Mod 3

Section 2.4 of the environmental assessment makes the statement that "the only other alternative to this proposed modification is to flare the gas."
This is incorrect as 100% of the tail gas produced currently, is onsold to Tomago Aluminium and will continue to be done pursuant to commercial contracts. There is no impediment to Tomago Aluminium continuing to take this tail gas for the forseeable future. There will be no requirement to flare any tail gas under the present arrangements.

Section 3.2 asserts the proposal will deliver an additional 370 TJ of gas to the Jemena network, equivalent to 2000 homes and small businesses. This ignores the fact that Tomago Aluminium will have to source an equivalent quantity of gas that can only be sourced from the Jemena network; hence there will be no additional benefit to NSW gas users or improvements in supply. In fact it is likely, owing to the applicant wanting to build and operate a second gas treatment flare, that overall gas supplies will be reduced, due to this flaring (operating for 4-6 weeks per year at 1.5 TJ/day).

Thank you for the opportunity to provide comment on the EA for MOD 3 of the Newcastle Gas Storage Facility (10_0133 MOD3).

The Division of Resources and Geoscience has reviewed the EA, and has no issues with the modification. The proposal will not affect operating mines, quarries or petroleum production facilities, nor mining or exploration titles granted by the Division.

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