up to $3.5 million for projects to offset or mitigate the ...info.gladstonerc.qld.gov.au/meetings/20130305... · 3/5/2013 · Funding Community Infrastructure (social, economic,

Gladstone Regional Council Submission to the Coordinator-General on the Arrow Energy LNG Plant project Supplementary EIS 5 March 2013

Issue Category Issue Sub Category Commentary

Coordinator-General Action(s) Sought

Outcomes Sought From Action(s)

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1. Funding Community Infrastructure (social, economic, environmental) as an offset for project impacts that cannot be mitigated 1.01 Commitments to fund projects as offsets to project impacts that cannot be mitigated Arrow Energy has committed to invest “ up to $3.5 million for projects to offset or mitigate the impacts of the project (comparative with other LNG Proponents) “. Council is firmly of the view that the commitment level is too low (“$3.5m”), too imprecise (“up to”), the timing is not specific, and the target use of the funds is too vague. There is an implicit social contract required of significant businesses in Gladstone. Direct contributions towards social infrastructure, particularly infrastructure identified in the Gladstone Social Infrastructure Strategic Plan (SISP), are sought by Council. Expectations are that the proponent would make a significant direct contribution towards key projects identified in the SISP. This project is significantly larger than the LNG projects that have preceded it. The EIS states a CAPEX of some $20 billion however: a) all of the existing projects that that have commenced 2 to 3 years prior expect a CAPEX of up to $25 billion based on 2 LNG storage tanks and 2 trains and one pipeline; b) this project is looking at two stages for up to 3 LNG tanks and 4 trains whilst it is bringing at least two pipelines to the facility. The proponent has steadfastly refused to budge on its original stance which is apparently based on its belief that its project’s impact is similar to each of the existing LNG projects and therefore its level of commitment should be similar to that applied to the existing LNG projects. Council is firmly of the view that existing LNG projects have severely under-committed to the mitigation of impacts of the projects underway and should not be used as the benchmark.

That the Coordinator-General condition the proponent to a) identify and agree to fund, in consultation and agreement with Gladstone Regional Council, a project or projects within the Gladstone region to the value of $10 million; b) have in place the agreement with Gladstone Regional Council on the identified project or project within 90 days of FID.

Council seeks an outcome of the funding of a defined significant project or projects, within a funding agreement within a defined timeline, to ensure that project impact offsets are implemented in a timely manner and are commensurate with the level of impact on the Community by the project.





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A project with an estimated $7.5 billion CAPEX (WICET) made a commitment of $25 million towards a nominated social infrastructure project. LNG Projects to date with CAPEX in excess of $20 billion each have made commitments in the range of $11 million each for social infrastructure – one sixth of the WICET project commitment. Approvals for this project, if supplied, will be some 2 plus years after other LNG projects and costs have increased substantially for infrastructure in that period because of the high levels of development in the region. Existing projects have, in many cases, paid for significant works on infrastructure preparation for project use that will not required to be paid by Arrow Energy. 1.02 Gladstone Foundation The initial submission set out issues identified in the EIS of concern to Council and made recommendations in the context of existing approvals for similar LNG projects approved in recent years. Council has consistently expressed it dissatisfaction at the level of community infrastructure funding provided by the existing LNG proponents for the Gladstone Region. Council believes that contributions by LNG proponents should be commensurate with the scale and impact of the projects. The Gladstone Foundation cannot fund any significant community infrastructure with the inadequate levels of funds provided by industry on a voluntary basis to date. A total of $13.5 million has been contributed by the 3 existing LNG projects. Council believes that the contribution towards the Gladstone Foundation should be a minimum of $25m for the first two trains of this project. The Arrow LNG Plant EIS seeks to cover up to four trains of development on Curtis Island. In the event that trains three and four are proceeded with the contribution towards the Gladstone Foundation should be an additional $25m.

That the Coordinator-General condition the proponent to contribute a total sum of $25m to the Gladstone Foundation within 90 days of the proponent making its final investment decision. That the Coordinator-General condition the proponent to contribute a further $25m to the Gladstone Foundation within 90 days of the proponent commencing construction of trains beyond the initial two trains on Curtis Island.

Council is seeking an outcome that will reflect the significant nature of the project and its community impacts.





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1.03 Housing Contributions (Community & Social) Work with the ULDA to identify opportunities is named in the EIS. These meetings have been held and existing proponents have made commitments. Arrow has not been able to articulate a $ commitment at this time. Existing proponents have provided the funding for this through the Gladstone Affordable Housing Company as part of the $6.5m commitment per proponent to GAHC. The Supplementary EIS response states that “Arrow Energy will work with agencies such as the GAHC on how the $6.5 million funding commitment will be allocated.” This $6.5m of funding towards the GAHC is supported (It includes the funding towards the ULDA initiative in C26.12 which was $1.1m for each of the other LNG projects). In the event that this is not achievable with the GAHC the funds could be allocated direct the GRC for the Phillip Street Community Project which is focused on aged housing.

That the Coordinator-General condition the proponent to: a) obtain the agreement of the Gladstone Affordable Housing Company (GAHC) and Gladstone Regional Council as to the allocation of the $6.5 million commitment towards social and community housing within 30 days of Final Investment Decision; b) provide the funds within 90 days of Final Investment Decision In the event that it is agreed between the proponent, Council and the GAHC that funding towards the GAHC is not the preferred option for delivery of social and affordable housing these funds be re-allocated to the Phillip Street Community Project for the provision of aged housing (including independent and low and high care) to stem the flow of our elderly residents leaving Gladstone due to the unavailability of retirement village services locally.

Council requires an outcome that includes Council and the GAHC in the determination of the utilisation of these funds and the timely provision of these funds.

1.04 Housing rental assistance programs The commitment to 'Provide $1 million in financial assistance to the GRC for emergency rental assistance' needs discussion with GRC to determine the most effective allocation of these funds closer to the timing of the company making its final investment decision.

That the Coordinator-General condition the proponent to commit to obtain the agreement of the Gladstone Regional Council for the use of the $1 million commitment towards rental assistance in the Gladstone region within 90 days of FID.

Council requires an outcome that results in the timely provision of these funds and commencement of appropriate programs.





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1.05 ‘Brighter Futures Fund’ No $ commitment in the "Brighter Futures Program" or a specific level of commitment to the Gladstone Region has been made in this document. Given that the program covers all regions impacted on by Arrow in Queensland and New South Wales it would seem to be appropriate for a level of commitment to the Gladstone Region to be named.

That it be recommended to the proponent that the target amount of funds (a minimum $ amount over a set period of years for example) to bee provided out of the Brighter Futures Program for disbursement in the Gladstone Regional Council area be stated in the SIMP.

Council is seeking clarity as to the extent of the commitment proposed by the proponent for the Gladstone region.

1.06 Contribution towards Health Services The EIS suggests that Gladstone Hospital has sufficient capacity for current and expected demands of it, including any additional demands arising from the project impacts on the area. This statement is not agreed to by Council. The proponent has made no clear commitment in the SEIS towards improving mainland health services beyond a statement that it will consult with Queensland Health and contribute to the health services in the Gladstone region despite the expected project demand of such health services. Council believes the proponent has had adequate time to consult on this matter and should have, at this time, been able to detail actual actions that it would commit to if the project was approved.

That the Coordinator-General require the proponent to:

a) liaise with Queensland Health and the Gladstone Hospital Board to determine the additional impacts expected on the Gladstone Hospital and Gladstone region health service provision and to identify appropriate mitigation strategies for the impacts identified for inclusion in the SIMP for the project; and

b) commit to a financial contribution of $5 million towards the improvement of health services in the Gladstone region (targeted at services and facilities identified during such consultation) that will provide a lasting legacy to the Gladstone region after the initial period of construction.

Council seeks a specific outcome not a commitment to consult.





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2. Housing demand impacts 2.01 Definition of ‘local’ employee The term 'local' is mentioned a number of times in the EIS. This is used to describe parts of the project employees and if incorrectly described may discount the expected obligations for mitigating impacts by minimising the apparent impacts on available housing in the community. As this term is used in reporting on impacts off the project and is the basis of many commitments generally conditioned of such projects it is vital that this be reasonable and correct. In the response the Proponent has advised that “For the purposes of the SIA, local workers were assumed to include workers residing within the GRC area prior to the commencement of the construction stage of the project.” Council does not believe this approach to the definition is fair or reasonable.

That the Coordinator-General stipulate in the conditions for the project that, for any document or plan required to be submitted for comment or approval, including, but not limited to, the Social Impact Management Plan and the Integrated Housing Strategy, the term 'local' when applied to employees engaged to work on the project should only refer to people who: a) were domiciled in the Gladstone

Regional Council area (OR - within 60km of the Gladstone CBD) for in excess of six months continuously prior to being engaged to work on the project; and

b) had a residential address as their principal place of residence within the Gladstone Regional Council Area (OR - within 60km of the Gladstone CBD) for in excess of six months prior to being engaged to work on the project.

Council wants an outcome that ensures that the term ‘local’ as applied to all conditions of the project where applied to employees of the project is consistent with the term as it is generally understood in statistical terms when applied to people considered to be residents of the area.





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2.02 Timely & appropriate levels of provision of housing for project workers Estimates from the previous projects Coordinator-General approvals had placed the number of mainland house expected to be provided in the range of 250 per project plus additional commitments to social and community housing. The reality has seen between 45 and 90 houses per project being accepted by the State Government in Integrated Housing Strategies lodged by proponents. Some projects are still to implement their commitments some two years after commencing. Delays in housing provision and the low numbers of houses have contributed significantly to the high housing stress being experienced in the Gladstone Regional Council area. The commitment to provision of housing of up to 130 houses with up to 90 to be provided during the construction phase and the qualifying statement “Based on the state of the market to meet this project generated demand…” indicates that the commitment being made is: a) imprecise in terms of what actual number; b) inadequate in terms of total numbers if it is to address project workers coming into the area to reside in residential housing for the duration of construction works (3 to 4 years) – Note that supplementary traffic management plan (appendix 13) mentions some 500 mainland based staff in addition to the up to 600 ‘locals expected and mentions an 11 month delay in camp availability on the island with full capacity being reached 24 months after FID ; and c) inadequate in terms of timing – houses must be provided in time to meet workers demands for housing – not be reactive. Strategies proposed are considered to be inadequate in dealing with expected impacts of additional housing demands from the project.

The Coordinator-General condition the proponent to: a) provide mainland housing for 50% of the

projects workforce taking up residence (i.e. residing in residential housing, units or flats) in the Gladstone Regional Council area for a period of six months or more during the project duration; and

b) provide such housing in a timely manner so that it is available at the time that the demand for such housing by the project workforce eventuates.

c) lodge an Integrated Housing Strategy six months before construction commencing for approval by the Coordinator-General.

d) ensure such strategy is to clearly set out project accommodation demands and actions to be undertaken (including timing and method of provision of accommodation needs) to meet the project accommodation needs;

e) obtain the agreement of the Gladstone Regional Council to this strategy before lodgement with the Coordinator-General; and

f) not commence construction until such strategy is approved by the Coordinator-General; and

g) not continue with the project construction if actions in the strategy are not implemented in accord with project needs and the timelines in the approved strategy.

These conditions are sought to avoid: a) a repeat of the outcomes of existing projects high levels of damage to the community that has arose out of the poor levels of commitment and poor levels of timely implementation of project housing provision with existing projects underway in its region. b) poorly worded conditions with inadequate definitions and no clear outcomes having been stipulated; and c) the ability of Project Proponents to avoid reasonable commitments towards the provision of mainland housing for staff housed in residential accommodation on the mainland by a combination of classifying such workers as ‘local’ and/or not classifying them as ‘project workers seeking to settle’ – the undefined term used by the government in previous approvals.





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2.03 Restrictions sought on utilisation of existing residential housing This region has already experienced significant social and business impacts because of housing shortage (Both for purchase and rental). Better mitigation of this issue should now be sought. It would seem to be clear from existing projects that delays in approval of Integrated Housing Strategies and the lack of clear commitments to put accommodation in place for the projects needs in a timely manner( so that the projects impacts on the local housing market -purchase and rental - are minimised) has resulted in significant negative effects on the community. The message seems to be clear, and Council has consistently sought to advance this message “Ensure that accommodation requirements for the project are met by the project and are in place at the time of demand for that accommodation” Council remains concerned that in the Supplementary EIS the project proponent still advises that the project can have an impact of “an increased use of temporary accommodation” and rate this as a ““low significance” residual impact”. The response surmises that an “early works workforce accommodation strategy to be finalised four months prior to construction commencing” and that this is sufficient lead time to allow for appropriate mitigation measures to be put in place. This is too late. The proponent has acknowledged an awareness of “some workers moving to resource areas with the intention of obtaining employment” but does not accept that that this “source is a major contributor to pressure on the rental market.” In keeping with the proponents definition of “local” the impacts of such workers are ignored in this EIS and no provision is made by the Proponent to measuring the quantum of such effect or mitigating the impacts. Council suspects, but is unable to quantify, that the level of project workers who have moved to the Gladstone region (with or without families/partners) for existing projects who utilise housing stock within the community and/or are classified as “local” by project proponents is significant and has had a massive bearing on the negative housing impacts in the region.

That the Coordinator-General condition the proponent to put in place accommodation for its workforce in advance of the projects needs and minimise the level of project employees that are accommodated in existing facilities not specifically constructed to cater for construction staff. That the Coordinator-General:

a) Continue its housing monitoring program;

b) incorporate a requirement for this

proponent to participate in quarterly reporting requirements during the construction phase; and

c) Seek funding from the proponent for

independent OESR research into the measurement of the impacts on housing demands in the Gladstone Region for this project.

The outcomes sought by Council is quite specific a) Condition the proponent to provide for its project workforce accommodation needs before or at the time those needs occur. b) have a housing monitoring program in place that details the real situation on the ground with respect to project workers taking up residential housing stock in the region.





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2.04 Methodologies utilised to estimate housing demands In the EIS the estimate of 'only 87 members of the construction workforce, who choose to seek accommodation in the study area, will bring their families, with the remaining 380 workers being single and predominantly male due to the nature of the employment opportunities generated in the construction phase' is not considered to be a sustainable argument. Recent studies by mining companies in the Pilbara state that FIFO workers are "largely family orientated individuals, with 75% of FIFO employees being in long-term relationships and half having children ". [A Matter Of Choice - Capturing The FIFO Opportunity In Pilbara Communities, Chamber of Minerals and Energy of Western Australia, 2012] Given the longevity of the construction aspect of this project, particularly if the third and fourth trains are constructed, it is not considered reasonable to suggest that only 87 out of some 3,500 construction staff (at peak) would seek to be domiciled in the area (i.e. residing on the mainland in residential housing - house, flats, townhouses, caravan parks etc for six or more months in the year). How this 467 (380 plus 87) or 14% is arrived at from a base of a peak construction workforce of 3,318 is also not provided. In the Supplementary EIS clarity as to how the numbers of project employees accommodated in housing (not camps) on the mainland were arrived at still has not been provided. Direct experience of Council with existing projects has suggested that the real numbers are much higher than project proponents are prepared to admit and inaction on the government’s part to get clear independent data on this has assisted in keeping this information obscured. As these figures directly impact on the commitments to wards housing that the project would normally be asked to provide it is important that Council and the government have clear unambiguous figures provided. The EIS and supplementary EIS continue to not provide these figures. Council can not have any confidence that the mitigation measures proposed are reasonable or appropriate.

That the Coordinator-General condition the proponent to: 1. Provide details of:

a) how the estimate of '87 members of the construction workforce, who choose to seek accommodation in the study area, will bring their families' was arrived at by the proponent;

b) confirmation that this 87 is the only employees in the construction phase (out of all project staff engaged on the project) that are expected to be housed in mainland accommodation; and

c) quarterly estimates of project workforce numbers using the pro-forma table set out in Appendix 1 to this schedule;

2. Set out clear timelines, methods and commitments to the provision of accommodation to meet the projects accommodation needs as identified in the table to be provided in condition 1(c) above along with details of contingency planning if such commitments can not be kept due to circumstances beyond the control of the proponents; And

3. Ensure that utilisation of existing accommodation (Houses, flats, units, hotels, motels, caravan parks etc) in the Gladstone Regional Council area (that have not been purpose built for the housing of construction staff for the project) is minimised.

Council is seeking an outcome of clarity and transparency with respect to the estimated profile of the project workforce and the assumptions used to arrive at expected project housing needs.





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3. Local Businesses 3.01 Skilling needs of workers In the EIS Council queried the effectiveness and veracity of 'developing a recruitment plan to identify what positions will be targeted without negatively impacting on the availability of local services' given the skills drain that has occurred to date without any effective strategy to negate/minimise this effect having been identified or implemented. Whilst the Revised SIMP identifies a number of strategies and stakeholders the ones suggested by Council have not been included and the identified options have not been included in this strategy.

That the Coordinator-General condition the proponent to liaise with local industry groups including Gladstone Industry Leaders Group (GILG), Gladstone Chamber of Commerce and Industry (GCCI), Gladstone Engineering Alliance (GEA) and the Gladstone Area Promotion and Development Limited (GAPDL) in the Gladstone Region to identify a range of strategies that will minimise loss of critical permanent staff in local businesses for short term construction work including options such as:

- staff sharing and secondment arrangements that do not result in permanent critical staffing loss;

- training and mentoring for individuals; - training and mentoring for suppliers;

and - accommodation subsidies for fixed

income employees in service and supply sector of $ (more than the other projects contributed).

Council is seeking an outcome that includes liaison with the bodies mentioned and consideration of the options presented.





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3.02 Increased accessibility to project supply chain Council had concerns that the Economics area of the EIS and the resultant draft commitments made does not adequately address concerns of local (defined as local to the Gladstone Region) businesses, particularly small businesses, with respect to their expectations of being included in the supply chain for meeting the needs of the project. The scale of the projects demands and the resultant packaging of contracts often dwarf the capacity of small business to participate however such business could participate if demands were broken down into smaller lots. Council acknowledges that in the SEIS the intent in the revised SIMP strategies is essentially to “encourage contractors to source local goods and services where possible” and to put in place programs to ensure local business is aware of knows how to participate in the project procurement systems. Council believes however that local business can be stymied in competing for the provision of services because of the sheer scale of service provision being sought and the lack of consideration to breaking up service supply to manageable lots that can be managed by local businesses. It is acknowledged that the logistics of doing this in large scale projects is not always achievable.

That the proponent: a) give specific consideration in the development of its procurement policies and in its contractual arrangements for the project to enhance the prospects of smaller local businesses participating in the supply chain for meeting the projects needs; and b) work in partnership with Industry Capability Network (Queensland) to meet its obligations under the Australian Industry Participation Plan which align with the Queensland Local Industry Policy specifically in the areas of:

Building local supply capability Providing full fair and reasonable

opportunity to local suppliers

Council seeks a stronger policy from the proponent to its contractors to increase the ability of local businesses to participate in project services provision.

4. Waste Management 4.01 Clarification of project waste levels & Requirement for a project waste management plan This EIS implies that agreement of the Gladstone Regional Council has been obtained regarding the disposal of solid waste at the Benaraby Regional Landfill. Discussions regarding this, particularly given the quantities proposed, will need to be held. From the Supplementary EIS Council notes that the Proponent proposes to refer the production and implementation of the projects Waste Management Plans to “Contractors”. This potentially will involve Council in consultations with a myriad of Contractors. Council is of the view that the Waste Management Plan for the

That the Coordinator-General condition the proponent to a) update the waste management plan for the project (including the provision of more accurate projections of waste type and quantities); b) seek approval of this waste management plan from Gladstone Regional Council; and c) ensure that its project contractors

Council seeks outcomes of: a) clarity and consistency of understanding of the levels and types of waste expected to be produced; b) agreement as to the where and what types of waste will be accepted by Council at its facilities; and c) minimisation of Council involvement in contractor waste management





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project should be prepared by the Proponent for the Project (one plan) in consultation with and with the approval of Gladstone Regional Council.

preparation of waste management plans are in accord with the waste management plan for the project approved by Gladstone Regional Council.

plans by ensuring that the project proponent ensures that such plans are in accord with the approved project waste management plan – not Council.

4.02 Implementation and enforcement of waste segregation Council sought in it submission on the EIS to understand what processes are in place to ensure that wastes are not mixed, i.e. waste concrete with general construction and demolition waste? This will need to be developed and advised to Council as in commitment # C35.05. Also a query as to who will oversee this. In the SEIS the response has not specifically addressed Council’s concerns and/or stated a commitment that addresses Council’s concerns. Council now has significant experience suggesting that waste segregation practices currently in place for projects such as these are not resulting in appropriate delivery of segregated waste to refuse sites.

That Coordinator-General condition the proponent to ensure that processes acceptable to Gladstone Regional Council for the segregation proper delivery of the segregated waste to approved refuse sites and minimisation of waste and are included in the project Waste Management Plan and are conditioned by the proponent in all contractual arrangements with sub-contractors involved in managing project waste.

Council is seeking an actual outcome that will minimise waste to landfill from the project.

5. Traffic & Transport 5.01 Council to approve relevant plans (not just be consulted) Relevant management plans are also required to be provided to Gladstone Regional Council (For local roads traffic) for approval. Commitments in the EIS or SEIS to obtaining approval from Council for the relevant plans have not been made.

That the Coordinator-General implement similar submission and approval requirements as for the other LNG projects with respect to plans such as the Gladstone Logistics Plan, Road use Management Plan, Road Impact Assessment, Traffic Management Plan and Road Infrastructure Agreement and nominate Council as the agency with jurisdiction with respect to approvals related to plans involving the project use of Council controlled roads.

Council is seeking an outcome that allows Council to determine the appropriate project uses and applicable conditions for use of Council controlled roads.





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5.02 Project to utilise Council adopted processes It should also be noted that Gladstone Regional Council has an adopted Pavement Impact Assessment Model which it requires to be populated and provided to Council for the assessment of impacts on Council's sealed road network. No commitment has been made to enter into a Road Infrastructure Agreement with Council for the project use of Council roads within a specified time.

That the Coordinator General condition the proponent to:

a) enter into a Road Infrastructure Agreement with Gladstone Regional Council similar to the agreements entered into between Gladstone Regional Council and other LNG project proponents prior to the commencement of project construction; and

b) require the submission of a completed Pavement Impact Assessment (utilising the model adopted by Gladstone Regional Council) for assessment and approval by Gladstone Regional Council within 90 days of FID.

That the Coordinator- General emphasise in approval conditions for the project that all project generated traffic must be reported on in the documents required to be submitted for consultation and/or approvals.

Council is seeking an outcome of consistency with other project approvals and timely commencement of the processes involved in these agreements.





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5.02 Car/bus inter-change points 1,000 external personal commuting daily to the mainland launch site is considered to be too high. (Page 26 shows this as some 8,760 vehicle movements weekly generated by the project of which 7,340 are expected to be private car movements). Council has experienced little commitment from existing project proponents to providing mainland car/bus interchanges along bus routes established by the projects to pick up project workers housed throughout the community. Whilst this project is examining the establishment of one significant car/bus interchange point experience with existing projects has shown that this is not always practical to enforce for all project workers unless appropriate mechanisms are in place.

That the Coordinator-General condition the proponent to: a) put in place car/bus interchange points

for the collection of project staff housed on the mainland by bus; and

b) actively discourage individual worker vehicle trips to Mainland/Curtis Island discharge points and the tunnel project worksite and other project worksites by:

limiting workforce parking at such sites; and

c) making it a condition of employment of staff that they utilise project provided buses for travel between accommodation and work sites.

Council is seeking an outcome that will minimise traffic levels of workers too and from project sites and minimise community impacts along project bus routes.

5.03 Provision of cumulative project data for road use No cumulative impact data for the Council controlled local roads network has been provided by Arrow to date. Project data is required from the proponent.

The Coordinator-General condition the proponent to provide estimated traffic data for all local roads (in addition to State controlled roads) in the Gladstone Regional Council area for this project and the related projects from Arrow Energy and its subsidiaries (Arrow Bowen Pipeline and Arrow Surat Pipeline projects) in the format utilised in the traffic data recently sought and obtained from the QCLNG, APLNG and GLNG projects; and

Council seeks to understand the impacts on its road systems and to manage potential conflicts in a consistent manner as that utilised with existing projects underway;





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5.04 Determination of vehicle routes The EIS makes it clear that the proponent has not seriously considered Council's advice to utilise Don Young Drive/Red Rover Road in lieu of the Dawson Highway. It also did not mention the Calliope River Road link. This needs to be corrected as the most practical legal route will be the one that is used by transport operators and it is Council's preference that these roads be used in lieu of the Dawson Highway section through the residential areas and shopping areas for heavy transports. In the SEIS the comments were noted. Council still requires company to liaise with and seek Council’s approval of proposed routes as this commitment has not been made by the proponent.

That the Coordinator-General condition the proponent to:

a) liaise with, and seek the approval of, the Department of Main Roads and Gladstone Regional Council for routes proposed to be used by heavy vehicle movements for the project;

b) ensure that contractors be required, under their contract conditions, to use the routes agreed to by Gladstone Regional Council and the Department of Main Roads; and

c) Ensure that these routes, and the associated traffic, be reflected in the Pavement Impact Assessments and Road Impact Assessments submitted for approval to Gladstone Regional Council and the Department of Main Roads.

Council seeks an outcome that will ensure project traffic is correctly informed of the preferred routes for heavy traffic and that such usage is correctly reflected in project impact reports.

5.05 Parking of heavy vehicles in Gladstone region Uncontrolled parking of oversize vehicles, B-Doubles in urban and business district areas on road verges and other non-approved sites has been a problem for Council. Council is experiencing significant numbers of heavy vehicles being parked in residential, commercial and industrial area, often near mainland accommodation facilities (Motels etc)used by the vehicle drivers. The staffing resources to control such inappropriate parking (Both Police and Council regulatory staff) is extremely limited and unable to cope with the levels of complaints being received particularly given the outside of normal hours timing of most of the infringements. In the SEIS this is noted however no commitment has not been made by the proponent to the specific issues raised by Council in this section.

That the Coordinator-General condition the proponent to:

a) require all contractors engaged on the project to provide details of legal locations for heavy vehicle parking areas assigned for the parking of their vehicles whilst the heavy vehicle drivers are accommodated in the Gladstone Regional Council area;

b) condition such contractors to provide transport from those locations to and from accommodation locations for such drivers; and





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c) condition such contractors to ensure that heavy vehicles are not parked in the Gladstone Regional Council area in areas other than approved legal areas for such parking.

5.06 ILS Contribution to address issues of flaring impacts on aircraft safety Page 40 28.5.3 Air Services Notes that proponent will 'Provide a share of funding toward the new instrument landing system at Gladstone Airport upon Project FID.' Arrow Energy is to pay $2,625,000 plus GST after receipt of tax invoice from GRC following decision on FID for its share of the cost of the ILS. Within 7 days of receipt by Council this money will be distributed to the GLNG, APLNG and QCLNG proponents.

That the Coordinator-General condition the proponent to pay Gladstone $2,625,000 (plus GST) within 30 days of after receipt of tax invoice from GRC following its decision on FID for its share of the cost of the ILS as its contribution towards the cost of mitigating the impacts of gas flares required for the project.

Council seeks and outcome which is in accord with the agreements entered into.

6. Environmental issues 6.01 Calliope River dredging impacts The proponent's proposed dredging of the Calliope River mouth (specifically the bar at the river mouth) will alter the flood dynamics of this river. This is one of two options being looked at by the proponent for its mainland Materials Offloading Facility (MOF). The other proposed location is at Fishermans Landing. Representatives of the proponent did respond to a question on this at a recent public consultation meeting in Gladstone advising that the dredging would have an effect of up to 0.8m in height change at low tides (0.8m less) tapering off the further upstream you go in Calliope River. The implications for Council are that Council will need to revisit its flood models for this river. This should not be at a cost to ratepayers. Compensation from Arrow to fund the revised flood modelling required, should they proceed with this option will need to be sought. The proponent has made no commitment to undertaking what Council has requested in its SEIS.

That the Coordinator-General condition the proponent to, in the event that the project does proceed with the construction of a mainland Materials Offloading Facility at the Calliope River mouth which will involve dredging of the Calliope River, pay Gladstone Regional Council's costs for the updating of flood studies with respect to the Calliope River flood plains so that such studies can take account of the changes in the Calliope River that is expected to occur.

Council seeks compensation for the costs of having to upgrade this study of the dredging occurs.





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7. Other Social Impacts Mitigation 7.01 Participation in Gladstone Liquor Accord Council in it submission on the EIS suggested active participation in the Gladstone Liquor Accord and standardised responses for licensed premises on the island in keeping with the Accord. Council understands that there is difficulty getting this commitment from existing LNG Project proponents and sub-contractors. Its revised “SIMP Action Plan: Community Investment and Social Wellbeing” section makes no mention of actioning this reasonable request even though the island accommodation facility is also expected to incorporate a licensed facility. Such Code should also include reference to and commitment to the codes in place in the Gladstone Liquor Accord - i.e. any transgression in venues covered by the liquor accord resulting in banning of access to licensed premises should also result in a banning of access to the licensed venue on the project camp licensed facility.

That the Coordinator-General condition the proponent to a) coordinate with and actively participate in

the Gladstone Liquor Accord with respect to its workforce and its licensed premises (including licensed premises run by contractors on its behalf, at Temporary Workers Accommodation facilities on the mainland and on Curtis Island); and

b) require its contractors to utilise Gladstone Liquor Accord standardised responses in the standard operating procedures of the proponents licensed premises; and

c) require its contractors to include this in the relevant Code of Conduct for employees.

Council is seeking an outcome that standardises the management of provision of alcohol from licensed premises within the community.

7.02 Addressing the issues of negative public image impact for region from dredging Dredging works associated with the LNG projects have, rightly or wrongly, been associated with significant negative publicity for the Gladstone Region, particularly the Gladstone Harbour. This is impacting on the sense of liveability and the perceived high recreational value of the harbour lifestyle for residents and potential residents of the area. This unforseen impact of the LNG projects needs to be addressed. The response provided in the SEIS, whilst positive, is non-committal with respect to specific identifiable actions regarding addressing negative image issues.

That the Coordinator-General require the proponent to incorporate funded strategies within the SIMP for the enhancement of the image of the Gladstone Region to counter the negative publicity to date associated with aspects of the LNG project and related projects such as dredging works in the Gladstone Harbour.

Council is seeking an outcome which will enhance the image of the region to counter the negative publicity that has been received.





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7.03 Planning and investment in social infrastructure needs for the region Planning and Investment in social infrastructure needs to be undertaken prior to any construction commencing and any workforce for the project arriving in the Gladstone region. The revised SIMP uses timelines of “within 12 months of awarding the EPC contract”, “24 months prior to the completion of construction” etc for the development of strategies to address impacts. This remains unacceptable to Council. Strategies should be in place before impacts commence and actions implemented in a timely manner to mitigate impacts not just monitor and react when it is too late to implement actions that will mitigate impacts.

That the Coordinator-General condition the proponent to undertake planning and Investment in social infrastructure needs prior to any construction commencing and prior to any significant workforce for the project arriving in the Gladstone region (Significant being of the order of 400 employees).

Council is seeking an outcome that recognises that investment on social infrastructure needs to clarified and commenced with the same level of urgency that applies to implementation of the project after approval.

8. Cumulative impact Issues 8.01 Arrow LNG is part of a combined project which also includes Arrow Surat Pipeline and Arrow Bowen Pipeline projects Cumulative Impacts of this project with The Arrow Bowen Pipeline Project and Arrow Surat Pipeline Projects needs to be identified and mitigated by the proponent of this project given that these projects are essentially the one project. After perusing the SEIS Council does not withdraw its requirement that this project be considered in conjunction (cumulatively) with the other two projects in order that its consideration be on par with the three similar (though individually much smaller) LNG projects that have been approved to date. The proponent is quick to say its mitigation measures should be judged in accord with other LNG projects approved to date but seeks to distance itself from a combined responsibility for the combined impacts of its separate projects. The proponent also acknowledges that cumulative impacts may not yet have been assessed in its response. Its response also does not acknowledge the requirement to address cumulative impacts with regard to other projects underway or proposed in the area.

That the Coordinator-General condition the proponent to consolidate the impacts from the Arrow LNG Plant project, Arrow Surat Pipeline project and the Arrow Bowen Pipeline project, particularly with respect to traffic, housing and other social impact related issues and prepare cumulative impact analysis and mitigation strategies accordingly. That the Coordinator-General condition the proponent to participate in and contribute to cumulative impact studies incorporating the other significant projects in the Gladstone Regional Council area.

Council is seeking a consistent outcome that appropriately addresses cumulative impacts.





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8.02 Other Projects Cumulative Impacts In the EIS Council was concerned that the Cumulative workforce projections in Fig 32.1 and especially Fig 32.2 seem to be based on outdated information and are therefore not reflective of current realities. The cumulative workforce numbers still appear to be significantly dated. The proponent in discussions has indicated that it will be in a better position to understand these numbers when it has completed the identification of its EPC contractors.

That the Coordinator-General condition the proponent to update these projections and figures for inclusion in the subsequent SIMP and Integrated Housing Strategy to be submitted for comment by agencies (including Gladstone Regional Council) and subsequent assessment for approval by the Coordinator-General.

Council seeks a clearer more consistent analysis of these projections.

9. Technical Issues – approvals Legislative Requirements etc 9.01 Management of plan approvals at project level (not at sub-contractor level) Council has experienced the submission of multiple plans for approval for different aspects of LNG projects with plans in some instance coming from contractors to proponents for parts of the project when Coordinator-General approvals only envisaged a consolidated document for the project. In some cases there has had to be a complete re-writing and re-submittal of documents. In other cases Council has been presented with documentation that covers areas outside of it jurisdiction without clear referencing to the parts that are in the Council area. These instances involve substantial allocation of Council resources for the re-analysis and further review of these documents which was not envisaged in the levels of funding provided for Council processing of these documents. Council acknowledges the comments made but notes that the proponent has made no commitment to the process set out in Council’s recommended condition.

That the Coordinator-General condition the proponent: a) to ensure that, where the provision of plans

for review and/or approval by agencies is required and such plan incurs no separate assessment fees from that agency then the proponent is to ensure that the plans submitted to the agency is i) for the agency area only and ii) consolidates all the projects aspects within such plan. (Examples are the Gladstone Logistics Plan, Road use Management Plan, Road Impact Assessment, Traffic Management Plan etc);

b) to ensure that its contractors sub-plans are consistent with the approved plans from the relevant agency; and

c) to, where plans are required to be re-submitted, pay the agency the reasonable costs of such further review.

Council seeks and outcome that would encourage the proponent to appropriately target the reports and plans presented for approvals and minimise the administrative workload on agencies.





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9.02 Funding of project coordination plan assessment and approval costs Costs of assessment of project plans, previously estimated at $150,000 per project for Gladstone Regional Council (2 units @$75,000 per unit) have increased. This project is also significantly larger than previous projects (four trains rather than 2 trains) plus increases in costs since previous approvals. No commitment has been made by the proponent to address Council’s concerns in the SEIS.

That the Coordinator General increase the proponent contribution towards agency assessment costs for plans submitted under the project approvals to $87,500 per unit and allocate 2 units to Gladstone Regional Council to be paid within 30 days of submittal of the first plan for approval or comment to Council and an additional 2 units to be paid at the time of submission of documents for the commencement of the construction of the third and fourth trains.

Council seeks to recoup a larger part of its costs in assessment of plans and liaison with the project.

9.03 Currency of data used for various planning documents Outdated statistics being used in the EIS General reliance is made in the document on 2006 census numbers throughout. These statistics are 'time damaged' particularly given the level of growth that has occurred since that time. Council acknowledges the advice in the SEIS that “Future updates of the SIMP will also continue to be informed by the most recent data as it becomes available.” Council notes however that, despite Council providing clear statistical data on housing rental changes in its May 2012 submission on the EIS, this data, despite its currency and availability from an independent source, was not utilised in the subsequent SEIS analysis update provided in February 2013. This has undermined Council’s confidence in the stated commitment made by the project proponent in its Supplementary EIS. The revised SIMP continues to ignore the RTA statistics that have been available continuously for each quarter and were provided to the proponent by Council in its submission. As a result the report and analysis in this area remains inaccurate, biased and deliberately seeks to underplay the extent of impacts of current projects on housing prices and housing availability.

That the Coordinator-General stipulate in any approval conditions that that proponent must utilise the most current statistical data available, particularly more recent statistic estimates from the OESR, in all documents to be prepared for approvals by various agencies. That the Coordinator-General condition the proponent to revise its assessment of project impacts on housing prices and rentals utilising the most current data available n this area (specifically in the rental areas as provided by Gladstone Regional Council).

Council seeks to ensure that reports relying on statistical analysis for the project do utilise the most recently available data.





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10. Other matters 10.01 Subsequent decisions to proceed with trains 3 and 4 In the event that there is a decision to proceed to trains three and four all plans identifying impacts of the projects will require review and re-submittal.

That the Coordinator-General condition the proponent to update all plans setting out impact analysis of the project for submittal to the various agencies for approval six months before commencement of the additional trains beyond the initial two trains.

Council seeks an outcome that will allow it to appropriately respond to the revised impacts of any decision to proceed with the additional trains.

10.02 Conditions by Coordinator General to require specific actions with specific outcomes. Lack of condition effectiveness where conditions only require 'consideration' by proponents or allow commitments in terms of statements such as “up to…” will be provided. Council notes that where previous projects were asked to 'consider' contributions to the Gladstone Foundation there was a significant delay in any commitments being made by proponents. At the time of making this submission the Gladstone Foundation had not received any funds despite proponents giving consideration to this request in their project conditions.

That the Coordinator-General frame all of its approval conditions so that the conditions are required to be met by a specific action for a specific outcome (not just consideration of a matter or by reference to phrases such as “up to”) and that such outcomes be required to be achieved in a defined timeline.

Council seeks outcomes out of conditions that is clear and unambiguous as to time and extent of the actions sought.





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10.03 Definition of ‘single status FIFO workers’ It was not understood how Arrow stated in its EIS that it could specify that its project workers be 'engaged on contracts specifying that their position is FIFO and single status'. This seems act as an artificial barrier to stop workers who may wish to relocate to the region and settle here from doing so. Such a stipulation would appear to be illegal in Australia. The project proponent explained in its SEIS that: “The percentage of single status FIFO workers during the construction phase that would seek to be relocated to Gladstone was based on the following assumptions:

Employment contracts will specify the position is FIFO The positions are trade specific and likely to be short term

in nature FIFO rotations will not be attractive for family households

with two or three weeks on and one week off FIFO contracts will be based from the current home location, ad will not include relocation of workers families. As such, workers will be flown to site unaccompanied, and returned to their home locations at the conclusion of their shift. Their status as single or otherwise is not relevant for the contract.” It is clear that FIFO is not a “choice” as the recent reports on FIFO by the construction industry would have us believe. Also interesting that the proponent would comment that FIFO rotations are not attractive for family households as the construction industry is seeking to argue otherwise to justify the large percentages of FIFO workers who do have families. To creatively describe workers with families as “single” is merely an artificial device to divorce the company from any obligation to provide family housing in the region.

The Coordinator-General require the Proponent to a) not describe workers as “single” merely because the proponent requires such workers to reside in single accommodation; b) not preclude project workers from choosing to move to the region upon gaining employment with the project; c) address the provision of appropriate accommodation for project workers who choose to relocate to the Gladstone region whilst employed on the project.

Council is seeking outcomes that ensure that: a) common meanings of words such as ‘single’ are not distorted by artificial definitions; and b) the dignity of workers in being to choose their place of residence in line with their place of employment so that it can align with them having a home life with partners and/or family is preserved.

Documents

up to $3.5 million for projects to offset or mitigate the ...info.gladstonerc.qld.gov.au/meetings/20130305... · 3/5/2013 · Funding Community Infrastructure (social, economic,