Narrabri Gas - Bibblewindi Exploration

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

My comments below state my opposition to the exploration drilling planned by the company Santos in the Pilliga Forrest and surrounding North West NSW region. The Pilliga Forest is an icon habitat in North West NSW and deserves respect and consideration for its role in maintaining biodiversity within the state.

GENERAL REQUIREMENTS - It is known that 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 advised of their future development plans in the area. This is clearly a breach of requirements set by the Director General and negates an approval or part approval of the submission prior to this information becoming known. It is vitally important for all the facts to be provided by Santos prior to commencement of exploration drilling as it is well known that once the first well pad is laid down that many more will follow without control, without testing, without consultation and without community support.

It is a known fact that the Pilliga Forest is an important WATER recharge area for the Great Artesian Basin. It is known the Director General requires baseline monitoring, however there is no baseline water study completed for the Pilliga groundwater systems. The aquifer monitoring bores required to do this have not been constructed at the date this submission has been lodged. This fact therefore negates any or any part approval of the Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934 due to omission of required infrastructure for monitoring.

In addition, I am advised 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. It is a tool of the extractive industries to claim they have not caused damage because there is no baseline data. This must stop and the environment must be given due respect prior to extraction processes commencing. 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. These Ecosystems support vast areas of habitat, drinking water supplies and other attached environmental considerations within the soil and the greater landscapes. The potential impacts to any groundwater drawdown or contamination must be identified prior to any or any part approval of the submission. The lack of BASIC DATA therefore negates approval of the Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934.

It is a known by the general public that these two Bohena wells are part of an exploration program that involves the process of multi-lateral drilling, even if the Director General has not yet been advised by Santos of the plans for development of CSG in the NSW North West Region. It is known that drilling through the casing of wells poses a risk to any underground aquifer system and in this region the risk is posed to the Great Artesian Basin and other adjoining aquifers. I is very difficult, if not impossible, to seal a junction between the casing and the lateral. It is also known and proven by pollution across the world by CSG drilling that polluted water cannot be cleaned once it has been contaminated and that disrupted seals cannot be adequately repaired. Water is a PRIMARY ELEMENT required for survival and must not be subjected to contamination.

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, other than the fact that the Pilliga Mouse is a threatened species. I therefore call the Director General to require that baseline ecological surveys be conducted prior to any or any part approval of Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934 in order to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl in the Pilliga Forest region as well as across the North Western Region of New South Wales. The fact this study does not exist negates approval of this submission.

AIR QUALITY - There is no data available to assess the risk of fugitive emissions on environmental and human health from the variety of toxic gases that are emitted from coal seam gas deposits. 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. I therefore submit that it is not possible to give approval or any part approval to Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934 prior to these assessments being completed, appropriately reviewed and adequately considered. The Government has an obligation to protect the health and wellbeing of the people and the environment of New South Wales and I call upon the Government to do its job correctly.

BUSHFIRE HAZARD - The Pilliga has always been, due to the nature of its content, highly susceptible to fires. I have first hand knowledge of this fact as my childhood was spent in the NSW Central Western Region and family member lived in Narrabri. We always knew of fires in the Pilliga region and also knew (and know) they are largely due to the high incidence of ironstone attracting lightning strikes. I am advised it is not unusual for the Rural Fire Service to record up to 1000 strikes, some that cause fires, over a 24 hour period in the Pilliga region.
I am advised that Santos does not appear to have a clear bushfire strategy, especially in relation to the continuous gas flaring which cannot be shut down on catastrophic fire days. I am also advised by an industry insider that the knowledge on how to actually shut down the attached infrastructure of a well that contains an operating gas flare that catches alight is not available in Australia and that an individual would need to be brought from the United States of America to carry out this work. This fact alone, therefore negates any approval of or any part approval of the Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934.
Bushfire danger, as demonstrated by the current October and November emergency situations across the New South Wales inland highlands, western regions, coastal highlands, coastal escarpments, coastal hinterlands, coastal headlands and river deltas proves the danger of bushfire.
It is fact that no other business or private individual is able to commence business without the appropriate bushfire strategy in place. This therefore negates Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934 completely as the proposal to utilise continuous gas flaring creates a continuous and immediate bushfire hazard potential. Because this proposal is situated in an isolated natural bush region does not negate the danger posed to the environment or the residents of the Pilliga and surrounds by bushfire.

CONSULTATION OMISSIONS - It is extremely disappointing that Aboriginal Heritage requirements were taken out of the Director General Requirements. I find this to be an insult to the legal process of consultation with the rightful owners of the land and the legislation under the Native Title Act. It is also an embarrassment to the government of NSW, as the Government cannot pretend that the Native Title claim does not exist and that the Aboriginal Elders have their right to claim their homeland nation.There is a Native Title claim over the project area. Santos must include the Gomeroi Native Title Claimants, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation. I do not recall information stating that the Native Title Act does not apply to New South Wales. This therefore negates approval of Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934 before such consultation takes place.

I trust that common sense prevails and that due process is followed as this submission is considered by the Minister. I expect the laws regarding protection of the waters and the lands, protection of communities (both natural and human) from bushfire hazards and the Director General's requirements for baseline data and provision of information on future development plans is requested and received prior to any further consideration given to Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934.

After many, many hours of research on the gas industry and how it operates I object.
There is more than enough physical evidence to date here in our country of the consequences of this industry. Bubbling Rivers, dead flora and fauna, sick people, toxic enviroment, these things can't be fixed.
The footprint of this industry is far to great.
I call for a ban on fraking.
I feel we have so much to loose and so little to gain if this country is to allow this indusrty to threaten the future of this country.
The science has to be governing factor.

Isn't the negative impacts seen in other countries doing this kind of exploration enough reason for you to NOT do this in Australia. Come on have some for thought for our futures, not just for now but for many years to come.

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.

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:

I am studying my Doctorate on koala conservation management at Sydney University. It is known that koalas generally do not inhabit state forests however the Pilliga Forest and Nature Reserve has become well known because of its resident koala population. The koala is under threat nationally and no State is willing to take a stand to protect the future of the species here. The species is a key stone species in Australia and is a national icon. Allowing the destruction and poisoning of yet another koala habitat is disgraceful. See below for detailed information regarding key issues for the CSG development.



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 have been doing some reading on the website. I have found out some things, which I am pleased to hear, such as the banning in the use of BTEX chemicals and the use of evaporation ponds.

Question is, what chemicals are used in place of these? And how is the waste fluid treated or disposed of? My concern is also the longevity of these mines/wells. I have been advised that volume for extraction are not maintained, and the numbers of wells need to increase exponentially to maintain output.

Also, it is good to hear that it will not be allowed within residential areas. But what is the buffer? 2 kilometres is hardly a buffer. Would Barry O'Farrell accept it if there was a proposal 2.1 kilometres from his house? I do not think so.

The disappointing thing is, this is common sense and the Government or the Department should not have had to react to the public outcry. These rules should have been put in place before applications were even accepted. The plan to accept wells in Camden or St Peters or Orford (Stanwell Tops) is just absolutely ridiculous, unethical, and irresponsible to say the least.

The effects on humans and the environment have been well publicised. I do not understand why the NSW Government, which is supposed to represent and protect the people who live in this state condones the poisoning of lands, destruction of peoples lively hoods and industry, and the poisoning of the tax payer. The effects on farmers and other agricultural industries from open cut coal mining is disturbing. This can be managed and controlled if the companies were made to operate within tighter guidelines. But with CSG and the methods employed introduce a whole new set of risks in terms of maintaining water quality, the amount of water required to be used considering a lot of NSW is in drought and farmer need to use this water too.

The effects from Santos and other operators in South East Queensland was shown on the 730 Report earlier this year.

I understand we need industry for the economic benefit of the state, and to create employment, but this is too high a price to pay for a short term gain. Xstratas actions of sacking the whole workforce in a mine in Queensland, and aiming to employ a fully non-unionised workforce I do not think demonstrates good will.

I do not understand why primary industries such as farming and thoroughbred / horse racing and wine industries are not being listened to and favourable decisions are being given to the mining companies. The farming and horse racing industries (based in Mururundi/Scone) and the wine making industries in the Hunter Valley have been there for years and bring in export dollars and foreign investment, and employ way more people than CSG can on a long term basis. So why are these industries being put at risk of being damaged/shutdown? Bylong Valley is another area which should be protected.

Manufacturing is being allowed to decline. The closure of the Electrolux factory in Orange should be of major concern to the NSW Government and would employ a lot of locals and would have for many years.

Pipelines are not permitted within the 2 kilometre buffer zone, but are permitted subject to approval? It's a contradiction. All these developments are in rural/bush areas. What is going to stop a pipeline from catching fire during a bush fire?

The fact that mercury has some how mysteriously gone missing at the Orica site at Port Botany is another example. It is obvious that it has leaked into the local area, and probably into the port itself. Yet no warning have been given to the public about the mercury and many other carcinogens that have leaked into the environment in the area. One local has raised concerns about the remediation process that took place along foreshore drive and where the waste was relocated to? It took 20 years, possibly more for any action to be taken by the company to attempt to resolve the issue. Yet it appears there has been a major effort to not make any of this public? Has any action been taken against Orica/ICI or the damage done? Any financial penalty for the crimes committed? Has anyone been held accountable or convicted for negligence?

It has been displayed many times the mining companies ineptitude and disdain for complying with regulations and ability to operate without damaging the environment. Sugarloaf is a good example. And the EPA's/Governments history of not taking action to make these companies accountable further reduces my confidence in everyone's ability to operate within the laws and regulations defined, let alone what should be put in place.

Anyway, back to the exclusions. I believe all State Forests and National Parks, Water catchment areas should be excluded. A buffer zone of at least 10 kilometres should be implemented, and pipelines should not be allowed within the buffer zone, no exceptions.

With regard to the Water Catchment, The Water Catchment Authorities recommendations which were in a report and submitted to Government should be followed in full. The protection of the water supply should be the number one priority.

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.

Kind regards,
Michael Turnbull

I strongly object the Bibblewindi Gas Exploration Pilot Expansion as it is a direct long-term threat to the health and well-being of the land, the water and the air in this region and beyond.

CSG has been shown to be an unstable, water-intensive, toxic, non-renewable source of energy. Despite plausible deniability underpinned by interest-conflicted scientists and corporate lobbyist-funded research on the environmental impacts of CSG mining and exploration, it is well known by those who have been direct witnesses to the detrimental impacts of such mining that the ramifications of CSG mining are overwhelmingly negative upon the ecological health and functioning of the surrounding areas, poisonous to nearby life and difficult to control and maintain over long periods.

We have ample, viable sustainable and renewable energy alternatives available to us in this country and around the world. Through the ever increasingly efficient use of solar, wind, geothermal, wave, tidal and magnetic energy sources Australia can easily meet the energy requirements now and into the future. To consider opening one more CSG mine or exploratory hub in the Bibblewindi region is inconceivably unnecessary and worse, damaging to the local ecology and communities.

Consider the irreversible impacts of fracking to the local water basins and the surrounding rivers. Consider the huge quantities of methane that are released (controlled and uncontrolled) into the atmosphere (and I will remind you at a far more damaging rate to global climate and temperatures than Carbon Dioxide). Consider the local residents whose land values will never improve when surrounded by or scarred by the ugly industrial machinery slurping up unnecessary gas to temporarily achieve our energy 'fix'. Consider the damage done to the florae and faunae in the immediate surrounds of rivers and unpredictable gas release points who can longer tolerate the toxicity of their water supplies and will perish as a result. Consider the irreversibility of this damage to the land, the water and the air and ask yourself if you would like to live next to a CSG mine. Consider those who must live near by and the potential hazardous and deadly effects of methane gas leaks (airborne and through their water sources) and the documented nose-bleeds, headaches, tumours, breathing difficulties and general malaise that have been experienced by others in close proximity to such mines. Consider the general pollution of the land, air and water and the need to then safety store the toxic flowback water from CSG mining and hydraulic fracturing in huge quantities for long periods of time. Let alone the fact that after hydraulic fracturing is completed, a mixture of hazardous chemical compounds remains underground.

The CSG mining and energy companies and their heavily-pocketed lobbyists might apply weak environmental caution in their application of environmental 'safety' in their day-to-day activities. They may claim plausible deniability of any negative impacts on the local ecosystem and residents. They may claim that these mining ventures are economic boosters to the region and that such energy reserves ought to be extracted for our energy demands and requirements. But these are outright lies. Humans don't need to pump poisonous liquids mixed with fresh water into our earth at such high pressures that the very land itself cracks, just to be able to sustain our lifestyles. This is such an obvious fallacy.

Why must the 'fracking' fluids contain benzene, toluene, ethylbenzene, and xylene, uranium, Bromide, lead, cyanide, nitrate and Monochloramine (aka. mostly poisons!!)??? Why? What benefit or impact could this possibly have on the immediate land, soil and water except to pollute this area with devastatingly toxic chemicals and known carcinogens for how many years to come? This is outrageous, unacceptable and categorically detrimental to the ecosystems and life in the surrounding areas and should not be considered as a potential 'option' for even a split second.

It's even well-known that such practices directly impact the tectonic plates and cause seismic disturbances. In the United Kingdom in 2011 the British Geological Survey confirmed seismic events were a direct result of drilling and fracking activities by Cuadrilla Resources.

On the driest continent on earth, water is our most precious resource. Despite this, the current mining boom is putting at risk our drinking water catchments, our underground water resources, and our rivers and wetlands. What of the impact of those poisonous and carcinogenic chemicals on the water catchments, basins and rivers in the nearby areas?

Our best food-producing lands and our finest natural areas are at risk from inappropriate coal and gas mining. Mines encroach on towns and villages, harming quality of life, devaluing properties and destroying and dividing communities. Other industries such as agriculture and tourism face labour shortages and rising costs whilst losing land and assets to mining. CSG mining is known to result in by-products including salty water which contains toxic and radioactive compounds and heavy metals. As a by-product of coal seam gas operations, salt has the impact of salinification of the soil with major adverse impacts if it enters the surrounding environment (and we're already on an extremely dry continent).

Australia is already the world's highest per capita emitter of CO2. In 2010, Australia was the world's largest coal exporter (298 million tonnes). Coal seam gas is predominantly methane which has a far greater greenhouse footprint than CO2. Methane is 72 times more potent than CO2 over 20 years and 25 times more potent over 100 years.

The coal seam gas industry frequently states that "gas is up to 70% cleaner than coal." This is a best case scenario comparing the most efficient gas-fired turbines with the least efficient coal-fired power stations burning the most polluting brown coal.

The 70% figure does not include the emissions involved in producing the gas - the drilling, fracking, compressing, pumping, liquefying and transporting the gas; nor the loss of carbon-storing forests and woodlands cleared to make way for gas wells, pipes and other gas-field infrastructure. Research from the US indicates that methane leakage or "fugitive emissions" in the unconventional gas industry may cancel out any greenhouse benefits of gas over coal or other fossil fuels.

Coal Seam Gas and the proposed Bibblewindi Gas Exploration Pilot Expansion are unwanted and unnecessary. Coal Seam Gas is not safe, not clean, not good for the economy, unwanted by the locals, unnecessary for our energy supply, categorically detrimental to the environment, doesn't boost jobs and the local economy as is purported, and Australians are fed up with these projects, plans and proposals. We want to protect our land, water and air and safeguard them from the devastating impacts of mining exploration and CSG, not encourage further development and growth of this toxic, non-renewable fossil fuel industry.

Please do not approve the Bibblewindi Gas Exploration Pilot Expansion. Please do everything you can to put an end to this unsustainable, dirty, poisonous practice once and for all.

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.

SUBMISSION ON THE DRAFT MINING AND EXTRACTIVE INDUSTRIES POLICY of Narrabri Shire Council November 2013

I am writing to object most strongly to the presence of Santos exploring for coal seam gas in the Pilliga Forest, Narrabri.

Unless Santos can provide scrutinised scientific data to back up their claims of `no harm' this company should not be given the approval to continue.

The Gomeroi traditional owners and the residents of Narrabri Shire need clear leadership from Council and the Government regarding this issue.
Why should any company be allowed to pursue a controversial extractive industry when the science has not been done and the findings of the Chief Scientist of NSW, Mary O'Kane's investigation into the Coal Seam Gas industry in NSW has not yet been completed?
Until these findings and recommendations have been published and discussed with the community Santos must not be allowed to proceed.
Also the Narrabri community has not given Santos a social license to continue with a local survey indicating Narrabri and NSW resident's lack of trust of this industry.

Water is our most critical resource and as the Pilliga Forest is a vital recharge area for the Great Artesian Basin this area should not be placed at risk with the establishment of coal seam gas wells.

Also the biodiversity of this region is at risk from fugitive emissions and contamination from the coal seam gas extraction process.

Consultation with the traditional owners and the residents of the Narrabri area have also been woefully inadequate.

Therefore, I call on Council and the NSW Government to call a halt to this project until it can be categorically deemed safe and risk free to continue.

I am particularly concerned about the risk of permanent contamination of artesian water supplies.
Evidence from USA has clearly pointed to this as a high risk which companies involved in CSG exploitation have not adequately addressed.

It is vital that we stopped destroying valuable natural reserves, food producing land and using and contaminating important water sources in the name of the economy and profits. We can and must change to renewable energy sources now, while we still have access to affordable carbon based energy. The formal submission is below.
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.
Dr Clare Rudkin

Dear Director General,

Having recently visited the Pilliga to gain first-hand knowledge of what the NSW government is putting at risk by allowing CSG exploitation there, I respectfully make the following submission:

GENERAL REQUIREMENTS - Despite your office 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 on their future developments in the area.

WATER - The Pilliga Forest is an important recharge area for the Great Artesian Basin. Your office 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 have 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 Claimants, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

What madness has possessed our State Government? I for one am whole-heartedly opposed to any CSG activity in our Pilliga. Thankyou for your consideration of my submission.

I am concerned about the effects of Bibblewindi Gas Exploration Pilot Expansion on the water table.

I understand that area is an important part of the Great Artesian Basin and any contamination or breakage within that system would have dire circumstances for residents, bore water users - especially primary producers, and the natural environment. A problem that could not be easily fixed, nor easily compensated.

It is also with great concern I perceive the potential negative impact this exploration will have on the surrounding biodiversity, air quality, and will be a future risk in relation to bush fire.

It is my opinion that Santos has failed to meet the Director General Requirements for this project and the Department of Planning should undertake a Environmental Impact Study.

The risk to our waterways is far too great to proceed without one, and the stories from residents and landholders living near other CSG projects are too worrisome to risk without further investigations.

Thank you.

Information uploaded below.

Bibblewindi Gas Exploration Pilot Expansion SSD 13 5934

Friends of the Pilliga is a small community-based environmental group based in Coonabarabran. We oppose the proposed extension of the existing Bibblewindi Multi-lateral Pilot on the grounds that the EIS does not fulfill a number of requirements.

Multi-Lateral Drilling
While it appears that Bibblewindi 31 and 32 are not yet multi-laterals, their construction method will allow for additional laterals in the future. This has the potential for substantial leakage of gas and water both to the surface and between aquifers. It is a risky activity.

Groundwater
Statements in the EIS are based on a model, developed from data gathered far from the proposed development. This cannot be extrapolated to the development site. There is no actual baseline data and to acquire these data would require 2 years results from monitoring wells in the area. These do not yet exist. By commencing drilling before the data are available the results are already skewed.

Air quality
No baseline data exists for air quality either.

Water courses
It is a misunderstanding to state that there is water in the creek lines only intermittently. The water courses may be filled with sand but when you dig down a short distance you almost invariably find water. The ecosystems of the Pilliga depend on this water and we should not risk contamination or depletion.

Waste Water
It is unclear from the EIS the quantities of water which will be produced, how the water will be treated at Leewood, or what will be done with the treated water and the extracted salts. Volumes of liquid to be moved in and out of the area are also unclear or confusing.

Biodiversity
It is apparent that there will be a significant, long term increase in the number of traffic movements once this project restarts, far more that the stated "minor increase" of 16 vehicle movements per day. It's already greater that this and will continue to be so during drilling and decommissioning stages. It's the longer extraction stage which brings the average down. The current speed limit of 20km/hr is generally ignored by project traffic. It's hardly likely that this will change in the future. This greatly increases the potential for incidental road kills and hence biodiversity impact.

Concerns about noise impacts concentrate only on residences. There is no reference to the impacts of 24 hour noise and light on the fauna. Already there is a constant low background hum when wells are active. This disrupts the behavior of species such as bats which are dependent on echo-location and may affect the behavior of Pilliga mice. Permanent sources of light at each well pad in the middle of the woodland similarly disrupt movement through the area by native fauna, either attracting or repelling.

The EIS reports finding no exotic plant species in the bush around the proposed well sites but at the same time indicating that exotic grasses are found on these sites themselves. It is only a matter of time before the exotic weed species spread into the natural areas. This would be exacerbated by the increase in the number of traffic movements bringing in weed seeds and spreading them along roads and tracks.

The increase in traffic would also increase the possibility of wildfire either by arson or by accidental in an area which is already fire prone.

The possibility of the introduction of Phytophthera is considered within the EIS, stating "Vehicles to be washed and cleaned where exposed to noxious weeds and unwanted plants". This is inadequate. Mitigation measures will not stop the spread of Phytophthera. It has already been identified in the southern parts of the Pilliga and could impact heavily on the timber industry should it be brought into the northern Pilliga. Prevention is the only alternative. Vehicle hygiene should be carried out stringently on both entering and leaving the area to prevent both this and the introduction of non-native plants.

Consulation
Santos has taken a very narrow view of what is meant by consultation and who are the stakeholders. Consultation has generally meant that the company telling you what they are doing. They don't ask you opinion on how they are doing it. This isn't consultation.
Stakeholders are considered to be the people in the immediate area of the proposal, where almost no one lives and the towns of Narrabri and Gunnedah. The Coonabarabran and Baradine communities are ignored and advertisements for consultation appear in only the Narrabri and Gunnedah media, not Coonabarabran. In fact the entire population of NSW should be considered as stakeholders.
They have been very selective in which Aboriginal groups they consider to be stakeholders as well.

Cumulative Impacts
As each small step of this huge multi-stage project gets approved and goes ahead, previous approvals are used to claim that it is all safe and under control. It is "death by 1000 cuts". Each step is in itself minor and has little impact but the longer term cumulative impact is dismissed. Each step has an impact but that impact can be dismissed as minor and eg fauna can go elsewhere. In fact this is a sanctuary in a widely altered landscape and accumulation of impacts on fauna, water, air causes increasing degradation each step of the way.
This is the slow replacement of natural landscape by an industrial landscape. It should be stopped before each step is used as justification for the next step.

I am someone with history and connection with the Pilliga area and I strongly oppose the Bibblewindi Gas Exploration.

The Pilliga forest is an ecosystem and habitat of national significance. Not only is it home to a number of endangered and threatened species, it also provides crucial ecosystem services to the local area. Not to mention it is one of only a few intact inland ecosystems of a significant size. There is a lot of unknown impacts associated with gas exploration and extraction, particularly on ground water. If anything were to happen to the ground water out here, whole livilihoods would be gone. Can you imagine the sheep and crop farmers around Pilliga being able to continue their farming without healthy water supplies?

On the other hand, the Pilliga area has some of the world BEST solar resources. We know solar is clean and available. Why on earth would a government take necessary and irresponsible risks when there are readily available energy alternatives. A solar thermal plant, like those already operating in the USA and Spain can provide baseload power and storage - which are the two arguments most commonly cited for requiring gas for electricity.

We don't need more gas and we certainly don't need more environmental degradation.

I urge the government to do the responsible thing and not approve this, or any other, gas exploration license in the Pilliga region.

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

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.

It is a sad fact that no matter what is said about conservation and protecting our natural underground water, our forests & the biodiversity of our country, the various government entities still allow submissions from large mining company's to mine sensitive areas of the country.

What of the voiceless creatures that will be disadvantaged by any form of mining, who will state their case, certainly not anyone from a governmental position otherwise we would not be objecting to this mining proposal.

We constantly hear arguments that it is good fro our country's economy, good for jobs, good for exports, but little consideration is given to the bad points.

Destruction of pristine areas and all for a quick dollar which in most cases goes to those who couldn't care less where the money comes from, as long as their bank balance grows, without consideration for the legacy that will be left to our future generations yet to set foot upon our land.

We do not own this land that we inhabit, we are merely custodians for generations to come, I dread to think what are they going to say in judgement of the people who allowed this to happen today.

Please see attached.

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.