Despite the Perth company publicly declaring the Pluto approvals process complete its plans to manage the contentious issue of greenhouse emissions are now with the EPA and the authority is expecting to see targets for reduction that support the WA Government's aspiration of net-zero emissions by 2050.
The EPA is also assessing what Woodside will do to manage air quality on the Burrup Peninsula where pollution could possibly damage ancient Aboriginal rock art that the Federal government put up for world heritage listing in January.
Woodside plans to sanction the US$11.4 billion Scarborough and Pluto train 2 projects in the first half of 2020.
Its website states for Pluto: "Environmental approvals timeline: Complete."
CEO Peter Coleman said in July that "Woodside's position, that it would confirm with the EPA, was that building a new LNG train at Pluto was covered by existing approvals."
However, the picture is a little more complex and while the main approvals are in place Woodside will have to submit secondary greenhouse gas and air quality plans that the EPA could recommend against. If that happens the final red or green light will rest with the environment minister.
The changes are down to a series of recent moves and countermoves by the EPA and state government.
According to a Woodside fact sheet the environmental approvals when the first Pluto train was built allowed for a second train and "associated management plans will be evaluated under these approvals and updated as required".
In March the oil and gas industry fought off the EPA's proposal to recommend major new projects, including expansions, offset all their emissions.
In August the state government released a loosely worded greenhouse gas emissions policy for major projects that included an "aspiration" of net-zero emission by 2050. Woodside welcomed the policy but progressive policy tank The Australia Institute saw it as an attempt to pre-empt and undermine the EPA's development of new greenhouse gas guidelines.
Instead of feeling undermined the EPA built on the Mark McGowan-led Labor government's call for net-zero by 2050 when it issued a draft new greenhouse gas guideline in December.
The draft called for proponents to demonstrate a contribution to WA achieving net-zero emissions by 2050, including emissions reduction targets over the life of the project.
EPA chair Tom Hatton was questioned at the time about whether previous approvals meant Pluto Train 2 did not have to go through this process.
"There is a requirement regardless for a GHG management plan and an air quality management plan," he said.
Yesterday Hatton told Energy News that the existing ministerial statement of environmental requirements for Pluto required Woodside to set targets for the progressive reduction of total net greenhouse gas emissions "and in doing so, it is appropriate that they consider the current EPA and state government policy settings".
The plans submitted to the EPA will not be subject the same public comment that occurred when the second train was considered in the original Pluto approval, an EPA spokesperson said.
A Woodside spokesperson said the company had correctly stated that primary environmental approvals were in place.
"These approvals allow for Pluto Train 2 and supporting infrastructure," the spokesperson said.
"As part of commencing design and construction activities associated with Pluto Train 2 under these existing approvals, secondary approvals are required for submission to the EPA, including a revised air quality management plan and greenhouse gas abatement program."
"Woodside will address the matters outlined in the EPA guideline in its GGAP."
If the EPA advises that Woodside's planned management of greenhouse gases from Pluto is inadequate environment minister Stephen Dawson has to choose between two uncomfortable options.
He could ask Woodside to come back with a better plan but risk wearing the blame for a delay to the Pluto expansion via development of the Scarborough gas fields and the ensuing jobs.
The alternative is to ignore the EPA and enrage elements within the Labor party who believe the government has been too accommodating to big gas at the expense of meaningful climate policy.