By Nicholas D’Alonzo

Photo provided by 350 Borloo Perth


The Perdaman Urea Project on the Burrup Peninsula is expected to be the largest, if not the only, user of Woodside’s Scarborough gas in Western Australia, and so is an important target of the “Say No to Scarborough Gas” campaign.

Late last year the Perdaman Urea project was put forward by the Environmental Protection Authority (EPA) for public comment on their determination that it could go ahead. Many people, including 350 Boorloo Perth, put in submissions to the EPA.

In January 2022, the EPA Appeals Convenor’s Report was published, addressing community concerns, and giving advice to the Minister for Environment about whether they should deny the project or require additional changes to the proposal.

The Appeals Convenor’s Report focused on 4 key issues: climate change impact, impact on Aboriginal cultural heritage sites, effects on human health, and land clearing on the site, with a quick comment on some issues raised by appellants that the reporters considered were outside the scope of the EPA’s assessment.

The report quickly dismisses effects on human health as it is located far from residential areas. The EPA guidelines are to limit the land clearing on the site and leave areas of important vegetation for the wildlife. The footprint of the plant is overall not very large and so it is possible to have both vegetation corridors and flora left on the site.

Impacts on the Murujuga Petroglyphs

The potential impact on the Murujuga petroglyphs is of particular concern as the rock art is of significant cultural and spiritual value to Traditional Owners, and of significant state, national, and international heritage value. This is the issue that received the most criticism in the report.

The EPA Report 1705 states, “The EPA considers that there may be a threat of serious or irreversible damage to rock art from industrial air emissions (in particular, the urea particulates and NH3) from the proposal, accelerating the natural weathering.”

Both the EPA’s and the Convenor’s reports put a lot of importance on potential nitrous emissions. But the Convenor’s report suggests tighter requirements and even a delay and reanalysis of the plan by the EPA once new scientific research on potential damage to the rock art is completed.

“We have therefore recommended that the proponent be required to ensure that key technical aspects of the development of the air quality management plan (AQMP) are subject to independent peer review to provide guidance to the CEO before the plan is approved.

We also recommend that the time for reporting exceedances of threshold criteria are reduced from 7 days to 48 hours.”

Greenhouse Gas Emissions

The potential greenhouse gas emissions from this project is a major concern for many of the people that made submissions and is a major concern for 350 Boorloo Perth. The Convenor’s’ Report makes for interesting reading on this topic. It clearly lays out the threat of climate change to Western Australia.

It is scathing in its assessment of the world’s failure to make decisions consistent to 1.5 degrees Celsius, or to even meet the Paris Agreement goals of limiting global temperature rise to 2 degrees Celsius.

This results in something of a conflict when the very clear evidence of the impact of climate change on Western Australia collides with what appears to be a toothless EPA decision on this issue.

The EPA finds itself unable to properly rule on this issue and instead defers to the Minister for the Environment. “It follows from the above that the EPA considers that the acceptability of the GHGe from this proposal is a matter for the decision makers under section 45 of the Environmental Protection Act.”

Perdaman has a plan to reach net zero emissions by 2050 in a linear fashion. But even without thorough planning on how the company will achieve it, the EPA has considered this to be okay under their guidelines.

The Appeals Convenor’s Report recommends that the Minister for Environment should require some sort of reduction in emissions elsewhere, either some form of offset or reductions in other parts of the state’s economy. However, once again, this remains at the discretion of the Minister.

As for the relationship of the Perdaman Urea Project to Woodside’s Scarborough gas project, the EPA states:

“In relation to the potential for this proposal to exacerbate GHGe through other proposals (such as the Scarborough proposal of Woodside Energy Ltd), the EPA noted that it is not able to consider the implications of recommending the approval of this proposal on other current and future proposals in the region as that is not within the scope of its assessment.”

“Not within the scope of this assessment” is a common refrain as the EPA can only assess the projects put before them regardless of what the alternatives are for Perdaman.

You can download the Appeals Convenor Report at the webpage below.


It is likely that the Perdaman Urea Project will be allowed to go ahead by the Minister for Environment and Climate Action, currently Reece Whitby. There is potential for additional requirements on nitrous emissions to protect the petroglyphs.

However, I do not think that the Minister will impose greater greenhouse gas emission reductions on the project and will be satisfied with a linear reduction to net zero by 2050.

What this Appeals Convenor’s report clearly shows is that bureaucratic environmental protection simply is too limited to reduce greenhouse gases alone.

Environmental activists such as volunteers for 350 Boorloo Perth must make themselves heard and put pressure on politicians and corporations to stop enabling the expansion of fossil fuels when we are in need of drastic action on climate change.

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