Given the timeframe, this is a draft post — just to flag this and start a discussion. Suggestions welcome. More coming Monday.
In March the WA EPA astonished the state by suddenly declaring that all new projects would need to “demonstrate how they would offset all emissions from their developments.” After an outcry these were withdrawn, but the EPA still wants them and are calling for submissions.
The requirements were so drastic they would affect the whole country just because of the size and the revenue lost from the WA projects. Not to mention that if the WA EPA gets away with this scientifically empty power grab, other EPA’s will follow…
Tens of billions of dollars in new resource projects will be at risk after Western Australia’s Environmental Protection Authority announced tough new measures around carbon dioxide emissions.
The new regulations will affect planned projects such as Woodside Petroleum’s $US11 billion ($15.6bn) Scarborough gas project and its $US20.5bn Browse development, as well as existing projects such as the $US34bn Wheatstone LNG plant and the $US54bn Gorgon LNG plant. — Paul Garvey, The Australian.
My post at the time: First they came for the coal industry, now for oil and gas: West Australian EPA decides state must meet “Paris” alone
The EPA is made up of five members appointed by the minister. It’s a QANGO, paid by the government, dependent on the government, but supposedly independent of it. It makes recommendations regarding the approval of new projects in the state but the government can choose to do something different. The problem is though, that companies need to jump through the hoops (which costs money and time), and it’s harder for a government to say “Yes” if the EPA says “No”. Plus it’s another PR win for the religion of climate change. More paid press releases.
- How do we predict or assess the “environmental benefits”: The EPA are only supposed to be considering the environment, not the economy, and they’re only supposed to be considering Western Australia, not the world. It seems to me that the hardest point for them to justify is how cutting emissions in a state of 2.6 million people or 0.3% of the worlds population will have any measurable outcome on the West Australian environment.
- Their entire assessment of “likely harm”comes from generic quotes and Argument from Authority from the CSIRO, BOM and the unaudited foreign committee. Who is responsible for checking these?
- The 2018 State of the Climate Report from the Bureau of Meteorology and the CSIRO
- The October 2018 IPCCs Special Report on Global Warming.
- The EPA needs to define what a “reasonable” measure is. If the rest of the world is doing almost nothing, is it reasonable for West Australian companies to pay exorbitant fees to allay emissions which will drive them out of business? And emissions that will just be emitted elsewhere and which will have no measurable effect to the fourth decimal place on the temperature of WA?
- The EPA document is poorly researched — it argues that “It is rapidly becoming standard international practice for greenhouse gas emissions to be considered by regulatory agencies”. Obviously the EPA is unaware that of what is happening in Russia, China, Indonesia, India, Africa, Brazil or the USA. Do they realize Donald Trump won?
On that basis the EPA are calling for submissions and promising to publish them and their responses. (That way they can say they consulted, even if they ignore everything that’s too hard). Nonetheless, it’s still worth putting in a submission Monday. Which I will. This post is here to remind others that’s it due, ask for suggestions, and offer to help.
The previous greenhouse gas guidelines released in March and withdrawn:
Key points in the Background Paper:
The EPA’s main role to protect the environment and abate pollution. Despite that, their entire assessment of “likely harm” comes from generic quotes from the CSIRO and the unaudited foreign committee:
How serious are the projected environmental impacts of further greenhouse gas emissions?
There is now broad community concern that greenhouse gas emissions from human activity are driving changes to our climate and the scientific data and analyses underpinning these concerns are robust and compelling.
The 2018 State of the Climate Report from the Bureau of Meteorology and the CSIRO noted that concentrations of all the major long-lived greenhouse gases in the atmosphere continue to increase, with carbon dioxide concentrations rising above 400 ppm since 2016 and the carbon dioxide equivalent of all greenhouse gases reaching 500 ppm for the first time in at least 800 000 years. Emissions from the burning of fossil fuels continue to increase and are the main contributor to the observed growth in atmospheric carbon dioxide. The report details the changes to our climate that have already taken place.
The October 2018 Intergovernmental Panel on Climate Change’s Special Report on Global Warming of 1.5°C describes what is at stake if we do not stay well below a 2 degree temperature increase, and the likely degree of emissions reductions that would be required to achieve this. Taken together, this information is of concern and cannot be dismissed as speculative or incorrect.
The EPA must have regard for the principles (s.4A) that those who generate pollution and waste should bear the cost of containment, avoidance or abatement; and that all reasonable and practicable measures should be taken to minimise the generation of waste and its discharge into the environment.
We’re supposed to kill industry because of the Paris agreement?:
Because greenhouse gas emissions affect local climate through global processes, effective environmental protection requires international recognition of responsibilities by national governments. This recognition is currently embodied in the 2015 Paris Agreement, in which 195 nations agreed to emissions reductions necessary to keep the global increase in temperature this century to below 2 degrees Celsius above pre-industrial levels, and to pursue efforts to even further limit the temperature increase to 1.5 degree.
It must “regard” three principles:
- The precautionary principle — the wholly unscientific idea that dangers we can’t be sure of must be avoided, and which is only selectively applied to politically convenient issues.
- The principle of intergenerational equity.
- The polluter pays principle.
The EPA is also supposed to consider the “means” of protecting the environment. So does that carbon trading idea work? Do carbon credits help Australia when they drive our clean industries over to China?
Sorry about the rough nature of this post, but suggestions are welcome.