Mod 4

People For The Plains is a group of mostly Narrabri Shire residents who have sought to gain a comprehensive understanding of the processes surrounding coal seam gas developments and the impacts of these processes.
Its charter is to educate and advocate on these issues in North Western NSW.

We object to Modification 4 of the Narrabri Gas Coal Seam Utilisation Project.

We are concerned about the Santos application seeking approval for the Modification 4 to allow use of coal seam gas from existing or future wells within PEL 238 at the Wilga Park Power Station consistent with the recent amendment to the Petroleum (onshore) Regulation 2007.

This appears to be another step in the process of moving PEL 238 towards coal seam gas "production by stealth".

1. Santos already has the Leewood waste water treatment facility capable of processing quantities of waste water from the Narrabri Gas project likely when the project is in full production.
2. The existing and future approved exploration wells in PEL 238 are capable of becoming production wells providing they have adequate gas flows, without any substantive change to current infrastructure.

Therefore approval of this Modification would amount to a devious bypassing of proper process by Santos and the Government. It would allow them to ramp up their operations to a level equivalent to "production"with little or no environmental assessment or public scrutiny.

In addition Santos notes that, "as exploration and approval continues within PEL 238 and PAL 2, approval for installation of additional pilot wells and infrastructure may be sought".

Part 4.1 Government Policy - Amendment to Petroleum (onshore ) Regulation 2007, states that gas released during prospecting operations is subject to meeting thresholds and limitations.

We understand that the following are the only thresholds and limitations:

2.a the right to beneficial use of gas conferred by section 28B of the Act is limited to period of 1000 days (whether or not consecutive ) per well.
b. Gas is to be used for beneficial use.
3 and royalty is payable, unless that recovery and use is authorised by a relevant development consent.

This raises the following questions about these thresholds and modifications.
1. 2.a appears to be a loop hole the company can use to their advantage. eg they can run the well for 100 days per year for 10 years or any other combination to make up 1,000 days. How can this threshold manage the impacts when it's implementation could vary so greatly and how can this be effectively monitored?

2. 3 does this mean that NSW will derive no direct financial benefit from the unknown quantity of gas to be extracted and utilised as a result of this Modification ?

3. Is there a limit to the number of pilot wells that can be drilled before an EIS is required? Where is the end to this threshold?

There is no mention in the application material of Santos's full scale production project proposed for 850 wells. How does further exploration and appraisal activity for PEL 238 fit into the application for the production project in this same PEL with the EIS apparently due out in Nov 2016 or early in 2017?

The Minister should reject the Modification application and require Santos to fully articulate its plans in the Pilliga, the quantity of gas it intends to extract and flare or vent and the length of time it intends to continue expanding its "exploration" activities with little or no environmental and public scrutiny.

To whom it may concern,
Santos is abusing the new provisions for "beneficial use" of gas obtained during exploration and that this project amounts to CSG production by stealth. Santos lists 27 wells in PEL238 as being subject of this application for beneficial use, but notes that "As exploration and appraisal continues within PEL 238 and PAL 2, approval for installation of additional pilot wells and supporting infrastructure may be sought."
Section 28B of the Petroleum Onshore Act allows for beneficial use of gas "only if that gas would otherwise have been flared or released into the atmosphere as part of activities under the licence or lease." But no information is provided about how much gas is likely to be removed and utilised under this application and whether all of this gas would otherwise have been flared or released into the atmosphere.
There is no assessment provided of the environmental impact of burning this gas in the power stations relative to flaring or releasing it.
There is no mention in the application material of Santos' full scale production project for 850 wells. Why is further exploration and appraisal activity required in PEL238 if Santos have now applied for a production project?
There is no information provided about the amount of clearing that needs to be undertaken for additional water pipelines and gas gathering lines required for this project. There is no information provided about the threatened species or other environmental values that will be impacted by such clearing.
The beneficial use clauses included in the Petroleum Onshore Regulation 2016 stipulate that "(3) For the purposes of section 28B (2) of the Act, royalty is payable under and in accordance with Part 7 of the Act in respect of any petroleum recovered by the holder of the petroleum title and used beneficially, unless that recovery and use is authorised by a relevant development consent." This means that NSW will derive no direct financial benefit from the unknown quantity of gas to be extracted and utilised as a result of this modification.
The community has widely rejected CSG production in the Pilliga and approval of this modification would amount to a devious bypassing of proper process by Santos and the Government, allowing CSG production to occur with little to no environmental assessment or public scrutiny, in the teeth of public opposition.
The Minister should reject this modification application and require Santos to fully articulate its plans in the Pilliga, the quantity of gas it intends to extract and burn, or flare and release, and the length of time it intends to continue expanding its "exploration" activities with little to no environmental and public scrutiny.

Thankyou for your time,
Peter Small
Coonabarabran Residents Against CSG

I submit that Modification 4 should not be approved.
It seems that the gas will be used at the Wilga Park power station for the purpose of generating electricity for the grid. Surely the company will be paid for this electricity. Therefore the beneficial use will accrue all the so-called benefit to the company. We, the citizens of NSW will get no financial benefit in the form of royalties nor will we get payment for the electricity. These are our public resources being used for private benefit. Companies should pay royalties for all gas extracted whether they sell it on or not.
I agree that it is better not to flare,e especially from a light and air pollution perspective,but it would be better not to extract the gas at all
Jane Judd

The time has passed for this kind of development. Evidence from all around the world shows its disbenefits and against this backdrop, any suggestion that there could be a 'beneficial use' is ludicrous.

Worse, to try to get the project off the ground without the process of public consultation which would inevitably bring out a plethora of objections from the community is a disgrace.

Two whom it may concern
I choose to make this submission being of sound mind and body
I hereby submit my opposition to this developement and all coal seam gas developements associated with it, including but not limited to the Narrabri gas field operations conducted by Santos.
I choose to stand in opposition for myself, my children and the environment that sustains us.
There are so many reasons (why this and associated projects should not continue), backed up and supported by so much information from around the world.
Accept this as my standing in opposition

To Whom it may Concern

I am writing this submission to question the above approvals.
My concerns are

That this is Pilot Wells not regulated gas wells

What royalties are being paid on this gas?

If the gas is being used for commercial purposes, eg power station, than the wells are not pilot well but production wells

Many issues are arising from the csg and infrastructure in Qld, I know, as I live it. Are these concerns being investigated as part of this procedure?

Bores are dropping over 30km from gas fields, is this information being used in deciding these 'pilot wells' are not going to impact water in the area?

Qld has a make good law of affected wells,, is this proof of impacts being investigate in this approval process.

Overwhelming numbers in the area have said they do not want csg, which means Santos has no social licence to operate, are the concerns of the people being address?

What are the agreements made with government for payment of wells in state forrest?

The forrest belong to the people,, once again has a social license been approved

Many Gammaalaray sites are in this area,, what is being done to protect these important cultural areas? What consultation is there with the people? Who is approving access to the culture areas and do they have the backing on the people of the area.

This is just the tip of the iceberg of the issues that are related to csg, the impacts to communities,, decrease in land values over 20% in 3 years, the csg industry boom is short lasting and the effects devastating and long term, i live it everyday

This proposed admendment needs major community input and a EIS must be gained if gas from wells is to be used.

Regards
Sandra Bamberry

Today is UN Day around the planet
Knitting Nannas Against Gas and I are sick of the destruction perpetuated by parliamentarians succumbing to lobbying by filthy fossil fuel corporations.
Today, we recognise the voiceless.
Please reject Santos' proposed modification to enable gas from all existing and any future CSG wells within PEL 238 to be used to fuel Wilga Park Power Station.

I have travelled far and wide in regions where the environment and communities have succumbed to gasfields. The regions have been destroyed, dewatered, lost bore pressure that is vital for farming and feeding our large and fragile nation and the waterways suchas the mighty Condamine River are no longer mighty.

Today Knitting Nannas presented a charge sheet to Kevin Hogan MP's office in Lismore and at other Federal Member's offices outlining the breaches this government has already made against agreements to which Australia is a signatory. It is time to think of your own children.

We want renewables.
We want forests preserved for our wildlife not cut down and burned for overseas companies.
We want a future for our next generations that does not need to destroy to continue our existence.

Please reject this proposal 4 modification.

Thank you kindly for accepting this submission.
Yours very sincerely,
Louise Somerville

In response to the Narrabri Coal Seam Gas Utilisation Project (Wilga Park Power Station) proposal I would like to state that I am vehemently opposed to any CSG mining at all and especially in this case.
I would like to believe that my species are more intelligent than going ahead with CSG mining which, as a form of energy supply for humans, shows blatant disregard for the health of our Planet and the viability of our childrens futures.
As such I voice my disapproval here and insist that steps are taken to work towards a healthy and renewable energy future for humanity.

Modification 4 - Beneficial Use of Coal Seam Gas from PEL 238

I object to the above Modification, which would allow Santos to build and operate a coal seam gas field by stealth without having to complete any EIS.

The people of NSW deserve better treatment than this from our Government, and should be given the opportunity to voice their opinion, and Santos should be required to submit an EIS for review.

At the very least a PAC meeting should be held.

I object to gas fracking because of tge pollution left in its wake - water courses around the world are being destroyed by tge extraction procesd. In Kansas USA, where they have never had earthquakes before, recent tremours have been attributed by scientists to gas fracking.

I now understand the tactics that Minister Andrews and Josh Frydenberg were referring to when they laughed with each other at COAG over how people would hate them. This move by SANTOS is completely underhanded and nothing short of a malicious attack not only on our water security today, but the water security for generations of Australians to come. How is it POSSIBLE that with the evidence from around the world that this is a dangerous form of mining (despite manipulative efforts by the gas industry to suppress this evidence with confidentiality agreements and/or gag orders) and in a country such as ours we should not even consider this toxic form of mining given our 'perilous water security ' (Rob Vertessy, outgoing head of the BoM).
All of you who are complicit in this I hope will find yourselves facing trial under these new international laws on environmental crime. http://mobile.abc.net.au/news/2016-09-17/icc-to-turn-focus-to-environmental-crimes-over/7854696
And as you consider expanding the power station, it is high time to leverage our abundant renewable resources. In case you have forgotten, this Paris agreement has been ratified, so agin, what are you thinking? http://unfccc.int/paris_agreement/items/9444.php
The fact this is also going ahead without an EIS in place is also evidence of appalling mismanagement or corruption. Although an EIS that gives this the thumbs up would have to be seriously questioned ~ you don't have to look hard to find hard evidence of irreversible water contamination where onshore gas mining has taken place. http://www.usatoday.com/story/money/business/2014/01/05/some-states-confirm-water-pollution-from-drilling/4328859/
Are those moving this forward in such haste also aware of the exponential increase in law suits awarding damages to those impacted by onshore gas mining? Why are you walking into that?
Despite the dreadful effort of that industry PR stint the movie Fracknation to discredit Gaslands, here are examples of the kind of damages being awarded for the contamination in Dimock http://www.ecowatch.com/jury-awards-two-dimock-couples-4-2-million-after-finding-cabot-oil-gas-1882188335.html
Is our government willing to compensate like this? They will be called upon to do it eventually ~ just look at QLD water in the gas fields to find out why. Or is SANTOS going to couch up for this? Are their shareholders aware?
Finally, what right do you have to reduce the value of the farmers' land in the area to nothing with this intrusion in agricultural zones? https://www.theguardian.com/environment/2016/sep/30/commonwealth-bank-coal-seam-gas-makes-property-unacceptable-as-loan-security
If we continue to do this on the limited agricultural land we have in Australia at a time of population growth and growing global instability we will send our farmers off the land. We need to protect our water and our long term food supply above all else.
Do not allow this project to expand, in fact you should move to shut the whole thing down right now.
Thanks for the opportunity to make a submission.
With great concern, Julia

Dear Sir Madam,
I can not believe that a decision to make a modification to PEL 238 for 'beneficial use of coal seam gas' without public consultation is showing any regard for anyone except Santos.

This is going to inflame public opinion, cause undue pain for many locals and seems to be allowing a distructive gas industry to develop a gas field by coming in the back door.

There are many things to consider,and any government that has no regard for due process will realise that it made a bad decision, unfortunately to late.

It has been shown that the gas industry in QLD is in big financial trouble, but still these companies attempt to invade us with an out dated and unnecessary industry.

I stress that this ideciion is denied any further consideration.

Dear Sir/Madam

re: Modification to Narrabri CSG Utilisation Project.

I am writing to express my concern that due process has not been followed with this Modification to the CSG Utilisation Project.

My understanding is that the Wilga Power Station is currently licensed to use 10mg of gas and that it has applied to Narrabri Council to extend this to 40 mg. I also understand that Santos would then be able to use the gas obtained from pilot wells under its exploration license for "beneficial use" and provide this to Wilga.

I further understand that there is NO Environmental Impact Statement occurring for this action.

In my opinion, this is a stealthy movement by Santos and the NSW Government to move to CSG production without the appropriate signoff process ie a public PAC hearing.

It is also my observation that Santos has no social license to proceed with CSG production particularly given the communities concern about risk to surface and ground water, and methane emission levels, and health impacts. International evidence of poor outcomes from CSG industry supports these concerns.

I strongly request that an EIS is conducted on this application by an independent body and that the PAC process is conducted.

Yours

Nicola Chirlian.

I now understand the tactics that Minister Andrews and Josh Frydenberg were referring to when they laughed with each other at COAG over how people would hate them. This move by SANTOS is completely underhanded and nothing short of a malicious attack not only on our water security today, but the water security for generations of Australians to come. How is it POSSIBLE that with the evidence from around the world that this is a dangerous form of mining (despite manipulative efforts by the gas industry to suppress this evidence with confidentiality agreements and/or gag orders) and in a country such as ours we should even consider this toxic form of mining given our 'perilous water security ' (Rob Vertessy, outgoing head of the BoM).
All of you who are complicit in this I hope will find yourselves facing trial under these new international laws on environmental crime. http://mobile.abc.net.au/.../icc-to-turn-focus-to.../7854696
And as you consider expanding the power station, it is high time to leverage our abundant renewable resources. In case you have forgotten, this Paris agreement has been ratified, so agin, what are you thinking? http://unfccc.int/paris_agreement/items/9444.php
The fact this is also going ahead without an EIS in place is also evidence of appalling mismanagement or corruption. Although an EIS that gives this the thumbs up would have to be seriously questioned ~ you don't have to look hard to find hard evidence of irreversible water contamination where onshore gas mining has taken place. http://www.usatoday.com/.../some-states-confirm.../4328859/
Are those moving this forward in such haste also aware of the exponential increase in law suits awarding damages to those impacted by onshore gas mining? Why are you walking into that?
Despite the dreadful effort of that industry PR stint, the movie Fracknation, to discredit Gaslands, here are examples of the kind of damages being awarded for the contamination in Dimock http://www.ecowatch.com/jury-awards-two-dimock-couples-4...
Is our government willing to compensate like this? They will be called upon to do it eventually ~ just look at QLD water in the gas fields to find out why. Or is SANTOS going to couch up for this? Are their shareholders aware?

We need to do a full cultural and heritage assessment of first nations sites as well, and this should be performed by the descendants of the gomeroi from the country where the operations are planned, people from off country should not be used for this purpose as this is against cultural protocols and they do not possess the detailed knowledge that those who have continuity of occupation going back thousands of years.
Finally, what right do you have to reduce the value of the farmers' land in the area to nothing with this intrusion in agricultural zones? https://www.theguardian.com/.../commonwealth-bank-coal...
If we continue to do this on the limited agricultural land we have in Australia at a time of population growth and growing global instability we will send our farmers off the land. We need to protect our water and our long term food supply above all else.
Do not allow this project to expand, in fact you should move to shut the whole thing down right now.
Thanks for the opportunity to make a submission.

Letitia

My name is Ursula Da Silva. As a young person (24) I still have a long time to live on this planet. To see my resources being used for short term profit by the politicians we employ is a disgrace. This is not a representation I even consent to. Your own laws should not be allowing a mass scale industry such as CSG to destroy the Pilliga. Allowing exploration and construction to be undertaken without the necessary environmental assessments and community consultation is unlawful. Similar circumstances would see an individual incarcerated by the same crimes.

I require you to answer the following:

1) What will the impact of the construction of the gas gathering systems at Bibblewindi and Bohena CSG Pilots be? Please include affects on the water tables, the flora and fauna impacted, the aquifers and the bushland.
2) What environmental studies have been undertaken to assess this impact?
3) What will the hazard of bushfire be in the presence of these constructions and the materials the transport? What has been undertaken to mitigate the possible outcomes of this new hazard?
4) What chemicals will be present? How will these affect the air and the chemistry of the air and the water and its level of quality? Please outline all the process planned to mitigate or recover an area if contaminated and how do you plan to prevent this?
5) What will the impact of the construction of the gas compression at Bibblewindi and Bohena CSG Pilots be? Please include affects on the water tables, the flora and fauna impacted, the aquifers and the bushland.
6) What environmental studies have been undertaken to assess this impact?
7) What will the hazard of bushfire be in the presence of these constructions and the materials the transport? What has been undertaken to mitigate the possible outcomes of this new hazard?
8) What chemicals will be present? How will these affect the air and the chemistry of the air and the water and its level of quality? Please outline all the process planned to mitigate or recover an area if contaminated and how do you plan to prevent this?
9) What happens if these facilities fail? Will an explosion occur and what are the likely outcomes? Please show me an Act of Legislation that allows for such a risk? And how does SANTOS plan to mitigate?
10) How close are the nearest residents to these facilities? How will their lives be impacted?
11) Is SANTOS aware that the Pilliga is a highly flammable forest populated largely with cypress pines?
12) How will the 32 kilometre buried gas flow line between the Bibblewindi and Bohena Pilot and the Wilga Park Power Station be maintained? What are the consequences of a leakage? How will this be mitigated?
13) What underwater ground streams/aquifiers will this construction be affecting? How will it affect them? What chemicals will leak into the water? How is this likely to affect the water-please include detailed studies showing potential affects and mitigations. Please also include other studies taken on by the companies in the times that their systems have failed and water has been polluted. Full comprehensive studies will be required in the response to this submission.
14)Please also include other studies taken on by the companies in the times that their systems have failed and the air quality has been polluted. Full comprehensive studies will be required in the response to this submission
15) Please also include other studies taken on by the companies in the times that their systems have failed and the land has been polluted, i.e through salt scarification due to drilling. Full comprehensive studies will be required in the response to this submission
16) Please also include full comprehensive studies of the increase in CO2 that the gas-fired power station expansion from the capacity of 12 megawatts to 40 megawatts will have, periodically, for a time frame of the next 100 years, so that my children and your children know what to expect.
17) Please outline the DA for this expansion
18) Please include any environmental studies this expansion may or may not have
19) Where is this gas going to?
20) How much of the gas mined by SANTOS is sold domestically and how much is sold overseas?
21) How much does SANTOS expect to profiteer off this expansion?
22) What local and non-local political members have approved/donated to SANTOS in the past/present.
23) Overall, what are the accumulative effects of a CSG mine in the Pilliga over the next 100 years? Will the air quality still be breathable? Will the water quality still be drinkable? Please outline when both of these will be beyond a human consumptive quality.
24) Overall how much CO2 does the entire SANTOS project intend to leak into the air?
25) How does SANTOS plan to mitigate methane in waterways?
26) What EPBC listed species will be threatened by this expansion? How does SANTOS plan to mitigate for these flora/fauna listed?
27) Have you watched GASLANDS?

I require all questions to be answered.
Ursula Da Silva

I object to any further development of this project because of its contribution to global climate change. We must be looking at sustainable energy sources for a future for this planet and its inhabitants. We are signatories to the Paris agreement from last year,a global undertaking to reduce emissions to combat climate change.This government is recklessly expanding and approving new fossil fuel projects. This is negligent and irresponsible and must stop.

My Name is Richard Darby, i work as an aged care worker. I would like to know what enviromental studys have been done in relation to the long term affects of coal seam gas mining. I believe australian farms to be one of our countries biggest assets, and all water and land needs to be used sustainably.
I require you to answer the following:

1) What will the impact of the construction of the gas gathering systems at Bibblewindi and Bohena CSG Pilots be? Please include affects on the water tables, the flora and fauna impacted, the aquifers and the bushland.
2) What environmental studies have been undertaken to assess this impact?
3) What will the hazard of bushfire be in the presence of these constructions and the materials the transport? What has been undertaken to mitigate the possible outcomes of this new hazard?
4) What chemicals will be present? How will these affect the air and the chemistry of the air and the water and its level of quality? Please outline all the process planned to mitigate or recover an area if contaminated and how do you plan to prevent this?
5) What will the impact of the construction of the gas compression at Bibblewindi and Bohena CSG Pilots be? Please include affects on the water tables, the flora and fauna impacted, the aquifers and the bushland.
6) What environmental studies have been undertaken to assess this impact?
7) What will the hazard of bushfire be in the presence of these constructions and the materials the transport? What has been undertaken to mitigate the possible outcomes of this new hazard?
?? What chemicals will be present? How will these affect the air and the chemistry of the air and the water and its level of quality? Please outline all the process planned to mitigate or recover an area if contaminated and how do you plan to prevent this?
9) What happens if these facilities fail? Will an explosion occur and what are the likely outcomes? Please show me an Act of Legislation that allows for such a risk? And how does SANTOS plan to mitigate?
10) How close are the nearest residents to these facilities? How will their lives be impacted?
11) Is SANTOS aware that the Pilliga is a highly flammable forest populated largely with cypress pines?
12) How will the 32 kilometre buried gas flow line between the Bibblewindi and Bohena Pilot and the Wilga Park Power Station be maintained? What are the consequences of a leakage? How will this be mitigated?
13) What underwater ground streams/aquifiers will this construction be affecting? How will it affect them? What chemicals will leak into the water? How is this likely to affect the water-please include detailed studies showing potential affects and mitigations. Please also include other studies taken on by the companies in the times that their systems have failed and water has been polluted. Full comprehensive studies will be required in the response to this submission.
14)Please also include other studies taken on by the companies in the times that their systems have failed and the air quality has been polluted. Full comprehensive studies will be required in the response to this submission
15) Please also include other studies taken on by the companies in the times that their systems have failed and the land has been polluted, i.e through salt scarification due to drilling. Full comprehensive studies will be required in the response to this submission
16) Please also include full comprehensive studies of the increase in CO2 that the gas-fired power station expansion from the capacity of 12 megawatts to 40 megawatts will have, periodically, for a time frame of the next 100 years, so that my children and your children know what to expect.
17) Please outline the DA for this expansion
18) Please include any environmental studies this expansion may or may not have
19) Where is this gas going to?
20) How much of the gas mined by SANTOS is sold domestically and how much is sold overseas?
21) How much does SANTOS expect to profiteer off this expansion?
22) What local and non-local political members have approved/donated to SANTOS in the past/present.
23) Overall, what are the accumulative effects of a CSG mine in the Pilliga over the next 100 years? Will the air quality still be breathable? Will the water quality still be drinkable? Please outline when both of these will be beyond a human consumptive quality.
24) Overall how much CO2 does the entire SANTOS project intend to leak into the air?
25) How does SANTOS plan to mitigate methane in waterways?
26) What EPBC listed species will be threatened by this expansion? How does SANTOS plan to mitigate for these flora/fauna listed?
27) Have you watched GASLANDS?

We object to the Coal Seam Gas going through, its not good for the environment, it pollutes the soil, the water and we are putting peoples lives at risk by going ahead with it.

I am a Grandmother of small children they deserve clean water and air and locally grown food.

I am writing to oppose this proposal as it does not follow any of the checks and balances that I would expect from any project that intends to extract unconventional gas to use as its source of energy.

Why are you people so determined to support Santos in this insanity? There is a mountain of evidence from around the world just a google click away that shows clearly that this industry is uneconomic, unsafe and destroys the biological systems of this planet. And if you don't believe what you see online, then spend a few days in the Queensland gas fields and see for yourself. It is madness allowing Santos to build a gas field in the main recharge zone of the Great Artesian Basin. It is the most destructive thing I can think of to try to keep this failing company afloat. And it won't work. Santos will only take down thousands of innocent Australians with them if they are allowed to do this. They will be fought every step of the way by people working without pay but with guts and a determination to survive against thugs and sellouts who only fighting to protect their bosses profits. Most of Australia supports the farmers. After all, they feed us everyday. Santos would be better off totally revising their company plan and investing in renewables to have any hope of surviving. And they need to provide stakeholders with a legitimate EIS before they embark on any project.
Katherine Marchment