Mod 4

As a resident of the adjoining PEL450 I wish to lodge an objection to Modification 4 - Beneficial Use of Coal Seam Gas from PEL238 by Santos.
I am appalled at what appears to be complete bypassing of proper process without adequate scrutiny by concerned and affected community members. Santos seems to be using a loophole regarding so called "beneficial use" to push aside required assessment before any expansion to the number of wells and their use for production and in addition infrastructure that they might need - it would amount to "production by stealth". There are a large number of reasons for my objection to this modification :-
* Santos have not yet produced an EIS for the project despite being 2yrs overdue. This modification does not assess disturbance to forest or threatened species caused by well or pipeline construction. Nor does it yet provide any solution to salt produced from the proposed Leewood RO plant operation.
* using this loophole allows Santos to avoid royalties to NSW taxpayers for this gas - so it's not very financially "beneficial" to taxpayers just to shareholders!
* right across the North West of NSW communities and LGAs have expressed strong opposition to CSG production in the Pilliga and elsewhere, with many councils passing resolutions to this effect. There is no social licence to expand this project in any way and especially without public scrutiny of such a modification to their current operation.
* the Santos application is short on detail - how much gas will be removed and used, what will that impact have from the power station, what provision is there for monitoring 'fugitive emissions' or health implications of "additional wells and supporting infrastructure" into the future.

The Minister should completely reject this poorly detailed application for modification which appears to be an open ended application for "open slather" production through the back door with completely inadequate assessment of impacts on water, health, threatened species, forest integrity, air quality and dangerous methane fugitive emissions from an unspecified expansion of wells and infrastructure.

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/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.
Also taking into consideration the impact on the true an entire traditional Gomeroi people's, their sacred areas and the land, animals and plants that is not yours to destroy !!!
Thanks for the opportunity to make a submission.
With great concern, Helen

Armidale Action on Coal Seam Gas and Mining is grateful for the opportunity to have its views in the matter of Modification 4 considered.
AACSG&M is gravely concerned regarding a number of aspects of the Modification and consider that the ill-conceived amendment in 2015 to the Petroleum Exploration Onshore Act of 2007 (PEOA) is being used by Santos to effect a movement from exploration into production covertly There is inadequate, or indeed no, information in Santos' proposal concerning:
 the environmental impact of using this gas in the power stations relative to flaring or releasing it  the amount of clearing that would be required for the necessary water and gas pipelines  at what time royalties would become payable and at what percentage scale. Currently, it appears that NSW will derive NO direct financial benefit from any gas produced CSG production in the Pilliga has been rejected by the community; Santos and the Government have no social licence.
This modification allows a devious bypassing of proper process.
The Minister must reject this application and require Santos to fully declare its intentions in the Pilliga; the quantity of gas it intends to extract and burn, or flare and release, the length of time it intends to continue expanding its exploration activities and whether this will go beyond the 850 wells already planned, with inadequate environmental concern and public scrutiny.
Kind regards, AACSGaM per Jan Brahe, Treasurer.

To whom it may concern
I object to Santos `Narrabri Coal Seam Gas Utilisation Project (Wilga Park Power Station)
Modification 4 - Beneficial Use of Gas from Coal Seam Gas PEL 238'.
I am objecting because of the growing body of evidence, in Australia and internationally, that coal seam gas mining (CSG) has catastrophic effects on the environment and public health, and that too little is being done to restore the destruction mining companies inflict.
I am concerned that (to date) it appears that no-one is held accountable for the destructive consequences of CSG, especially environmental and agricultural ruin that cannot be undone; mining companies seem to up and abandon the devastation they wreak, while politicians continue to politic and deny their culpability. I don't trust that any proposed CSG mining contracts and/or protection agreements are worth the paper they are written on.
The risk to human and environmental health, as a consequence of coal seam gas mining, cannot be ignored. Australian citizens have a legal right to the safety and protection of our water systems, agricultural resources and native environment. And it is the duty of Australian government officiates to act under their sworn allegiance to protect both citizens and country to guard both.

SUPPORTING REFERENCES
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

Yours sincerely
Tracey Rieniets

Submission to be uploaded-- see file attachment 1

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I'm writing to request that the Modification 4 (Beneficial use of Coal Seam Gas) near Narrabri is rejected. I understand that this means that further development of coal seam gas can move ahead in and around the Pilliga State Forest and surrounding lands.

I have spent several months around the Narrabri district in the last 2 years, and have followed with interest the fate of the Pilliga Forest which is such an important recharge area to the Great Artesian Basin, so it is because of this I am writing to request that you reject this proposal. Santos have been proven as ignoring 'world's best practice' on many occasions at it's mining sites and I have witnessed spills from their exploratory wells which continue to poison surrounding soils, flora and fauna.

Santos' initial Review of Environmental Factors (REF) application for the Leewood water facility was riddled with `inaccuracies' and `inadequate' information. To your credit, the Government, including your division of Resources and Energy, asked Santos for further information to address fundamental problems in the project design or risk the application being rejected. However, Santos' response has been anything but reassuring. It shows that the project is fundamentally flawed and cannot be solved with quick tweaking.

Water is such a vital resource in Australia, particularly aquifer water, without which inland Australia and all its industries cannot be sustained. Regarding CSG activities, the Groundwater Essentials, by the National Water Commission, 2012, found that,
'The pumping of groundwater lowers the watertable immediately around the bore, causing a dimple, called the cone of depression, to form in the watertable around the well. The cone of depression grows larger as the pumping rate is increased but once pumping stops the watertable will eventually return to its original shape, although the water quality may have changed.' (p.23)

'Extraction of water from a bore lowers the water level in the aquifer around it. Water levels will drop in other bores supplied by the aquifer, reducing the rate at which water can be extracted. Generally, closely spaced bores, together with high extraction rates, cause the greatest water-level interference. It is therefore important that the regulating authorities and neighbouring bore owners are consulted to ensure the location of a new bore minimises interference on surrounding bores. State and territory government water plans take this into account when allocating water extraction licences.' (p.26)

'Failure to address the range of challenges to the sustainable management of groundwater in Australia could result in irreversible degradation of this vital resource. Degradation may, in turn, lead to long-term detrimental impacts on industries, communities and environments that rely on groundwater.' (p.27) This does not include Cesium 137, lubricants and other toxins used in the gas extraction process.

Well casings are very unreliable: All gas drilling casings inevitably all deteriorate over time (http://oilprice.com/Energy/Energy-General/Shale-Gas-Casing-and-Cementation-Will-Fail-but-When.html). Initially, gas wells will cause depressurisation to the Basin causing private bores to cease, meaning an end to the properties and communities it sustains. But with the casing deterioration, the Basin will be irrevocably contaminated which spells disaster to a water poor environment.

The NSW Government specifically requested additional details of soil monitoring and location of monitoring stations in the treatment of produced water. Santos dodged the question and replied `the potential for impacts to groundwater are considered negligible'.

At the end of its exploration activities in 2018, Santos estimates that up to 500 million litres of concentrated toxic brine may be stored in the mega-dams at the Leewood water treatment plant. The Government raised concerns that Santos has no way of disposing of this waste.

Santos has dismissed the concerns outright stating, they 'commit to within two years to lodge a plan for the processing of brine, transport and disposal of salt`. This is not good enough! Santos have admitted that radioactive material will be present in the produced water, however they do not outline any ongoing testing to monitor the levels in the irrigation water. The Government raised concerns about Santos' plans for reusing waste water from the plant for agriculture, including that the soils on the irrigation site are highly unsuited to irrigation and that test crops proposed by Santos are likely to fail. Santos did not change or update its plans.

I am deeply concerned about the potentially serious environmental harms inherent in Santos' plans for CSG expansion in the proposed Pilliga gas field and their lack of knowledge and consultation with local Gomeroi/Kamilaroi who are very much against this development. I believe that this project could have a significant impact on the environment. This type of project should, in future, be assessed by a full INDEPENDENT Environmental Impact Statement (EIS).

Given the multiple problems and manifest inadequacies of Santos' plans, we cannot afford to risk our precious groundwater, cultural and an agricultural heartland being left with a toxic legacy. I would argue that there is no beneficial use of coal seam gas.

Claudia Caton

Thank you for the opportunity for input on decisions that could potentially affect the public in such a detrimental way.

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