Narrabri Gas - Bibblewindi Exploration

Pilliga Forest coal seam gas exploration by Santos has no merit. It was a bad buy. The land should not be desecrated as has happened to date.
The Great Artesian Basin is threatened by proposed intensive drilling. Santos should just write off its Pilliga investment.
The NSW Government must insist that no drilling can commence until baseline water table data is established. If this is obtained then the water table must be monitored and results of water quality and air quality reported regularly and immediately any spill or toxic circumstance.
Thanks for the opportunity to comment. Ian Tanner

Coal seam gas exploration in the Pilliga forest to date has resulted in substantial environmental damage, including clearing of vegetation, habitat loss and fragmentation.

The Ecological Assessment component of the Environmental Impact Assessment concurs with a 2011/12 ecological study of the Pilliga Forest prepared by Landmark Ecological Services Pty Ltd (see attached). The Landmark ecological study found the Pilliga Forest to be a `Noahs Ark' or refuge for many bird and mammal species that are declining across Australia. It is considered to be of national conservation significance and is vital to the survival of state and federally listed threatened species like the Pilliga Mouse and South-eastern Long-eared Bat. Coal seam gas exploration has already caused substantial damage to the forest and progression to full scale gas production could lead to local extinctions.
The Landmark ecological study of the Pilliga Forest included intensive wildlife surveys plus the collection of existing information and analysis of scientific literature on its values. Pilliga Forest was identified as unique due to being the largest run-fragmented block of remnant dry forest and woodland remaining in eastern Australia. The study recorded 176 different species of vertebrate wildlife and 22 threatened species and communities during a 5 day survey of the forest. As well as the Pilliga Mouse and South-eastern Long-eared Bat, the latter included the endangered Black-striped Wallaby and vulnerable Pale-headed Snake and Eastern Pygmy-possum.
The Pilliga is the only place in the world where the Pilliga Mouse is known to exist, with areas earmarked for coal seam gas mining containing a number of breeding sites for this species. Coal seam gas operation are also likely to impact the important Pilliga population of Koala.
The Pilliga Forest has significant environmental and cultural significance. Both the local Aboriginal and non-Aboriginal community recognise the importance of protecting this special place and have united in opposition to the proposal. Accordingly I strongly urge the Minister to refuse the proposal.

Submission for Santos EIS - Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:

GENERAL REQUIREMENTS - Despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Santos have not yet come clean with their future developments in the area.

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.

In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. There must be thorough sampling and testing across the project area to enable modelling of regional groundwater flows and a comprehensive assessment of Groundwater Dependant Ecosystems in the Pilliga region including the potential impacts any groundwater drawdown or contamination may have.

These two Bohena wells are part of an exploration program that involves the multi-lateral drilling. The drilling through the casing of wells poses a risk to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.

BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.

AIR QUALITY - Another requirement is to assess the risk of fugitive emissions on environmental and human health. The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. There is a Native Title claim over the project area and Santos must include the Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

Please don't let this project proceed. The area is precious,and areas like these are fast dwindling with rapid exploration and expansion for development. It is wrong, it has too many risks. Companies like these should be exploring sustainable energy options, and you as government have a responsibility to be encouraging sustainable energy. This isn't. The reports may be written in a way that could convince some that they are sustainable, but we all know that this is risky stuff. The area is too precious to put it at risk. Please think hard, and think about your legislation and your constituents, and remember you can say no.

Dear Sir/Madam,

the area that you are considering mining for gas in is a precious part of our country and should be protected at all costs. I ask that you reconsider allowing this beautiful part of our country to be destroyed. I also ask that you look at the following issues:

GENERAL REQUIREMENTS - Despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Santos have not yet come clean with their future developments in the area.

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.

In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. There must be thorough sampling and testing across the project area to enable modelling of regional groundwater flows and a comprehensive assessment of Groundwater Dependant Ecosystems in the Pilliga region including the potential impacts any groundwater drawdown or contamination may have.

These two Bohena wells are part of an exploration program that involves the multi-lateral drilling. The drilling through the casing of wells poses a risk to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.

BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.

AIR QUALITY - Another requirement is to assess the risk of fugitive emissions on environmental and human health. The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. There is a Native Title claim over the project area and Santos must include the Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

Yours sincerely,

Lynne Holian

To whom it may concern,
I would humbly ask that you consider the destructive effects that allowing this project to go ahead would occur in this area.
To my understanding these valuable natural assets are available under large areas of Australia and destroying the unique biodiversity in this particular area to access them seems rather silly.
Please use integrity and some thought for our children's future before destroying this unique area and it's endangered fauna and flora.
Respectfully yours, Roger Corben

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:

GENERAL REQUIREMENTS - Despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Santos have not yet come clean with their future developments in the area.

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.

In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. There must be thorough sampling and testing across the project area to enable modelling of regional groundwater flows and a comprehensive assessment of Groundwater Dependant Ecosystems in the Pilliga region including the potential impacts any groundwater drawdown or contamination may have.

These two Bohena wells are part of an exploration program that involves the multi-lateral drilling. The drilling through the casing of wells poses a risk to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.

BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.

AIR QUALITY - Another requirement is to assess the risk of fugitive emissions on environmental and human health. The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. There is a Native Title claim over the project area and Santos must include the Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

This is a national park, this should not go ahead. The damage to the park, and all water tables involved, is a seriously worrying outcome that I do not support.

GENERAL REQUIREMENTS - Despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Santos have not yet come clean with their future developments in the area.

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.

In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. There must be thorough sampling and testing across the project area to enable modelling of regional groundwater flows and a comprehensive assessment of Groundwater Dependant Ecosystems in the Pilliga region including the potential impacts any groundwater drawdown or contamination may have.

These two Bohena wells are part of an exploration program that involves the multi-lateral drilling. The drilling through the casing of wells poses a risk to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.

BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.

AIR QUALITY - Another requirement is to assess the risk of fugitive emissions on environmental and human health. The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. There is a Native Title claim over the project area and Santos must include the Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

I believe the Pillaga's biodiversity and its strategic importance to the Great Artesian Basin would obviously outweigh any short term gain imposed by this development .

I believe we should not rush into coal seam gas exploration and exploitation until we have all the facts and until we can guaranty our water and land will be totally safe. When other countries have banned the practice of fracking, I wonder why here in Australia we ignore the precautionary principle and rush into something that could damage our future. Our politician have the responsibility to act for all Australians, not just the mining interests.

5.2.1.2 Consideration of potential issues
Impacts to groundwater have greatest potential to occur during operation of the wells but may also occur
during drilling. During drilling groundwater aquifers will be intersected, however these will be cased and
cemented in accordance with the Code of Practice Coal Seam Gas Well Integrity (DTIRIS 2012) to isolate
any water transfer between aquifers.
Drilling mud and chemical additives would also be used during drilling to control the well and bring solids to
surface. There is little risk of contamination of aquifers from this process due to the well casing.

According to this Santos Development Application extract, there is an admission of groundwater contamination during drilling, when the drilling lubrication "chemicals", are at the highest concentration and before the well casing is in place.

To: NSW Government, http://majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=5934

Re: Submission Guide for Santos EIS - Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:

GENERAL REQUIREMENTS - Despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Santos have not yet come clean with their future developments in the area.

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.

In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. There must be thorough sampling and testing across the project area to enable modelling of regional groundwater flows and a comprehensive assessment of Groundwater Dependant Ecosystems in the Pilliga region including the potential impacts any groundwater drawdown or contamination may have.

These two Bohena wells are part of an exploration program that involves the multi-lateral drilling. The drilling through the casing of wells poses a risk to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.

BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.

AIR QUALITY - Another requirement is to assess the risk of fugitive emissions on environmental and human health. The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. There is a Native Title claim over the project area and Santos must include the Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

Thank you for the opportunity to bring these remarks to your attention.

Yours sincerely,
Robert E. Rutkowski

cc:

Secretary John Kerry

Premier Barry O'Farrell

2527 Faxon Court
Topeka, Kansas 66605-2086, USA
P/F: 1 785 379-9671
E-mail: [email protected]

I totally oppose all coal seam gas activity in the Pilliga Forest. All existing activity should cease and the environment restored to its pre-existing pristine state before Santos started drilling there. THERE SHOULD BE NO FURTHER EXPANSION OF ACTIVITY OF COAL SEAM GAS MINING OR ANY OTHER FORM OF MINING IN THIS AREA. This unique habitat is home to a number of endangered species and toxic spills have already occurred. We do not need coal seam gas in our country - there are vast resources of renewable energy able to be harnessed to more than address our needs. Climate change is a real threat to all habitats everywhere, including the human species. Develop renewable energy not coal seam gas.

We destroy ourselves every day by destroying 'NATURE'.

There cannot be bigger or more un-wise than this.

No one eats his ownself when hungry.

Ur. reaction at.............

[email protected]

Gas exploration is an outdated idea, why are we mining, pillaging, and harming our environment for the sake of a depletive energy source?

I stand in favor of renewable energy, and strongly oppose any action taken to drill in the Pilliga Forest.

The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.

Drilling in this region could have a detrimental effect on our air, water, eco systems, national and cultural identity. And unless it can be 100 percent guaranteed that none of these areas will be compromised, I stand in favor of leaving Pilliga untouched by drilling companies.

It would be wonderful to see the government support a holistic, forward thinking way of life, providing renewable energy sources for future generations.

GENERAL REQUIREMENTS - Despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Santos have not yet come clean with their future developments in the area.



WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.



In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. There must be thorough sampling and testing across the project area to enable modelling of regional groundwater flows and a comprehensive assessment of Groundwater Dependant Ecosystems in the Pilliga region including the potential impacts any groundwater drawdown or contamination may have.



These two Bohena wells are part of an exploration program that involves the multi-lateral drilling. The drilling through the casing of wells poses a risk to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.



BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.



AIR QUALITY - Another requirement is to assess the risk of fugitive emissions on environmental and human health. The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.



HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.



CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. There is a Native Title claim over the project area and Santos must include the Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

http://majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=5934

GENERAL REQUIREMENTS - Despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Santos have not yet come clean with their future developments in the area.

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.

In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. There must be thorough sampling and testing across the project area to enable modelling of regional groundwater flows and a comprehensive assessment of Groundwater Dependant Ecosystems in the Pilliga region including the potential impacts any groundwater drawdown or contamination may have.

These two Bohena wells are part of an exploration program that involves the multi-lateral drilling. The drilling through the casing of wells poses a risk to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.

BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.

AIR QUALITY - Another requirement is to assess the risk of fugitive emissions on environmental and human health. The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. There is a Native Title claim over the project area and Santos must include the Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

No drill rigs in Pillaga

There are hundreds of social, economic and environmental reasons not to proceed with this inappropriate and il-advised project. The following are only exceded by the consideration that we are OBLIGED TO LEAVE THE STATE IN BETTER CONDITION THAN WE RECEIVED IT, to the benefit of our grandchildren. The fraccers who are only interested in MONEY will wreck as much of their heritage as YOU allow them. STOP this GREEDY enterprise NOW!

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have
not even been constructed.

BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.

AIR QUALITY – Another requirement is to assess the risk of fugitive emissions on environmental and human health.

HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage
requirements for were taken out of the Director General Requirements. There
is a Native Title claim over the project area and Santos must include the
Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga
and the Narrabri Local Aboriginal Land Council in their consultation.

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:

GENERAL REQUIREMENTS - Despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Santos have not yet come clean with their future developments in the area.

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. The Director General requires baseline monitoring, however there is still no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not even been constructed.

In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. There must be thorough sampling and testing across the project area to enable modelling of regional groundwater flows and a comprehensive assessment of Groundwater Dependant Ecosystems in the Pilliga region including the potential impacts any groundwater drawdown or contamination may have.

These two Bohena wells are part of an exploration program that involves the multi-lateral drilling. The drilling through the casing of wells poses a risk to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.

BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl.

AIR QUALITY - Another requirement is to assess the risk of fugitive emissions on environmental and human health. The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

HAZARDS - The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. There is a Native Title claim over the project area and Santos must include the Gomeroi Native Title Claimnts, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

Thanking you in advance for your immediate attention in this most important matter.