Mod 4

The Gloucester Knitting Nannas object to the proposal that Santos be permitted to supply gas from exploration as "Beneficial Use of Coal Seam Gas".

It is our understanding that no EIS has ever been submitted for this potential coal seam gas field, and we are strongly of the opinion that one should be required.

A PAC meeting should also be held to allow the people to voice their opinion of this proposal.

A gasfield the size of PEL 238 should be subject to an EIS. Opening up the whole PEL to exploration to supply the power plant is in essence allowing full scale developement of the Gasfield under exploration.

This is not best practice in this dangerous industry.

Santos have already proved under exploration how dangerous this industry is when they contaminated an aquifer with Uranium.

This exploration license 238 should be cancelled now.

Yours sincerly
Melinda Wilson

To whom it may concern,
I'm writing to register my objection to the following:
I oppose Santos supplying gas from exploration as beneficial use of CSG to Wilga Park Power Station.
Santos should be required to submit an EIS and a PAC meeting should be held.
With all the evidence that this is a dangerous form of mining do not allow this project to go ahead.
The consequences outweigh any reason for this project to progress any further. I'm concerned about impact to the environment, Cultural sites, ground water impact, people health and wild life.
Regards,
Simona Angeli

As a local resident I am concerned to learn of an intended increase of production at the Wilga Park Power station. I have learned it was intended to commence without the completion of an E.I.S.
I want to live in the area for many years to come and want due process to be taken to ensure the health of all aspects of our community.

I am concerned that all areas of environmental and community concerns may not have considered. What efforts have been made to assess the effects on the water table and other environmental damage that may occur as well as impacts on farming and on possible aboriginal cultural sites, I hope due diligence will be undertaken before this is allowed to proceed. Has the local community, local aboriginal elders, the farming community etc been consulted properly and given time to comment?

Australia signed the Paris Climate Change Agreement in December last year along with nearly 200 other countries. The agreement called for urgent reduction in green house gases known to be the prime cause of Global warming to keep the warming below 1.5C above the 2Oth century average. Since the Paris Climate Agreement many further studies have shown that unless we urgently curb Global Warming the world including Australia will suffer severely from extreme weather, drought, raised sea levels and climate change induced famine and civil unrest. There have been world wide calls to keep 90% of Australia's fossil fuel reserves in the ground as it would be dangerous to extract and sell them. CSG mining has been found around the world to endanger the health of locals living near its extraction; a serious danger to underground aquifers and a potential earth quake hazard. Polls show that the majority of people in NSW would like to see a total BAN on CSG mining in NSW. As an older Australia I can still remember a time when Australia's international environmental reputation was impeccable. At the moment it is rock bottom as the country is trapped in a cycle of greed to sell off as much of our fossil as possible regardless of who around the world suffers. We are collectively very poor international citizens. I do not support any further CSG mining and recommend a total BAN on all CSG mining for any purpose across the state.

I understand that this application, if approved, will allow the development of the Narrabri CSG field to proceed without any of the normal environmental conditions being met. The risks to health and environment associated with Coal Seam Gas are well enough known that this bypassing of normal controls should not be allowed.
I also object to insufficient notice being given for the proposal to be properly considered by all interested parties, particularly those who would be adversely affected by it.

I am objecting to Modification 4 as it constitutes a major change and should therefore be subject to a full EIS. Moving a pilot well into a production status to supply Wilga Park power station cynically side steps environmental protections. The unique environment of the Pilliga is significant on environmental and cultural grounds. Industrialisation of the area threatens a significant recharge area for the Great Artesian Basin, which is vital for the ongoing viability of agriculture in the Liverpool Plains. Gas flaring also degrades the quality of dark sky observations by the world class Siding Springs observatory. The industrialisation also undermines the relationship between the Goomeroi people with their country by placing restrictions on movement and access to traditional lands. For these reasons I am registering my opposition to Modification 4.

While Section 28B of the Petroleum Onshore Act allows for beneficial use of gas if that gas would otherwise have been flared or released into the atmosphere as part of activities under the licence or lease, the applicant fails to provide information about how much gas is likely to be removed and utilised and whether all of this gas would otherwise have been flared or released into the atmosphere.

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.

Above all, there is no assessment of cumulative effects of all of the planned coal seam gas operations in this area.

The community opposes coal seam gas operations in the Pilliga forest and I urge the Minister to reject this modification application.

Santos must fully articulate its plans in the Pilliga, the quantity of gas it intends to extract and burn, or flare and release for proper assessment and public scrutiny before any further approvals are given.

To whom is reading this
im a 36 year old trades man with 2 trades #1 fabrication engineer
#2 communication technician. before coal seam gas i had never protested anything, now i find my self as a leader in the Anti CSG movement building camps and working with the community of NSW to fight this insane idea.
it all started with a few of my mates getting new jobs and moving north to QLD to work in this new industry. great money working on the land as many hrs as you could work. now these guys weren't greenies in any way. we all grew up on the coast surfing and building hot cars. so when they started telling me about some of the stuff that went wrong on site, with spills of water and drill mud creeks dying in days. dams putrid from there shit water. water bores with gas coming out. bubbles in the condemn river. it was a shock and i started to research this industry,
Did you know that this has never before been done anywhere in the world. Turning coal seam gas into LNG. Curtis island is the first an untested trial thats had nearly 200 billion dollars spent on it in the last 10 years in QLD alone.
Did you know that it was passed in QLD with no real impact statements and the person who passed it, did so under extreme pressure from her peers to make CSG a bankable out come. 4 corners episode,,, https://www.youtube.com/watch?v=ayhPNCUoQ7I
im not the sort of person who believes the hype, so in march 2013 i went to chinchilla in QLD and drove up to friends in gladstone only to come across horror story after horror story like the dredging of gladstone harbour. bubbles in the Condamine river. so i got on Facebook and went to meet some of the family living in the project area around Tara Chinchilla. i found that they were being branded as a bunch of weirdos and liars when all they wanted to know is if it was safe to live in a gas field, could the government do some air testing and water samples because there children were becoming sick from something in the area. and if they left the area with there kids after a few days to a week the children's nose bleeds, headaches, sore eyes and breathing all got better for all the families. I'm no doctor or scientist but i spent 6 months there with these families and saw it, i saw the parents on the phone to QLD health trying to make a complaint only to be hung up on or fobbed off.i saw baby being flown nearly on a weekly basis. so we bought some hair sampling kits of the internet from the USA and sent them off. we received a phone call from the scientist in the US who had received the sample and tested it from a 16 year old female. the scientist asked if she was still alive and recommended an immediate detox called chelation a heavy metal detox, she was full of lead, barium, uranium, btex chemicals. on the back of this we tested some water and found caesium 37 a man made radioactive compound highly dangerous. were not scientists so we sent all of the results to the national toxic network for a report to be written,,,, http://www.ntn.org.au/stop-csg/no-clean-bill-of-health-for-csg the author of this is a chemical scientist who's is the main advisor to the united nations on chemicals. armed with this evidence we went to the industry and government only to be fobbed off again. with no other option we started to protest and blockade. within 3 months QGC gas had bought out all 6 families and moved them out of the gas fields with non disclosure legal forms on them, GAG orders so they couldn't talk.
during this time i meet a fella up there making a movie called the frackman it was sponsored by dick smith and some other aussie greenies with a combined budget of nearly 2 million. with this money i helped the crew with water samples air samples and blood samples nearly 200 grand spent on testing all coming back off the charts. again the results are available on the national toxic network website. after we moved the families out of the gas field in QLD I went home to NSW determined to help stop it in NSW.
In january 2014 i moved to Narrabri the largest CSG project in NSW to work with the community out here some of whom id met in QLD. over the last 3 years we have gone community to community street by street door to door asking if you want to live in a gas field and the average percentage is 96% say no. 3.5 million hectares say a big NO to this industry. trained hundreds of farmers and small community in peaceful direct action. by this stage your probably wondering how i survived I've spent my house deposit and lived off cash donations from farmers and community. I've never received a wage from anyone, i also put on events group pictures where i fund raise, and I'm debt free so that makes it easy.
This project already has 22 spill sites, dead zones. 2 aquifers poisoned with uranium. every pond leaking from Bimblewindi, leewood, now tinsfield all 3 major site are faulty and leaking.
There 20% partner in this project has walked away stating that the gas flows are not worth the investment.
This project was devalued by 700 million $ by creditswiss in 2014 due to large scale community opposition.
Santos had the laws changed to protect there private property because they know there a huge resistance.

if this makes it to a pac i know its not worth a pinch of shit this will be the 6 PAC I've been to, where experts speak on hydrogeology water impacts, social impacts, environmental impacts. but when our experts don't agree with industry or government we constantly loose. its just a stall tactic to give the community the feeling of inclusion.

cheers Dan

I wish to oppose this developement on the following grounds
*I find it appalling to see that Santos is trying to build a CSG field in NSW by stealth
*I am also appalled that the application is not undergoing public exhibition
*Building a CSG field with no Environmental Impact Statement is sheer madness without regard for people or the environment and as such should be dismissed

Please don't continue on this path. Leave the well alone it is a sacred place.

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 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 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.

Since Santos purchased the Narrabri Gas Project from Eastern Star Gas they have been found guilty for the environmental damage they have caused over the Great Artesian Basin. Allowing this planning application to proceed with no Environmental Impact Statement or Planning and Assessment Commission public meeting is dangerous and undemocratic. The risks of the Narrabri Gas Project to land, air and water far outweigh any foreseeable benefits to the community. The communities of north west NSW have already made it clear they object to this project and it is about time the NSW government began to actually listen to farmers from the North West. CSG is not worth the risk.

Regardless of the 2008 project approval, of which any EIA undertaken would now need to be conducted again, there have been many new developments and changes to legislation. The Great Artesian Basin, upon which the Pilliga Forest sits, is an area of such significance that it is of great and national concern, this means it is an matter of National Environmental Significance (NES). The Great Artesian Basin then, is an area recognised in and subject to the Environmental Protection and Biodiversity Conservation register and Act.

The Narrabri CSG Utilisation Project MP07_0023 modification 4 should not be approved and its previous modifications must be revoked and subject to both a comprehensive EIA and approved only under the EPBC Act 2013.

Details as follow

New matter of national environmental significance - water trigger

Amendments to the EPBC Act became law on 22 June 2013, making water resources a matter of national environmental significance, in relation to coal seam gas and large coal mining development.

The nine matters of national environmental significance (MNES) are:

world heritage properties
national heritage places
wetlands of international importance (often called 'Ramsar' wetlands after the international treaty under which such wetlands are listed)
nationally threatened species and ecological communities
migratory species
Commonwealth marine areas
the Great Barrier Reef Marine Park
nuclear actions (including uranium mining)
a water resource, in relation to coal seam gas development and large coal mining development.

The clear reason for this Act and its amendment is as follows

The purpose of the Bill is to amend the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)[1] to provide for the establishment of a new matter of national environmental significance (NES), the protection of water resources from `coal seam gas (CSG) development' and `large coal mining development'. CSG and large coal mining developments that have, will have or are likely to have a significant impact on water resources will then require the approval of the Minister for Sustainability, Environment, Water, Population and Communities (the Environment Minister) under the EPBC Act. The practical effect of this amendment would be that the Minister would have the power to impose water specific conditions on large coal mining and coal seam gas projects, whereas at present this power is limited to conditioning water impacts only to the extent that any such impacts relate to an existing matter of national environmental significance protected by the EPBC Act.

As area of NES is is of National concern and for the whole community of Australia to be consulted on.

This is my submission as an individual Australian citizen.

Lauren

To Whom It May Concern

I object to the below listed Project, that Santos is intending to commence...

Santos `Narrabri Coal Seam Gas Utilisation Project (Wilga Park Power Station)
Modification 4 - Beneficial Use of Gas from Coal Seam Gas PEL 238'

It is with extreme concern on an urgent level on behalf of all citizens of our shared country and land, `Australia' that I object to this Santos Project, including...

Any other current existing ongoing Santos Projects, Gas Well Stations, Water Facilities, Power Plants, and any Project, Flare Stations, Development Planning of any kind that assists, supports and provides infrastructure and means of purpose to conduct Santos CSG, Coal Seam Gas Mining.. in this Project Location and any other associated locations for same Mining, in both the entirety of the NSW State and all other remaining states within Australia...

I also Object to Santos conducting any other Santos owned or partly owned by Santos shareholders and or funded by Santos, linked companies or Santos subsidiaries to the following,
Mining and or Industrial Activity, or similar and or different Projects and or Development Applications of any kind in addition to Coal Seam Gas Mining and related projects, in any given location both past, present and forth coming future intended Santos owned or co-owned/linked/related projects in their entirety, within the entire country of Australia.

Santos has already destroyed the Pilliga Forest in one area that they attempted to restore with failed results and the area is now dead forever. Tax payers money funded this wasted funds, there are other areas affected also and the Open Pond Water Holding Pits are also a major concern with weather events, overspill into forest/land and their gaseous toxic emissions into the air that sustains all life.

We the citizens of this country have basic International Humans Rights, to
Clean, Unpoisioned, Toxic Free, Pure, following....
Water both underground and within Rivers and Creeks and Water Aquifer pools, Land, Air, Natural Habitat for all living creatures, agricultural land to grow Toxic Free Food, and to Preserve the Ancient First Peoples Sacred Sites, Water Holes and Land that has been in their honourable guardianship for thousands of years.

It is the First Peoples of this entire Great Artesian Basin large area, that includes the Pilliga Forest, that have maintained and cared for our benefit as a nation/country to date, this precious Underground Water Resource.

We the people have a legal right to clean water, clean land, clean air, clean rivers, creeks and water systems and water aquifers and our native/agricultural animals are in current and future threat, as is our entire eco-system and us humans.

We are at dire great threat of Gas Explosions, Gas Methane Leaking, multiple chemical toxic poisioning to all our Environment, Fires that will not be able to be contained in large natural habitat and human habitat areas threatening life to all.

It has been well documented both in multi Media sharing platforms, campaigns and documentaries like... Gasland 1 and Gasland 2 in America, and here Frackman in Australia,
that indeed we are at dire great risk of FOOD, WATER, LAND, AIR, and ECO-SYSTEMS SECURITY, for all living species on this planet.

We have witnessed and still witnessing past and present the ruination of farmers, businesses, land owners, Indigenous Sacred Sites of grand scale across this entire country, let alone the Pilliga Forest Great Artesian Basin entire area...

We are witnessing the likes of George Bender and his suicide and struggle for 10 years with the CSG Industry in Queensland, and many many countless others who are on the brink of hope for their LIFE, with...
HEALTH, cancer issues, breathing issues, Skin disorders, Asthma issues, complete DIE OFFs of LAND, NATURAL HABITAT, Animals, Humans, Rivers, Creeks, all living breathing systems from microscopic to largest of trees, forests, everything that Nature has provided for us, we HAVE THE RIGHT, to ACCESS, SURVIVE and LIVE with Natures Natural Resources, without the NON-HUMAN RIGHTS behaviour of CSG Industry, being practiced illegally and wrongfully by CSG and associated Industries and Government...

I ask Santos to divest into Natural Resource Industries for the sake of our EXISTENCE please.

The State of Victoria has banned till 2020 Coal Seam Gas Fracking.
Queensland is an unspeakable criminal example of what Government has allowed and assisted CSG Industry in killing off our Eco Systems, Peoples, Habitats of all Species.

Santos you wish to at the expense of a whole State, in NSW, install 850 more Gas Wells, and the remainder of our country our home our lives our existence is at stake of being destroyed further, to what has already been proven to be a highly dangerous life threatening industry to our human existence.

I share the links below...there are plenty of scientific examples that you know exist to prove that CSG is lethally threatening to our lives and existence as a human race.

https://www.youtube.com/watch?v=LNzv0F3sLrA

https://www.youtube.com/watch?v=ayhPNCUoQ7I

https://www.youtube.com/watch?v=b61lkgfw464

http://www.edonsw.org.au/court_to_decide_if_santos_pilliga_csg_facility_illegal

Regards
concerned citizen of Australia

Santos is seeking to modify the existing Wilga Park approval to enable the use of coal seam gas from existing or FUTURE WELLS within PEL 238 WITHOUT ANY EIS. Santos' existing approval only allows them to use CSG from wells in PAL2 & PPL 3 , which has limited wells.

It is important that Santos complete another EIS for future wells in PEL 238. The process must be seen by the public to be open and transparent and not subject to favours. No one person or company should be above the legal process, after all we still are a democarcy and want no corruption.

I would like to object to the modification:

Santos is seeking approval for the following modification allowing: 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 would be in addition to the currently approved use of gas from pilots within PAL 2 and PPL 3.

Comment: We have laws and planning acts in place for a reason. Producing gas to burn to create electricity to sell is gas Production. It must require that gas obtained to fill the power station is obtained via a Production licence.

CSG exploration activities and licences in NSW are not subject to the same level of assessment as production wells and licences.

If Santos wants to sell gas into a power station, the company should first apply for a production licence for the area of their wells. Go through the proper process, and get an outcome. That is what should be expected of any company operating in NSW. The grid of gas pipelines compression stations and processing plants is already questionable to have been approved just for CSG exploration.

The community expects the best from the NSW Government and to take a firm but common sense approach to this modification.

Thank you for considering this submission. Please advise that it has been received.

Kind regards,

Submission from Armidale / Tamworth Greens
Santos Mod 4

The Armidale / Tamworth Greens would lodge an objection to Santos submission of Modification 4 of the application for the modification to the Part 3A approval to the original conditions to Narrabri Coal Seam Gas Utilisation Project which was originally granted to Eastern Star gas with the New South Wales (NSW) Department of Planning. Since 2011 Santos have applied for and been granted three (3) other modifications to the original approval all of which were small in nature.

Modification 4, has the potential, if granted, will enable Santos to use the coal seam gas from exploration wells, both existing and future build without lodging an EIS. Santos will profit from the use of this gas under the guise that the gas is for beneficial use. Santos indicate the gas will be used at the Wilga park power station, but does not limit the use to this function.
The Application states on page 2, Santos is seeking approval for the following modification allowing- Use of coal seam gas from existing or future well within PEL 238 at the Wilga Park Power Station consistent with the recent  amendment to the Petroleum (Onshore) Regulation 2007. This would be in addition to the currently approved use of gas from pilots within PAL 2 and PPL.

The application then goes on to state- This modification application applies to any existing or future approved pilot wells within PEL 238.

On page three after listing all the existing pilot wells that are outside the PAL 2 and PPL3 the application states- exploration and appraisal continues within PEL 238 and PAL 2, approval for the  installation of additional pilot wells and supporting infrastructure may be sought.

Santos is abusing the provisions of beneficial use of gas during the exploration phase. It would not be wise to flare or vent, rather than use the gas, but Santos are expanding their operations significantly without providing an Environmental statement or community consultation, under the guise of an allowable modification. By continuing to produce gas for profit on an exploration licence Santos are avoiding their social responsibility to pay royalties on an unknown quantity of gas
Santos are required to be transparent and gain a production licence, also to submit Environmental Impact Statements for every development.

There are many community concerns regarding this misuse of Section 28B of the Petrolium Onshore Act-
* There is no mention in the application 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?
* The community has 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, despite much public opposition.
* There are many unanswered questions, the amount of clearing planned in the Pilliga, and the effect on wildlife, particularly endangered species and the iconic Pilliga koala population.
* How do Santos intend to manage the issue of light effecting the Siding Springs Observatory?
* While quietly increasing production Santos will also increase the quantity of produced water. Without an EIS the community cannot comment on the plans to use the water and manage the large quantity of salt.
* Santos will be in full production by stelth, without submitting an EIS
The Minister must reject this modification application and require Santos to fully disclose their 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 without submitting and EIS.

Yours Sincerely

Pat Schultz
Armidale Tamworth Greens

I am against any modifications in this project until a detailed environmental impact study is approved detailing where waste is placed , I also am against this development due to the social and environmental impacts that this industry practices example the Surat Basin in Queensland