of stone arrangements to be destroyed or disturbed, and on the number of both rock art items and arranged stones that will be located within 200 m of any plant components. This is required for both Site A and Site B.
3. To provide firm estimates of the quantities of CO2, NOx, SOx and benzene to be emitted by the Pluto plant once operational.
4. To provide firm estimates of the quantities of condensate, propane, butane, light oil, hydrogen and other flammable, toxic, volatile or explosive substances to be stored at the completed and operational Pluto plant.
5. To provide written evidence that the senior Traditional Custodians of the local Indigenous groups agree to the placing of this plant on their traditional land.
6. To explain why destruction of the monument has commenced before the EPA announced its ruling.
7. To provide technical details of the effects of the acidic pollution on the ferruginous rock accretion, bearing in mind that Woodside has already lowered ambient pH from 7.2 to 4.6, causing acid precipitation 50 weeks in the year (see CSIRO report).
8. To provide a documented and reliable prediction of how much further the precipitation pH will be lowered by the Pluto plant.
9. To explain in detail why Onslow is not a realistic option for the siting of the Pluto plant.

We also recommend that the EPA propose the introduction of a nitrogen oxide levy, which has been in operation for years in countries such as Sweden. Massive emissions of NOx are extremely damaging to the environment, the air is not owned by polluters, and if they choose to pollute it they must be made accountable. Society has a right to clean air and water, and Woodside deliberately chooses not to replace its scrubbers at the NW Shelf facility with cleaner technology, even though the cost would only be $60 million (Roger Dean, DIR). NOx emissions travel for thousands of kilometres.

The application by Woodside is disingenuous in that it does not provide the full environmental effects of the project is alludes to, the Pluto project. It also fails to spell out the effects on the area’s world-class cultural heritage, it does not even detail how the proponent intends to deal with it. It lies about consultation of stakeholders, just as Woodside has lied in the past about the size of its emissions until we forced it to tell the truth (see admission of March 2003). As you know, Woodside is the country’s largest polluter. This application deliberately conceals the extent of the damage to the cultural heritage, which consists of two types: immediate destruction of hundreds of sites, and slow destruction of all rock art sites in the Dampier Archipelago, which constitutes Australia’s largest cultural monument. This application must be treated as your British counterpart would treat an application to build a refinery at Stonehenge that states ‘but we will only tear down part of the monument’. Woodside needs to be persuaded to locate the Pluto Plant elsewhere, perhaps at Onslow.

Please note also that the evidence for Woodside’s commencement of rock art site destruction in the last few days is publicly available at http://mc2.vicnet.net.au/home/dampier/web/vandal.html, together with a statement by one of the local Indigenous community leaders. For very detailed information about the Dampier rock art and its destruction, please go to http://mc2.vicnet.net.au/home/dampier/web/index.html

We represent about 7000 researchers around the world. Nothing in this submission is confidential.

Yours sincerely,

Robert G. Bednarik
Convener, International Federation of Rock Art Organisations (IFRAO)


Selection of Dampier petroglyphs under threat of destruction.