Mod 2 - Extension of Time

1. The area of the Illawarra upper escarpment is completely unsuited to CSG mining consisting almost entirely of SWA drinking water catchment "Special Areas" and dams, National Parks and other environmental preservation or conservation areas. It is also a high risk bush fire area which is exacerbated by its highly combustible peat base: This months bush fire ran through and burnt out APEX drill sites 9 and 10. This is a unique and highly sensitive upland swamp area, whilst production CSG mining is an extensive and environmentally invasive industrial activity that will result in 150+ well pads and associated above ground infrastructure on the escarpment. This activity will permanently damage and or change the ecology.

2. The risks of CSG mining are now well documented (especially those relating to water contamination) and current NSW CSG control legislation acknowledged as inadequate for managing this risk - The NSW Premier reconfirmed this only yesterday in his interview with Alan Jones. The revised NSW Government regulatory framework has yet to be released and it would be improper to proceed prior to APEX being assessed against these requirements.

3. The area is already under threat from massive coal mine expansion using long wall mining technologies. I understand that in the case of the Gujurat mine at Bulli the scale is 10x and at the Helensburgh Colliery 3x. There Warratah rivulet near Helensburgh that feed the Woronora dam has already subsided and gone underground as a result of Long Wall mining at the Metropolitain coal mine and 18 months of remedial work has failed to resolve the problem. Therefore the risks associated with CSG mining are being layered on top of the existing impact of extensive coal mining in the area - with no combined impact study yet undertaken!.

4. The applicants (APEX Energy) have already shown their incompetence and unsuitability by allowing a PEL to lapse through default, as a result of an "administrative oversite" What if the result of the next "oversight" is contamination or fire in our catchment, or environmental conservation areas?
The lapsed PEL cancels all current APEX CSG approvals therefore, at the very least, no consideration should be given to extensions or any other type of approval for APEX until this matter is resolved

5. There is widespread public opposition to CSG mining in the area. This includes a public petition of around 20,000 signatures delivered to the Premier, formal votes against CSG mining by 4 local councils (Wollongong, Wollondilly, Cambletown and Sutherland), and at least 2 local state MP ( Lee Evans and Ryan Park). Major concerns exist around the original approvals forced through by the previous Labour government under part 3A of the NSW planning Act , which bypasses many of the usual and expected environmental and public consultation processes. I am very concerned by the absence of independent research into the environmental impact of CSG in such a vital area of water supply ( let alone the combined impact of CSG and mining) and the lack of pubic consultation: Specifically APEX Energy did not enter into public consultation before its initial drilling at Darkes Forest, nor earlier this year before drilling within the Warragamba water catchment at Oakdale - this shows total a lack of respect for due process and pubic opinion .

6. Any decision to extend, renew, or other wise approve new activities inand around the water catchments flies in the face of commitments made by The Premier of NSW ( Barry O'Farrell that there shall be no mining ( including CSG mining) in our water catchments ' NO IFS, NO BUTS!"

Firstly, I advise that Nowra is a city, not a suburb - how about reflecting the actuality that people live outside of Sydney??
I oppose the extension as it relates firstly to drilling in a water catchment area. The current premier gave a 'no ifs, not buts' promise pre-election that this would not happen. Secondly, fracking is a seriously flawed process that is shown already to be detrimental to the environment and to health.
Again, I therefore state emphatically my opposition to this proposed extension to a programme that should not have been allowed in the first place.

Dear Madam/Sir,

I am writing to express my objection to the proposed modification by Apex Energy to their -currently frozen- development application to drill for coal seam gas in the Illawarra region.

This modification, if approved, would allow Apex Energy to extend drilling deadlines from "three years from commencement of drilling of the first bore hole". This is in relation to 16 wells which span two drinking water catchments, Woronora and Nepean.

There is currently a lack of serious consideration of and research into the immediate and long-term effects of coal seam gas mining, particularly in and around water catchment areas. However, companies that have developed coal seam gas projects themselves concede that leakages are common and only increase over time. Steel and concrete are not impervious to the elements; I (and I imagine others too) would be incredibly concerned by a situation where these were the only materials standing between our pristine drinking water supply and a huge amount of undisclosed chemicals.

This is not in any way an extreme view. It is a reasonable expression of caution at the thought of possibly inducing a public health crisis, in the event that our drinking water might be compromised.

Further, it was promised by the incoming O'Farrell government that:

"The next Liberal/National Government will ensure that mining cannot occur... in any water catchment area, and will ensure that mining leases and mining exploration permits reflect that common sense; no ifs, no buts, a guarantee."

The drinking water catchment is unsuitable for CSG exploration and production. Allowing this development to go ahead contradicts this pre-election promise from Barry O'Farrell.

What would we do if our drinking water was compromised?

In addition to concerns about the effects of CSG mining near out water catchments, there are other significant risks to the local area:

1. The Illawarra Escarpment is already a high risk bush fire area. In August this year a bush fire burnt through AI09 and AI10 in this project area. Extracting and piping gas in this environment will increase these fire risks.

2. The development of this coal seam gas project is being layered on top of extensive coal mining and a fault line, without an assessment of the combined impacts.

With such risks, it would seem highly reasonable to reject the modification by Apex Energy to extend drilling deadlines from "three years from commencement of drilling of the first bore hole".

Such applications should be considered in the context of the local environment. This application poses very clear risks to the local environment and importantly, its residents (as well as those living in Sydney who will be affected by water sourced from the Woronora and Nepean catchments).

I strongly urge you to consider this submission, as well as the multitude of community voices which stand in opposition to coal seam gas mining: 'Stop coal seam gas signs' are displayed outside hundreds of homes in the Illawarra, demonstrating the huge public concern over this issue.

Yours sincerely,
Amy Luschwitz

1. The area of the Illawarra upper escarpment is completely unsuited to CSG mining consisting almost entirely of SWA drinking water catchment "Special Areas" and dams, National Parks and other environmental preservation or conservation areas. It is also a high risk bush fire area which is exacerbated by its highly combustible peat base: This months bush fire ran through and burnt out APEX drill sites 9 and 10. This is a unique and highly sensitive upland swamp area, whilst production CSG mining is an extensive and environmentally invasive industrial activity that will result in 150+ well pads and associated above ground infrastructure on the escarpment. This activity will permanently damage and or change the ecology.

2. The risks of CSG mining are now well documented (especially those relating to water contamination) and current NSW CSG control legislation acknowledged as inadequate for managing this risk - The NSW Premier reconfirmed this only yesterday in his interview with Alan Jones. The revised NSW Government regulatory framework has yet to be released and it would be improper to proceed prior to APEX being assessed against these requirements.

3. The area is already under threat from massive coal mine expansion using long wall mining technologies. I understand that in the case of the Gujurat mine at Bulli the scale is 10x and at the Helensburgh Colliery 3x. There Warratah rivulet near Helensburgh that feed the Woronora dam has already subsided and gone underground as a result of Long Wall mining at the Metropolitain coal mine and 18 months of remedial work has failed to resolve the problem. Therefore the risks associated with CSG mining are being layered on top of the existing impact of extensive coal mining in the area - with no combined impact study yet undertaken!.

4. The applicants (APEX Energy) have already shown their incompetence and unsuitability by allowing a PEL to lapse through default, as a result of an "administrative oversite" What if the result of the next "oversight" is contamination or fire in our catchment, or environmental conservation areas?
The lapsed PEL cancels all current APEX CSG approvals therefore, at the very least, no consideration should be given to extensions or any other type of approval for APEX until this matter is resolved

5. There is widespread public opposition to CSG mining in the area. This includes a public petition of around 20,000 signatures delivered to the Premier, formal votes against CSG mining by 4 local councils (Wollongong, Wollondilly, Cambletown and Sutherland), and at least 2 local state MP ( Lee Evans and Ryan Park). Major concerns exist around the original approvals forced through by the previous Labour government under part 3A of the NSW planning Act , which bypasses many of the usual and expected environmental and public consultation processes. I am very concerned by the absence of independent research into the environmental impact of CSG in such a vital area of water supply ( let alone the combined impact of CSG and mining) and the lack of pubic consultation: Specifically APEX Energy did not enter into public consultation before its initial drilling at Darkes Forest, nor earlier this year before drilling within the Warragamba water catchment at Oakdale - this shows total a lack of respect for due process and pubic opinion .

6. Any decision to extend, renew, or other wise approve new activities inand around the water catchments flies in the face of commitments made by The Premier of NSW ( Barry O'Farrell that there shall be no mining ( including CSG mining) in our water catchments ' NO IFS, NO BUTS!"

Dear Sir/Madam,

I understand that APEX Energy has apparently applied for a 3 year extension to their Coal Seam Gas entitlements, due to expire on 22 September, 2012, resulting from Part 3A of the NSW Planning Act under the disgraced Labor State Government.

I hereby lodge my OBJECTION to granting any approvals which could allow CSG drilling in our local Illawarra region, for the following reasons.

a) The Illawarra region north of Wollongong is a major collection source of DRINKING water for many thousands of citizens, and proposed CSG operations pose a high-risk threat to the future health of those consumers.

b) The chemicals injected sub-surface, into water tables and aquifers by CSG are recognised as being quite toxic, even carcinogenic. Saline tailings and wastes generated by CSG are also very damaging to the existing natural environment.

c) There is NO credible scientist who could GUARANTEE that there would be no future health risk from CSG operations in these areas.

d) These Illawarra areas are recognised as high BUSHFIRE RISK areas, and CSG operations constitute an obvious pathway for instigating bushfires. It was only a few years ago (Christmas Day 2001) that Helensburgh was partially evacuated due to wildfires, said to have been started by Integral Energy power lines as far away as Appin. Those wildfires destroyed houses at Stanwell Tops, and very nearly caused fatalities.

e) It is widely known that methane is more than 20 times more potent than carbon dioxide, as a 'Greenhouse Gas', and unburnt escapes to the atmosphere, into the far-distant future from abandoned wells, cannot be fully captured.

f) The general public is excluded from these Water Catchment areas, with signs warning of $11,000 fines, but CSG wastes would obviously be far more toxic than anything the normal general public would generate.

g) The Illawarra is renowned for its scenic beauty - CSG well sites leave a trail of unsightly visual destruction.

CONCLUSION
Clearly, CSG operations MUST be EXCLUDED from Sydney's drinking water catchments.

It would be sheer insanity for ANY Government to risk the future health of the populace, by granting approval to such controversial activities.

Attention: Director, Mining and Industry Projects
Major Projects Assessment
Department of Planning
GPO Box 39
Sydney NSW 2001


To Whom It May Concern,
Objections to the Modification Proposal 07_0103 MOD2 from Apex Energy N.L.

I write to strongly object to the proposal from Apex Energy to renew and indefinitely extend their 2009 major project to undertake coal seam gas operations in the catchment lands of the Northern Illawarra. Regardless of current Government policy, shaped as it is by royalty interests, scientific uncertainty remains and risk taking in the catchments and high value conservation lands is unacceptable. The Special Areas have already suffered significant damage as a result of coal mining.

At a public rally before the last election, the then Opposition Leader stated that the next Liberal and National Government would "... ensure mining cannot occur in any water catchment area and that any mining leases and exploration permits will reflect that common sense. No ifs, no buts, a guarantee."

On December 1, 2011 the Premier told 2GB's Alan Jones: "I don't intend to allow -- particularly after the drought we went through over a decade -- mining or any other activity to threaten water resources." He also stated that "... exploration licences have been granted, in some cases permission to mine has been granted, in areas, frankly, that should never ever have been on the list."

In light of this, the catchment areas supplying water to Greater Sydney and the Illawarra should surely never have been on that list. These are areas considered so ecologically sensitive that locals are not even allowed to bushwalk there. The financial gains from any CSG mining projects in these catchments will be short-lived, while the damage caused will be extensive and irreversable.

There is a ground swell of opposition to coal seam gas mining in the catchments, with large rallies and a petition that now has more than 30,000 signatures. Wollongong City Council, Sutherland Shire Council, Campbelltown City Council and many other council's in NSW are opposed to coal seam gas development. Towns and districts are declaring CSG free zones.

Yours faithfully,
Vincent Bicego

I am a concerned citizen who is quickly becoming alarmed. I feel the following issues must be addressed before CSG extraction is approved in NSW.

Failure of well casings - It should be shown without doubt that the concrete used will not crack, crumble or fail in some way allowing the gas to leak into aquifers.
Incidences of this problem have been documented by the CSG industry in the USA. South Western Energy has a document with diagrams showing a cement barrier around the sides of the well preventing gas from migrating to upper levels and into aquifers but when it fails the gas leaks into the surrounds contaminating the drinking water.

The following figures are collected from CSG industry reports in the USA where the problems with CSG are well known. Schlumberger has a review published in 2003 showing that casing failure occurs at alarming rates. It shows that 6% fail immediately upon drilling and that well casings deteriorate over time. Over a 30-year period 50% of well casings failed. An Alberta Energy Resources Conservation Board report shows gas migration at astronomical rates in deviated or horizontal wells and that surface casing doesn't help the problem at all. Archer Well Services shows enormous rates of leakage - 45% in wells in Gulf of Mexico, 34% in the UK and a 40% risk of uncontrolled discharge. In Pennsylvania well leakage is between 6.2% & 7.2% rate of failure for newly installed wells with gas migrating into aquifers.

A recent Queensland report found that over 50% of the wells tested In Qld were leaking.

It has to be shown that the cement and steel used in the construction of well casings have to last forever in order to be safe for future generations. Cement failure caused the blowout in the Gulf of Mexico. Cement failure caused the massive gas leak in the North Sea.

A full health impact assessment should be conducted before permits are issued.

Various studies about the effects of gas drilling have found that there are acute health problems relating to gas drilling activities and that the magnitude of these effects was from moderate to high.

It would be better to know the health consequences now before we allow this irreversible damage to our water supply to take place.
Although the gas industry insists that gas drilling is safe, there are numerous reports showing that there are risks to the environment and health of the community. As well as the problem of chemicals and compounds leaching into the water table, there have been many accidents with spillage of produced water. As far as I know, there is no known way to fix the problem once gas and chemicals (naturally found in coal seams) migrate into the ground water or find their way out through other cracks and fissures exposed when the water pressure is removed. So far there is no guaranteed safe drilling for coal seam gas.

At Fullerton Cove no Groundwater Assessment program will be implemented until this project begins! It seems the Newcastle and Lower Hunter residents and all the animals and birds and fish which rely on the aquifers that supply 20% of Newcastle's drinking water, are being used as an experiment!

There should be no risk of failure if water supplies are at stake. Clean safe drinking water should not be put at risk for the entire future in return for a possible supply of gas from a project that may not be viable at all.

In the USA some gas companies have shown that the gas leaking into the water is not the gas they were drilling for and therefore feel they are not responsible. The drilling process caused the gas leakage. Pockets of shallow gas can find a way to escape up failed well casings and into the aquifers. This has been the subject of a study by the Slumberjay 2010 groundwater report. I could find no information in Australian reports.


The CSG Industry should be responsible for rehabilitation of drill sites.

Dart Energy doesn't have a good record regarding this responsibility. They have compliance issues recorded against them at Fullerton Cove regarding `the failure to properly rehabilitate a site ... possible acid sulphate soil issues' and a `lack of appropriate surface water and groundwater monitoring'.

It seems the typical way of the mining industry is to lie, contaminate, pollute, take the profits then walk away and let the taxpayers pay for the cleanup. As well as the contamination of our water supplies, gas drilling causes massive land scarring, pollution, truck traffic and habitation fragmentation by pipelines.

The NSW government needs to step in immediately, call for a Moratorium on CSG and respond to the concerns of NSW residents and prevent drilling until all concerns are satisfactorily answered.

There is enough science out there pointing to huge problems but if we don't talk about this and get concerned and ask the right questions it will just go ahead regardless of future problems and then it will be too late. All costs must be considered (not just the jobs and profits).

I ask that the NSW Government does not grant an extension to the Apex coal seam gas entitlements for the following reasons:
1. It was an election promise by the O Farrell team that this would not occur.
2. Increased fire risk and intensity to our area when it is already prone to fire because of the natural bushland that surrounds us. Methane gases will increase the likely hood of fires. Only last month did a fire start at Bulli Tops Well site and quickly spread to Darkes Forest. Our lives and homes would be in serious danger in case of catastrophic
fires. It is a fact that lives are lost in Australian bush fires, remember Victoria?
3. These sites will be constructed across the upper Illawarra escarpment causing a huge increase of heavy truck usage. this in turn will destroy the bushland, increase pollution and devalue the quality of life for humans and animals alike.
4. Drilling will be occurring within the protected water catchment areas for Sydney and Illawarra.If this water is contaminated, as it has been in many areas of Queensland, there are no alternatives except billions having to be spent on more d-salination plants. In turn our water rates will be astronomical. Native bird life and animal life will be affected, farms, crops etc. This is the source of life!
5.There could be damage to the sandstone geology on which our aquifers sit.
6.Our local environment will be ruined by the drill sites. The quality of our children's and our lives will be diminished by the noise pollution, the increased
chance of disasters and the possible threat to our health and well being.
7. The drop that will occur in the market value of our homes and properties.
8.The damage these wells will cause to wildlife populations. The areas around our suburb is mostly bush. We need these to protect our natural heritage.
9. The Royal National park adjoins this area. What damage will occur to our oldest PROTECTED area? The green corridor that exists must be protected at all costs. There is no turning back when its all ruined. Is that the legacy the OFarrell government want's to be remembered for?
10. No guarantees have been made that our lives will be safe in case of an explosion.
11.Tourism in the area will be affected, in turn, lost revenue, in turn loss of jobs. Will Apex offer those people jobs?
12. Money is not the only thing that counts. Whilst the promises by Apex may be tempting, to a government with huge debts, the consequences if our environment and our water supply are contaminated will be insurmountable.
for all the reason above it is imperative that extensions are not granted to APEX Energy.

I object to the modification and renewal of this exploration licence for two broad reasons;

1) the first pertains to the action of coal seam gas mining itself:
If the exploration of these 16 wells found that the area was viable no doubt would it lead to coal seam gas mining in these areas, as was publicly announced by the head of Apex Energy in the media this week. Although the licence required for production from these wells is a process entirely separate to this, it would be foolish to think that this exploration licence in question would not pave the way for this to occur, especially considering the government approved renewal of PEL 444 this week. I therefore oppose the modification and renewal of this exploration licence for three years from the time the first hole is drilled, as it will undoubtedly lead to scaled up coal seam gas mining in the areas under PEL 444 and potentially under PEL442 (now PEL 138). I oppose coal seam gas mining in these areas for the risks they pose to the drinking water for Sydney and the Illawarra (either through toxic chemicals introduced from mining into the aquifers feeding these catchments or those released from the ground into the aquifers during mining). There is also the potential that hydraulic fracturing or fracking may also be used in this mining, which poses major threats to this water supply due to the release of highly toxic chemicals used in the fracking fluid. Apex Energy claims they will not use such a practice in their mining, however again it would be foolish to think that this would not happen, especially if were to yield more gas and more profits, and especially considering the moratorium on fracking was lifted this week. The Code of Practice, regarding fracture stimulation activities, meant to regulate this activity, does not detail the legal ramifications of what occurs when this code is breached. It troubles me that highly toxic chemicals could be released into our drinking water, with a post hoc response being the best my government could offer. This is also the case for bush fires that could result due to leaking methane. Consideration of the process after the damage is done is irresponsible and life threatening. I really can't understand why the government would even dare to dabble in this risk. In no possible scenario would the economic gains for mining companies nor the proceeds towards government justify the threats to the health and well being of their population.

Additionally, the infrastructure that would accompany this mining such as roads and buildings, as well as the increase in volume of trucks, would not only be an eyesore to this pristine park land but it would also disrupt the ecosystem. It scares me that the Department of Primary Industries has applied pressure to the Wollongong Council to downgrade the locations in question from E2 (Environmental Conservation) to E3 (Environmental Management) to allow for mining to occur. Again, I worry at what this government values.

2) The second reason I object to this modification and renewal of this plan is that this entire process is not transparent. The documents available on the exhibition website are not laid out clearly for a lay person unfamiliar with these processes to understand and comment on, particularly given that the exhibition is only open for 2 weeks, and is only open for those with internet access. This severely limits who can comment, and as such it is biased towards the NSW government and Apex Energy. It is a threat to participatory democracy, and deserves scrutiny before any further action is taken regarding the renewal of this licence. The public deserves unbiased, independent and scientific evidence of these practices, with time to think and respond clearly so as to defend their health and environment. Furthermore, this renewal, if approved, would allow for an indefinite start date for exploration mining, in which time the environment or public opinion could change, yet they would have no means to voice this concern as the licence would have already been approved based on pre-existing conditions. It is irresponsible as the public is being asked to act now without the full knowledge of what lies ahead.

Barry O'Farrell promised to ban exploration and mining in the drinking water catchment. This is nothing short of betrayal. Communities have made it clear that science must come before development, and that land and water must be protected.

The community ojects to this whole heartdly to this

The community objects to this whole heartedly.

We do not want this.

"All that is necessary for the triumph of evil is that good men do nothing."

Please see attached document.

Barry O'Farrell promised to ban exploration and mining in the drinking water catchment. This is nothing short of betrayal. Communities have made it clear that science must come before development, and that land and water must be protected.

The community ojects to this whole heartdly to this

The community objects to this whole heartedly.

We do not want this.

"All that is necessary for the triumph of evil is that good men do nothing."

Development must always be considered in the context of the surrounding area. This can change over time. Given this, a modification for an indefinite start date is irresponsible.
The risks of CSG mining are well evidenced and the Premier has acknowledged that the current legislation is not adequate to manage development of the industry. In this context, no new applications or modifications should be approved and existing projects should be frozen, to conduct an investigation into the full impacts of CSG development.
The drinking water catchment is unsuitable for CSG exploration and production. Allowing this development to go ahead contradicts the pre-election promise from Barry O'Farrell: "The next Liberal/National Government will ensure that mining cannot occur... in any water catchment area, and will ensure that mining leases and mining exploration permits reflect that common sense; no ifs, no buts, a guarantee."
The Illawarra Escarpment is a high risk bush fire area, exacerbated by its highly combustible peat base. Indeed, in August 2012 a bush fire burnt through AI09 and AI10 in this project. Extracting and piping gas in this environment will increase fire risks.
The development of this coal seam gas project is being layered on top of extensive coal mining and a fault line, without an assessment of the combined impacts.
There is widespread public opposition to CSG exploration and mining in the area. This includes a public petition of over 30,000 signatures, formal votes against CSG mining by local councils and two actions opposing CSG development attended by over 3,000 people each.

I object to Apex Energy application to modify their currently frozen coal seam gas development in the Illawarra for the following reasons:

Development must always be considered in the context of the surrounding area. This can change over time. Given this, a modification for an indefinite start date is irresponsible.

The risks of CSG mining are well evidenced and the Premier has acknowledged that the current legislation is not adequate to manage development of the industry. In this context, no new applications or modifications should be approved and existing projects should be frozen, to conduct an investigation into the full impacts of CSG development.

The drinking water catchment is unsuitable for CSG exploration and production. Allowing this development to go ahead contradicts the pre-election promise from Barry O'Farrell: "The next Liberal/National Government will ensure that mining cannot occur... in any water catchment area, and will ensure that mining leases and mining exploration permits reflect that common sense; no ifs, no buts, a guarantee."

The Illawarra Escarpment is a high risk bush fire area, exacerbated by its highly combustible peat base. Indeed, in August 2012 a bush fire burnt through AI09 and AI10 in this project. Extracting and piping gas in this environment will increase fire risks.

The development of this coal seam gas project is being layered on top of extensive coal mining and a fault line, without an assessment of the combined impacts.

There is widespread public opposition to CSG exploration and mining in the area. This includes a public petition of over 30,000 signatures, formal votes against CSG mining by local councils and two actions opposing CSG development attended by over 3,000 people each.

Please, please, please look after the drinking water for the Illawarra and Sydney areas and deny Apex Energy their application.

Dear Madam/Sir,

I wish to lodge an objection to Apex Energy's Exploration Project which will cover an area from Sydney to Wollongong. Their licence should not be renewed.

The area includes Sydney's water catchment and some near pristine bushland.

The proposition to have 150 or more coal seam gas wells operating over a 25 year period in a water catchment area without contamination of the water supply would have to rely on a lot of wishful thinking. The experience in the USA and parts of Australia would show wishful thinking cannot overcome adverse outcomes. The adverse outcomes are usually permanent as remediation often causes more harm than the original damage.

To permit coal seam gas mining at all in NSW, given the evidence to date, is irresponsible. To do so in Sydney's water catchment area is criminal.

There is also the destruction of forest and whole eco systems as part and parcel of this plan which should, on those grounds alone, rule it out.

If less gas was exported, there would be no need to coal seam gas mining.

I would firmly recommend the government rethink its entire Strategic Land Use Policy with the aim of providing adequate protection to water, environment and the communities which inhabit these areas.

I declare that I have not donated $1,000 or more to any political party.

Submission attached from Doctors for the Environment Australia.

Please confirm receipt of submission via email.

1. The risks of CSG mining are well evidenced and the Premier as acknowledged that the current legislation is not adequate to manage development of the industry. In this context, no new applications or modifications should be approved and existing projects should be frozen, to conduct an investigation into the full impacts of CSG development.
2.The drinking water catchment is unsuitable for CSG exploration and production. Allowing this development to go ahead contradicts the pre-election promise from Barry O'Farrell: "The next Liberal/National Government will ensure that mining cannot occur... in any water catchment area, and will ensure that mining leases and mining exploration permits reflect that common sense; no ifs, no buts, a guarantee."
3.The Illawarra Escarpment is a high risk bush fire area, exacerbated by its highly combustible peat base. Indeed, in August 2012 a bush fire burnt through AI09 and AI10 in this project. Extracting and piping gas in this environment will increase fire risks.
4.The development of this coal seam gas project is being layered on top of extensive coal mining and a fault line, without an assessment of the combined impacts.

The NPA Illawarra branch members strongly object to the Modification Proposal on exhibition.

Please find attached PDF submission.

Hello,

I strongly oppose this application to extend the Apex exploration project.

1. The project has had very large scale community opposition which should be heeded.
2. The premier made an election commitment not to proceed with CSG at the expense of other important land uses, including water catchment in the case of this project.
3. An indefinite extension is completely inappropriate given the changing understandings of this kind of project and its effect on the surrounding environment.
4. Further study of the possible impacts and impacts of drilling elsewhere should be undertaken before any further exploration occurs in this sensitive area.

Regards,
Daniel Heckenberg