Freedom of Information documents posted on the federal Department of Agriculture, Water and Environment website on Tuesday shows comments on the Supplement for the Browse to North West Shelf proposal - EPBC 2018/8319.
The proposal involves drilling and extracting gas from the Brecknock, Calliance and Torosa gas reservoirs near Scott Reef, approximately 425km north of Broome, WA.
As part of the public comment period of the proposal, Woodside legally has to respond to concerns cited around the project, and the Department of Agriculture, Water and Environment reviews whether Woodside's responses are adequate.
The project received almost 20,000 submissions, however Woodside failed to disclose how many support the proposal and how many are against it.
The department notes that multiple submissions raise concerns around the impacts the project would have on many animal species, including the Pygmy Blue Whale - a subspecies of blue whale that is listed as endangered under the EPBC Act.
The department highlighted that the waters surrounding Scott Reef are identified as a key feeding ground, or a ‘foraging biologically important area', for the Pygmy Blue Whale, and the department's conservation management plan identifies noise interference from seismic, drilling and gas processing; vessel disturbance, and climate change variability as key threats that the Browse project poses.
The government has similar concerns around the project regarding its impact on marine turtles as they use Browse Island as a key nesting area, and migratory birds.
"[Woodside] should provide clearer, logical and robust impact and risk evaluation that acknowledges the potential for blue whales...and marine turtles to occur within the project area and the potential ongoing importance of the Scott Reef," the department's comment states.
Woodside's EIS also fails to fully describe a detailed evaluation of the consequences of an oil spill, with the department saying consideration should be given to engineering controls or feasible alternatives such as double bottom/hull or other measures that would limit the likelihood and potential scale of a condensate spill.
"Addressing these issues is important to support a case for the inherent acceptability of spill risks for the project taking into account the proximity of the Torosa FPSO to Scott Reef, and the potential for a spill of this nature to impact on the values of the Scott Reef complex," the comment states.
The draft EIS also fails to provide adequate commitment to how the project would be decommissioned as it becomes disused.
The department also orders Woodside to address concerns in relation to gas demand projections in end user markets, including how uncertainties associated with future project demand for LNG has been identified and accounted for in evaluating the greenhouse gas emissions of the project.
The public submission noted the International Energy Agency's World Energy Outlook 2019 indicates gas demand would peak sooner than Woodside anticipates.
The submission asserts that there would be 31% growth in gas demand overall, not the 130% figure Woodside has stated; that coal-to gas switch is less economically feasible, and LNG faces uncertainty in terms of scale of imports, their durability and price competitiveness.
While the EIS considers the avoidance, mitigation and management of greenhouse gases at a high level, the department said it lacks detail around how associated emissions with the project could be avoided, whether its proposed measures are best practice and what other options there are that could achieve better outcomes.
Meanwhile no discussion of offsets is provided in the draft EIS, with the department saying Woodside needs to commit to developing an offset plan for whales, turtles, greenhouse gas emissions, and Scott Reef itself.
The documents released also show an email chain where government officials from the EPA, DAWE and NOPSEMA attempt to arrange a time to meet with Woodside to discuss the proposal, but the meeting is repeatedly pushed back.
The Browse development, destined as backfill for the declining North West Shelf LNG facility, has had sanction pushed back multiple times and is now slated for after 2023.
The high-CO2 fields' development has attracted the ire of conservation groups, with anti-gas Clean State suggesting its development is "much worse" than the Adani-driven Carmichael coal mine.
Woodside told Energy News it was in the process of finalising its Response to Submissions document and EIS Supplement (Commonwealth).
"These documents will be made public once reviewed and accepted by the regulators," a Woodside spokerson said.