Submission on the APLNG “Gas Supply Security Project”
From: Darling Downs Environment Council (DDEC) To: EnvApprovals@upstream.originenergy.com.au
Date: 4th of June 2025
Subject: Strong Objection to the APLNG “Gas Supply Security Project” – Environmental, Climate and Community Concerns
Dear Origin Energy and the Commonwealth Department of Environment,
The Darling Downs Environment Council (DDEC) strongly objects to the proposed APLNG “Gas Supply Security Project” on the basis of its unacceptable environmental, climate, and community impacts, the failure to adequately assess these risks, and the direct contradiction it represents to Australia’s stated climate and biodiversity commitments.
This submission addresses the most serious concerns related to:
1. Climate Change and Emissions
This project would enable the extraction and burning of fossil gas until 2061, long past Australia’s commitment to reach net zero by 2050, and at odds with the global carbon budget for limiting warming to 1.5°C.
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Estimated lifetime emissions exceed 435 million tonnes CO₂-e, with between 4.3–7 million tonnes emitted in Australia alone.
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The Public Environment Report (PER) fails to assess the majority of projected emissions, only analysing 916 wells despite seeking approval for 4,435. No downstream (Scope 3) emissions are assessed.
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The inclusion of only one gas processing facility in the emissions analysis, when eight are proposed, constitutes a critical omission.
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The report relies on outdated or discredited policy references and lacks a credible emissions reduction plan, particularly in light of the Safeguard Mechanism requirements.
This scale of emissions would increase climate risks for Australian communities, biodiversity, and ecosystems, including the Great Barrier Reef—without any clear public benefit or plan for phase-out.
2. Failure to Address Water Impacts
The project proposes to extract 72 gigalitres of groundwater from regions that are already heavily affected by cumulative drawdown from coal seam gas (CSG) operations.
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Springs and groundwater-fed ecosystems—particularly in the Dawson and Condamine River catchments—face drawdown beyond thresholds identified by the Independent Expert Scientific Committee (IESC).
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The PER fails to incorporate the latest regional groundwater model (2021 OGIA), relying instead on outdated assessments from 2020.
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Origin has ignored IESC advice recommending site-specific hydrogeological modelling and downplays risks by claiming that additional drawdown on already impacted springs is “not significant.”
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The cumulative water drawdown may push ecosystems past ecological tipping points, especially those dependent on the Great Artesian Basin.
This demonstrates a serious disregard for Australia’s water resources, including those relied upon by downstream communities, agriculture, and ecological systems.
3. Biodiversity Destruction and Fragmentation
The project would result in direct clearing of 16,670 hectares, including critical habitat for a range of threatened species.
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Modelled clearing includes 1,354ha of Koala habitat, 923ha for Greater Glider, and thousands more for reptiles like the Yakka Skink, Dunmall’s Snake, and the Collared Delma.
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Habitat fragmentation is extensive, particularly from access tracks, well pads, and pipelines—posing disproportionate harm to small, sedentary and ground-dwelling species.
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Origin fails to conduct local ecological surveys and bases its biodiversity analysis on broad predictive modelling that has not been ground-truthed.
In light of Australia’s worsening extinction crisis and international commitments under the Global Biodiversity Framework, this approach is completely inadequate.
4. Community and Intergenerational Risk
This development is being pursued for export-driven gas profits, while:
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Domestic energy needs are already met and will decline in line with renewable energy adoption.
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The project is marketed as “Gas Supply Security,” yet its real intent is to extend exports beyond existing contracts set to expire in 2035.
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The expansion would further industrialise rural landscapes, introduce long-term noise, light and air pollution, and put agricultural land, water security, and public health at risk.
Furthermore, the project entrenches dependence on fossil fuels in direct conflict with Australia’s own Energy Transition Plan, creating intergenerational harm.
5. Inadequate and Misleading Public Environment Report
The PER is fundamentally flawed and should be rejected. It:
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Fails to clearly state whether the proposed 4,435 new wells are in addition to or replacing the 10,000 previously approved;
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Grossly under-represents the scale and timeline of climate pollution;
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Ignores credible, expert recommendations from the IESC;
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Omits cumulative impact assessments;
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Misrepresents the significance of water and biodiversity risks;
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Fails to justify the public interest benefit of this project in the face of mounting climate harm.
Conclusion and Recommendation
The Darling Downs Environment Council strongly urges the Commonwealth Government to refuse environmental approval for the APLNG Gas Supply Security Project on the basis of:
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Major unaddressed climate and biodiversity impacts;
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Outdated and incomplete environmental modelling;
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Violation of international and national commitments on climate, water, and biodiversity;
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And a lack of genuine need or public benefit, especially given APLNG’s already surplus gas reserves.
This project represents an unacceptable environmental and social risk that is incompatible with a safe climate future. Communities across Queensland—including the Darling Downs—deserve investment in sustainable energy, not the expansion of polluting gas fields that lock in harm for decades.
Sincerely,
Ahri Tallon
Coordinator
Darling Downs Environment Council
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