Mod 2 - Extension of Time

I request that Department of Infrastructure and Planning, and the state government of NSW, reject the application for a 3 year extension to APEX Energy's Coal Seam Gas entitlements. I further request that all applications for CSG exploration and drilling be denied within any and all water catchment areas. I request that no such extension be given until full environmental scrutiny and public consultation takes place. I object to all forms of CSG exploration and extraction due to the risk of damage to the sandstone geology, the increased risk and severity of bushfires, the decrease in the value of properties, the increased risk of water contamination and damage to landscape and wildlife populations.

I also object to Wollongong Council's proposed rezoning (downgrading) of the Royal National Park and surrounding communities from its current high level down to an ordinary Level (E3). It is imperative that the zoning remains as is to protect the community, environment, waterways and wildlife from the impact of CSG exploration and extraction.

I request that Department of Infrastructure and Planning, and the state government of NSW, reject the application for a 3 year extension to APEX Energy's Coal Seam Gas entitlements. I further request that all applications for CSG exploration and drilling be denied within any and all water catchment areas. I request that no such extension be given until full environmental scrutiny and public consultation takes place. I object to all forms of CSG exploration and extraction due to the risk of damage to the sandstone geology, the increased risk and severity of bushfires, the decrease in the value of properties, the increased risk of water contamination and damage to landscape and wildlife populations.

I also object to Wollongong Council's proposed rezoning (downgrading) of the Royal National Park and surrounding communities from its current high level down to an ordinary Level (E3). It is imperative that the zoning remains as is to protect the community, environment, waterways and wildlife from the impact of CSG exploration and extraction.

I request that Department of Infrastructure and Planning, and the state government of NSW, reject the application for a 3 year extension to APEX Energy's Coal Seam Gas entitlements. I further request that all applications for CSG exploration and drilling be denied within any and all water catchment areas. I request that no such extension be given until full environmental scrutiny and public consultation takes place. I object to all forms of CSG exploration and extraction due to the risk of damage to the sandstone geology, the increased risk and severity of bushfires, the decrease in the value of properties, the increased risk of water contamination and damage to landscape and wildlife populations.

I also object to Wollongong Council's proposed rezoning (downgrading) of the Royal National Park and surrounding communities from its current high level down to an ordinary Level (E3). It is imperative that the zoning remains as is to protect the community, environment, waterways and wildlife from the impact of CSG exploration and extraction.

I request that Department of Infrastructure and Planning, and the state government of NSW, reject the application for a 3 year extension to APEX Energy's Coal Seam Gas entitlements. I further request that all applications for CSG exploration and drilling be denied within any and all water catchment areas. I request that no such extension be given until full environmental scrutiny and public consultation takes place. I object to all forms of CSG exploration and extraction due to the risk of damage to the sandstone geology, the increased risk and severity of bushfires, the decrease in the value of properties, the increased risk of water contamination and damage to landscape and wildlife populations.

I also object to Wollongong Council's proposed rezoning (downgrading) of the Royal National Park and surrounding communities from its current high level down to an ordinary Level (E3). It is imperative that the zoning remains as is to protect the community, environment, waterways and wildlife from the impact of CSG exploration and extraction.

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!"

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!"

The Southern Councils Group (SCG) is the peak organisation representing Local Government in the Illawarra and South Coast regions. Member Councils include Bega Valley Shire, Eurobodalla Shire, Kiama Municipal, Shellharbour City, Shoalhaven City, Wingecarribee Shire and Wollongong City Councils.

SCG resolved the following joint statement of support for Wollongong City Council's position on exploration in water catchment areas.

> SCG expresses its concerns that the short-term and long-term environmental impacts of Coal Seam Gas (CSG) activities are not well understood, at either a State-wide or regional level.

> SCG acknowledges there is widespread local community concern about and opposition to CSG in the Illawarra and South Coast.

> SCG urges the State Government to rule out CSG activities in water catchment areas.

Objections to the Modification Proposal 07_0103 MOD2 from Apex Energy N.L.

Please find attached a cover letter and submission objecting to the proposal from Apex Energy N.L. to renew and extend the coal seam gas exploration project 07_0103 approved in 2009.

Industrial activity of any kind is neither appropriate nor acceptable in an area set aside to protect the drinking water of Greater Sydney and the Illawarra.

This submission is made with the support of a number of community groups, as listed in the attached submission document.

Please do not publish my contact details.

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.

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.

We object to the proposal of allowing Apex Energy or Ormil Energy to explore or extract coal seam gas from the Illawarra region.
The Sydney Water Catchment land is far too precious to be jeopadised by such hazardous and degrading activity. Plus Apex Energy have proven to be vastly lacking in the methodology, planning and finances to contemplate such a venture and are merely wishing to secure the approvals with the hope of re-selling the PELS and PART3A approval at a profit. Plus should anything go wrong, as it inevitably will, Apex Energy do not have the financial resources to re-mediate or compensate for toxic water, poisoned crops/livestock and wildfire razed land when the typical bushfire is further ignited with tapped methane gas.

The former State Labor goverment had some excuse in awarding the original PELS and major project application, since the DPI was largeley unaware of the huge risks involved. But the present State government , and planning department has no excuse at all, and should be fully aware of the environmental impact and huge ground swell of opposition from the community, tax payers, environmental groups and farmers.

Project Application No. MP 07_0103 MOD 2,

Dear Sir/Madam,
I would like to formally object to Apex Energy's Modification No 2.

Industrial activity and risk taking of any kind is neither appropriate nor acceptable in the catchment lands set aside as Schedule 1 Special Areas to protect the drinking water of Greater Sydney, the Illawarra and the Southern Highlands. More than 60% of the population of NSW depends on the health of the Special Areas.

Sydney is extremely fortunate to have the remarkable and still largely pristine catchment area on it southern doorstep. The shameful damage that has been inflicted on these areas by longwall coal mining bears damning and lasting testimony to the royalty-shaped policies of next-election focussed governments. The community is of course very well aware of this conflict of interest and has little trouble seeing through the masking language woven to justify decisions that are not in the long term public interest.

The impacts of coal seam gas operations have been widely reported and documented.
The catchment lands supplying water to Greater Sydney and the Illawarra should never be subjected to these polluting processers. Reflecting this "common sense", 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 councils in NSW are opposed to coal seam gas development. Towns and districts are declaring CSG free zones.
Collectively, we have an intergenerational responsibility to ensure water security and biodiversity into the uncertain future. Filtration and desalination plants are an inadequate and costly replacement for a remarkable natural system that has been in operation for millennia.

The Coastal Upland Swamps of the Special Areas are complex and highly fragile ecosystems hosting biodiversity of international standing, and are vital catchment components that store and filter water. The high quality drinking water that Sydney and its nearby regions enjoy depends on the health of the swamp communities.

I state that I have not made donations to any political party.

Your Faithfully

Gavin Workman