Narrabri Gas - Bibblewindi Exploration

Please find attached my Submission to the Bibblewind Gas Exploration Pilot Expansion.

Kind regards,

Lisa Norman

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.



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.



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.



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.



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.



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.

Santos EIS Bibblewindi Gas Exploration Pilot Expansion SSD 13_5934
This EIS is seriously deficient. It doesn't meet the Director-General's requirements on a number of matters discussed below, in particular the likely interactions with proposed gas exploration and production, i.e. future developments and cumulative impacts.
The EIS appears to rely on the multiple Review of Environmental Factors (REF) assessment documents lodged with the Maitland office of NSW Mineral Resources some time ago, which were not made publicly available online as they should have been. The recent approvals by the NSW Division of Resources and Energy of eight coal seam gas pilot production wells in the Pilliga forest of North West NSW appear to ignore proper assessments, and to pre-empt the Department of Planning processes in an area of significant biodiversity and biophysical importance for the region.
The Pilliga feeds the Murray-Darling catchment, is a Great Artesian Basin recharge area, a Tier 1 Biodiversity Hotspot and a globally identified Important Bird Area. It's certainly no place for a gasfield. It is unacceptable that NSW Division of Resources and Energy approval has been given without comprehensive assessments and baseline data.
Additionally, the Department of Planning processes are deficient in that they apply only to the actual physical site of development, with no clear mechanism to consider the cumulative impacts on the whole region of any proposed expansion. The effects of x ha of clearing for 8 new well pads etc. are significant, but will become an absolutely catastrophic fragmentation of the forest if/when the proposal is expanded to 1000 wells and infrastructure, as foreshadowed by Santos and Government media releases.
This Santos project will cut up the Pilliga Forests into a draught board of gas wells, pipelines and roads, the details as yet unspecified, but with serious cumulative impacts. Such fragmentation will result in the loss of threatened species habitat and lead to invasion of feral animals and weeds. Expansion to the originally proposed 1,000 wells in the Pilliga will effectively destroy the self-sustaining integrity of the forest.
No approval of the initial stages should be given until the NSW Chief Scientist has completed her report and recommendations into coal seam gas in NSW, and until Santos has produced a detailed risk and water management plan that will be enforced by the NSW Government, addressing exactly how they will deal with the production of CSG contaminated waste water and salt from all their proposed drilling activities in the Pilliga forest. This plan must be available for public, government and independent scientific scrutiny. The current EIS does not address these issues and does not meet the Director-General's requirements.
Problems and failures with specific issues in the EIS.
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. Independent studies have shown that most of the Pilliga ecosystems are highly groundwater dependent, and likely to be severely impacted by drilling for gas wells. (....). There are no grounds to conclude that the cumulative effects of an expanded project will be negligible or acceptable just because this initial EIS has found no expected local impacts on nearby bores or surface aquifers from these two new wells. There is a serious risk and likelihood of contamination of the Great Artesian Basin and other aquifers since the drills must go through the southern recharge area of the GAB to access the coal seams beneath it. Such impacts would be irreversible, so the risks are unacceptable.
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 whole 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 of any groundwater drawdown or contamination by leakage of produced water. The whole project and expected expansion beyond the Pilliga should be referred to the Commonwealth Scientific Panel for assessment under the water trigger legislation, and this initial project should be modified to start collecting and publicising data for the full assessments
Contamination risks: These two Bohena wells are part of an exploration program that involves multi-lateral drilling. The drilling through the casing of wells poses a significant 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. This increases the risk of contamination of underground and surface aquifers by leakage of produced water and its contained toxic coal seam chemicals.
Waste water: Santos has yet to finalise an adequate or enforceable plan to deal with the millions of litres of salty waste water that will be produced in PEL 238. The critical issue of waste water management, the issue that has plagued coal seam gas development in NSW to date has not been adequately dealt with.
Contaminated waste water transfer into the new large Leewood ponds for ongoing open water storage is not a long term or sustainable water solution, and fails to deal with safe disposal of the large amounts of salt and toxic heavy metals brought to the surface in the produced water from the coal seams. The NSW Coal Seam Gas Inquiry recommended that the NSW Government ban the open storage of produced water.
Santos' plans for waste water treatment outside of this pond storage are not clear. They discuss sending 35 trucks of waste water per day to Sydney. Other statements say they will re-inject water into aquifers and/or build a reverse osmosis plant. A clear, proven and accountable plan and facilities for water treatment must be finalised before drilling commences.
BIODIVERSITY - Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. They try to minimise potential impact by stressing that ha of clearing is only a small percentage of the total area, but this is not a relevant consideration. 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 and to underpin any proposed mitigation measures.
The Pilliga is listed in "Biodiversity hotspots of Australia" by the Federal Environment Dept. See SEWPAC 2009, http://www.environment.gov.au/biodiversity/hotspots/national-hotspots.html.
This Commonwealth report specifies the Brigalow Belt North and South as a biodiversity hotspot, one of 15 in Australia and only 2 in NSW. The biodiversity hotspot concept identifies "exceptional concentrations of endemic species that are undergoing exceptional loss of habitat."
The Pilliga Forest is listed as an Important Bird Area. In 2009, BirdLife Australia (then Birds Australia) released a report on Australia's 314 Important Bird Areas (IBAs), which are areas recognized as globally significant sites for bird conservation. To qualify as an IBA each site must meet the criteria developed by BirdLife International. The Pilliga is one of only a few such areas listed in NSW, which would be seriously degraded by proposed coal seam gas mining.
The Pilliga forest is found to be of "National Significance" according to the report of a study carried out by independent ecology experts in October 2011. This focuses on the area specifically targeted by the Santos proposal and was publicly released in about October 2012. It identifies a number of important species not noted previously and the risks from coal seam gas mining. It was available to Santos and should have been used. http://www.stoppilligacoalseamgas.com.au/wp-content/uploads/2011/12/PILLIGA-ECO-REPORT_Web2.pdf

AIR QUALITY -Santos is required to assess the risk of fugitive emissions and dust levels during operations on environmental and human health. There has been no baseline atmospheric methane data collection against which to assess any future potential fugitive emissions, and no Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information. This information is needed for any meaningful assessment of cumulative impacts of planned expansion to 1000 wells in the Pilliga and many more wells in the PELs underlying the whole of the surrounding agricultural region.
HAZARDS - The whole Pilliga area 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 lightning strikes over a 24 hour period in the Pilliga region. This poses a high risk of wildfire ignition, a risk which must be greatly enhanced by the presence of numerous coal seam gas wellheads with unmeasured/unknown leakages and fugitive emissions of methane.
Santos does not appear to have any clear bushfire strategy to address this risk, especially for gas venting and flaring which cannot be shut down on catastrophic fire or total fire ban days.

CONSULTATION - It is extremely disappointing that Aboriginal Heritage requirements were taken out of the Director General Requirements. Gomeroi Native Title Claimants have demonstrated against the project because of insufficient consultation about their 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, along with local landholders and concerned farmers who have also protested about inadequate consultation.
There is no social license for the Santos project to proceed with coal seam gas drilling in the face of widespread community opposition and protest, especially when Company has approached the Forestry Corporation to obtain closure of the forest in order to deter peaceful protest.

FALSE CLAIMS:

The EIS p 34 makes a dishonest claim in Table 21-1 Environmental considerations:

""The beneficial aspects of the proposed activity provides significant GHG mitigation potential through the supply of CSG for power generation, which represents a 58 per cent emissions saving (per GJ) over more traditional large-scale energy sources such as coal".

The proposed activity is to produce CSG for export, not for use in NSW power generation. Emissions per unit of electricity produced by burning CSG are not less than for burning coal when emissions for the whole CSG production cycle, including mining, liquefaction and transport, are included in the calculations.

Moreover the rises in price of energy for household consumption will not be alleviated for NSW by rapidly extracting CSG to "save the State from an impending gas shortage", as claimed by Minister Hartcher and by gas companies. Gas prices are rising because of construction of processing plants and export terminals in Queensland, and a rush to export high volumes of CSG while the price is high - not because of any impending shortage of supply.

The Orwellian direction of Minister Hartcher to use the term "natural gas from coal seams" in place of "coal seam gas" is not likely to convince the general public that it is a good idea to extract all the gas you can find as quickly as possible, while effectively downplaying or ignoring concerns for likely impacts on the environment, aquifers, catchments, and productive agricultural land.

We believe consent should be withheld for this project unless and until the proponents have comprehensively committed to supplying all the information required by the Director-General, including assessment of future cumulative impacts.

This submission has been compiled by Beth Williams on behalf of Armidale Branch of the National Parks Association of NSW. 6th November 2013.

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.
The Queensland Government is all ready destroying there state, so why don't we just wait and see the damage that it is doing and be grateful that we didn't follow suit, surely some politician has half a brain and realises our country is worth more than a quick money fix.

Dear Sir,

I write as an Executive Committee member of the Upper Mooki Landcare Group, to express our groups concerns about the development of the Bibblewindi Gas Expansion Pilot Expansion in the Pilliga Forest, and the possibility of its expansion outside the Forest.. We have been following closely the activity in the Pilliga Forest, and respond to the Director Generals Requirements as follows.

Our Landcare Group is situated at the southern end of the Liverpool Plains, based at Warrah Creek. We have been observing the action and developments by Santos in the Pilliga Forest with great concern, as this company has purchased property at Warrah Creek. On this basis we can only surmise that, despite Santo's recent public statements that they plan only to explore and extract in the Pilliga Forest, their long term plan includes expansion across the Liverpool Plains. Our Warrah Creek community has declared that this industry is not welcome, and no social
license has been granted to Santos within our community following a recent community survey.

Our group is concerned about the effects on water, as 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 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 draw down or contamination may have.

The 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 laterally drilled well.
Santos have stated 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

Our members are concerned that risk assessment of fugitive methane emissions on environmental and human health, (or baseline data for atmospheric methane emissions) through the Health Impact Assessment process for this development has not occurred.

Most of our members are also members of local Rural Fire Services and are aware that the Pilliga is highly susceptible to fires, due to the high incidence of ironstone attracting lightning strikes. During visits by our members to the Pilliga on Santo's information days it appears that the company does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

Our members are also concerned 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.

Thank you for the opportunity to submit on this application. Our organisation objects to this development, and are concerned that it may be the pre-curser to further unwanted and unneeded high risk developments in the Liverpool Plains.

The North Coast Environment Council objects to this proposal. See attached submission.

The Piliga Forest is an area of outstanding natural beauty and significant biodiversity and the proposed expansion of CSG by Santos represents a real threat to this unique ecosystem .This vast and precious area of wilderness needs to be preserved and protected for the benefit of present and future generations of Australians and should in fact become a National Park.
Santos proposed CSG project needs to be assessed further for the potential implications in a variety of contexts, including:
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 reviewed both Appendix 3 of the "Bibblewindi Gas Exploration Pilot Expansion EIS" of 9 July 2013 and the report "Referral of Proposed Action: Water Resource Assessment, Energy NSW Coal Seam Gas Exploration Program" of 7 June 2013, each prepared for Santos NSW (Eastern) Pty Ltd.

I am concerned that no basic hydrogeological or geological data has been provided and therefore it is not possible for any expert in these fields to make any meaningful comment as to whether the conclusions reached in the above mentioned reports are justifiable or not.

The following lists the nature of the information that should be required of the Federal Government, analyst or decision maker in order to make an assessment:

* Depth of coal seams (note, fig 4-4, the only geological map or cross-section, does not have either a horizontal or vertical scale and is stated to be "not to scale").
* Thickness of coal seams.
* Thickness, depth, lithological description, porosity and permeability characteristics of the coal seams and importantly those horizons considered to be aquifers, aquitards or aquicludes.
* Structure, isopach and possibly facies map of selected horizons.
* Representative electrical borehole logs.
* Core analyses, if available.
* Tectonic setting with specific reference to faults and their potential fluid transmissibility.
* Seismic or other geophysical data.

The significance of requiring basic data is best highlighted by reference to the report, eg:

* Section 4-2-1. The Clare Sandstone is up to 95m thick (one of only two references to the thickness of a stratigraphic unit), is considered a potential groundwater resource and is separated from the Hoskissons coal seam by the Benelebri Formation, stated to be a confining bed but with no supporting evidence. Figure 4-4 (no scale) shows the combined Clare Sandstone and Benelebri Formation thinning to zero over the Rocky Glen Ridge, but there is no information as to which of these beds thins. Should it be the Benelebri Formation the consequence would be that the Clare Sandstone, the potential aquifer, would be in direct contact with a targeted coal seam. De-watering of the coal seam would predictably have an impact on this potential aquifer (note, the word "potential" is used in the report, not to imply the formation's characteristics may not meet the required standards, but rather as recognition that the presence of the shallow Pilliga Sandstone has to date provide sufficient ground water).
* Table 4-2 "Hydrostratigraphy of the Program Area". From the target coal seams to the surface not one confining bed has been positively identified. A number of beds are referred to as "probable hydraulic barriers" or as an "impedance to groundwater", but not one as a recognised barrier to groundwater movement.

The lack of supporting data or evidence leaves the following unanswered:

* On what basis is it estimated that 1.41GL would be extracted over 3 yrs from 6 pilot sites/42 wells? (note different start dates).
* On what basis is it claimed there would be no aquifer interference?
* On what is the predicted 2m decline in groundwater head based on?

I have noted that in respect of initial groundwater potentiometric heads, there is a lack of base data, as acknowledged by the authors. This increases the margins of error of the (not included) model.

At the end of pilot programme the Maules Creek Formation is predicted to achieve 80% recovery after ten years. This would appear to indicate hydraulic connectivity. Further Figures 4.1 and 4.5 show rapid recovery after drawdown in both the Hoskissons and Maules Creek coal seams, again appearing to indicate actual or potential hydraulic connectivity to aquifers. Note also that the Maules Creek formation is listed as being a "negligibly transmissive unit", an apparent contradiction to the rapid pressure recovery.

I would emphasise that the above not only provides a statement of the reasons I am unable at this time to either verify or dispute the findings of the reports, but more importantly illustrates the concern I have of the environmental risk this project appears to present.

I have sufficient concern, specifically in respect of the apparent hydraulic interconnectivity of the coal seams to actual and potential aquifers and the lack of both supporting data or argument as to why this is not so, as to leave me with no choice but to object to the proposal.

By way of qualifications, as a petroleum geologist I have some fifty years experience in the exploration and production of oil and gas and as well have authored various hydrogeological reports.

I object to this proposal on the grounds that it is likely to cause significant environmental damage to the unique natural asset which we know as The Pilliga. Threatened species recorded in the area covered by this proposal need to be protected as we are losing native animals at an alarming rate. The intrusion of mining infrastructure on the scale proposed will place enormous stress on the communities of native animals in the Pilliga, and the proposal should be rejected on these grounds.
Further, both the system of aquifers and groundwater flows needsto be properly mapped and understood before any further drilling is permitted. The future of the Pilliga relies on the security of its water supply, and Santos has failed to conduct comprehensive mapping and assessment of groundwater flows. Time should be allowed for a thorough evaluation of this project's likely impact on the Pilliga's groundwater and aquifer system before any decision on this proposal is made.
Additionally, the enhanced risk of fire which is inherent in any project involving gas must be addressed in terms of the indefinite legacy of this proposal. Specifically, can the applicant (Santos) show that it will take responsibility for the increased fire risk in perpetuity? How will Santos manage this risk? Future land use surrounding the Pilliga will be affected by any increase in fires, and there is already a projected increase of risk due to the effects of our altered climate. These are serious matters, and I urge the Director-General to reject the current proposal on environmental grounds.

Australia is the driest inhabited continent on earth - and the single greatest resource this country has, is the Great Artesian Basin (GAB). We know that it is ancient water, millions of years old, that it's recharge is so minimal that "it should be viewed as finite", and that almost a quarter of Australia would be virtually uninhabitable, without the GAB groundwater.
Our objection is that Santos are already drilling in the Pilliga, and the studies into the impacts on the GAB here have not yet been done.
The area in the Pilliga, that Santos intends turning into an industrial gasfield, is the southern recharge area of the Great Artesian Basin (GAB), the most vital area of the GAB in NSW. They are drilling through the Pilliga Sandstone, where the GAB intake beds are, and not only have they done no baseline water tests, but the aquifers here have not even been mapped or modelled (as Dept. of Water Resources will confirm). They are punching holes in the GAB recharge area, with no idea of the depth of the aquifers, the rate of flow, the direction of flow etc. 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.

We have had reviewed both Appendix 3 of the "Bibblewindi Gas Exploration Pilot Expansion EIS" of 9 July 2013 and the report "Referral of Proposed Action: Water Resource Assessment, Energy NSW Coal Seam Gas Exploration Program" of 7 June 2013, each prepared for Santos NSW (Eastern) Pty Ltd.
It is of great concern to many reviewers that no basic hydrogeological or geological data has been provided and therefore it is impossible for any expert in these fields to make any meaningful comment as to whether the conclusions reached in the above mentioned reports are justifiable or not.
The Federal Govt. or decision maker, should insist on the following information being provided, in order to make an assessment:
* Depth of coal seams (note, fig 4-4, the only geological map or cross-section, does not have either a horizontal or vertical scale and is stated to be "not to scale").
* Thickness of coal seams.
* Thickness, depth, lithological description, porosity and permeability characteristics of the coal seams and importantly those horizons considered to be aquifers, aquitards or aquicludes.
* Direction of flow, and rate of flow, of aquifers
* Structure, isopach and possibly facies map of selected horizons.
* Representative electrical borehole logs.
* Core analyses, if available.
* Tectonic setting with specific reference to faults and their potential fluid transmissibility.
* Seismic or other geophysical data.

From the target coal seams to the surface not one confining bed has been positively identified. A number of beds are referred to as "probable hydraulic barriers" or as an "impedance to groundwater", but not one as a recognised barrier to groundwater movement.

The lack of supporting data or evidence begs the question:
* On what basis is it estimated that 1.41GL would be extracted over 3 yrs from 6 pilot sites/42 wells?
* On what basis is it claimed there would be no aquifer interference?
* On what is the predicted 2m decline in groundwater head based on?

Of enormous concern is that these two Bohena wells are part of an exploration program that involves 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.

We know also that well integrity is a major issue. All gas wells fail in time. The drilling industry figures are that 7% of wells leak immediately, and within 20 years 50% leak. But the truth is that "the biggest bore casing company in the world, will only guarantee their casing for three years." So it is only a matter of time before the wells corrode and crumble, and cause massive contamination of the drilling and fracking fluids, and inter-aquifer leakage. The industry will be long gone by then, leaving future Australians to deal with the issues, the main one of which will be loss of our groundwater, and community health impacts.
We already have undeniable evidence of the damage that coal seam gas (CSG) mining does to the aquifers. Professor Philip Pells said recently, "It is now no longer a matter of "if" CSG mining will destroy the aquifers, but merely a matter of how long it will take."
The health impacts (to humans and animals) are well known; we already have cancer clusters forming around the gasfields on the Darling Downs, and children with bleeding ears, convulsions, constant headaches and nausea etc. Dr. McCarron (who did a study, attached) believes it is from air-borne B-TEX chemicals. But as the gas industry does not disclose the chemicals used, it is hard to test for them.
The Chief Scientist is at present gathering evidence, to present her report in March next year. We are providing her with evidence to show that further studies are urgently needed before this industry proceeds, particularly as the damage will be irreparable. Scientists and experts have said we need groundwater studies, health impact assessments, chemical analyses, air monitoring etc. With all the evidence we can produce that these crucial studies have not yet been done (and urgently need to be done), can the Dept. please give us one reason why this drilling cannot wait until Professor O'Kane's report is released? What is the rush, particularly when the damage to the groundwater will be irreversible? And the gas isn't going away. If they can prove they won't damage the GAB, then the gas will still be there.
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 clarified their intended future developments in the area; therefore no cumulative impact studies can be conducted.
As we have learned with tobacco, thalidomide, asbestos, and agent orange - it is better to wait and err on the side of caution, than rush in before all the studies are done - and leave our future generations with a terrible legacy.
The late hydrogeologist C.W. Atkinson, who did a research paper for National Parks on the hazards of CSG exploration in the Pilliga - (attached) said most of the damage is done in the exploration stage, before the studies are done. We are asking you to invoke the Precautionary Principal and halt Santos' "gas exploration pilot program" until the scientific studies are completed, and the essential data and information listed above, has been provided.

Attached document

I thoroughly object to Coal Seam Gas operations in the Pilliga State Forest. These kind of projects are only coming to light in a piecemeal manner which is not taking into account the cumulative impacts of this poorly regulated industry on the water resources of the region. Insufficient baseline testing and analysis has been done, previous damage has been overlooked or covered up and the science is not there in any meaningful manner that this industry, like many extractive industries, can carry out its operations without damage to the above ground or below ground ecosystems including the health of surrounding residents and their small holdings.
The damage already being done in the Dalby region to bores and water, air and soil quality by the gas industry should serve as a warning that Santos and other gas field players really do not understand the complexity of the ecosystems which they are destroying with government agreement and the only conclusion is that they do not care either.
Please reject further industrialisation of this important forest habitat and water resource.

Submission file uploaded.

upload

Submission

Despite the Director General `s list of Requirements not being completely met, Santos still presumes to go ahead with their Drilling in the pilliga, because the Narrabri Shire has also given them the Green flag to proceed with their Exploration Pilot Expansion!

I object to this Exploration continuing for the following reasons:
1. There are no real future Development plans for the area despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production" Or perhaps they are still on the drawing board...??

2. The Pilliga Forest is a very important recharge area for the Great Artesian Basin, and for this reason the Director General requires baseline monitoring, so where is the baseline water study for the Pilliga groundwater systems? There are no aquifer monitoring bores yet constructed! There must be thorough sampling and testing across the project area to enable accurate modelling of regional groundwater flows, and comprehensive assessment of Groundwater Dependant Ecosystems (Stygofauna, our underground `filters' that keep our aquifers clean and healthy). This also needs to include the potential impacts any drawdown (this is of concern for Stygofauna, as a drop in groundwater can be detrimental to these GDE's) or contamination may have.

3. The Two Bohena wells that are part of the exploration program pose a risk, as they are multi-lateral; this makes it very difficult if not impossible to seal the junction between the casing and the lateral. Drilling through the casing of wells poses a great risk to the underground aquifers and in particular to the Great Artesian Basin.

4. The risk of fires in Pilliga due to lightning strikes is well recorded. On total fire ban days, everyone is expected to adhere to these restrictions, so why is it that Santos is excluded? Yes it is noted that gas flaring cannot be shut down....but still we have the continuous `fire' blazing away in the middle of the Forest on Total fire ban days! One rule for the people and another for CSG? And Santos does not appear to have a clear bushfire strategy in place.

5. Habitat in the Pilliga is the life blood of the Forest for the birds, reptiles and mammals that call it home, some of these are permanent residents, while many of the birds are migratory, and some of these are also Vulnerable species. They depend on the flowering trees for a great part of their annual pilgrimage. The Pilliga Mouse, will most likely have most if not all of its habitat destroyed, Santos has admitted this regarding their CSG Exploration. The Eastern Pygmy Possum and Barking Owl are also species at risk! The breeding status and population dynamics of these threatened species in the Pilliga are poorly understood.

6. The risk of fugitive toxic emissions into the atmosphere and the detrimental effect on the environment and humans has not been modelled or assessed due to the lack of a Health Impact Assessment baseline health data and air quality study being conducted in the region. Health Impact Assessments are not at this stage part of EIA's. A requirement by the Director General, is to assess the risk of these emissions and there effect on the Environment and Human health, it is imperative that HIA's be a compulsory part of any planning of major works and industry that could cause long and short term health issues for communities that are to be impacted by such industries. How else can these requirements be met, other than a regional HIA survey being conducted?

7. There is a Native Title claim over the project area, so Santos must include the Gomeroi, the Traditional Owners of the Pilliga (the Native Title Claimants') and the Narrabri Local Aboriginal Land Council in their consultation. It is extremely disappointing that the Aboriginal Heritage requirements were taken out of the Director Generals Requirements!

To Whom it May Concern

I write to you in relation to SSD 13_5934 currently on public exhibition. For the record, as avvery concerned ratepayer of the Narrabri Shire Council, I believe there should be a Moratorium on all infrastructure, exploration or production of coal seam gas in this Shire until the absolute independent science of safety is complete. At the very least this should continue until such times as the final report of the NSW Chief Scientist's investigation into the Coal Seam Gas Industry of NSW is delivered, including any recommendations.

A rapidly growing sector of this community now believes Council, together with the state and federal governments has the interests of Shire residents positioned as secondary in your deliberations and actions, particularly with regard to the pursuit of the rapid establishment of unsustainable industries, such as mining and extractive industries, to the mutual exclusion and sublimation of sustainable industries such as agriculture, which have nurtured this region for in excess of 150 years.

Together with my family, I am currently the operator of one of the largest potato and peanut enterprises in NSW. Our farm is located on the rich soils between Wee Waa and Narrabri. We rely totally on ground water to irrigate these crops utilising more than 18 centre pivot irrigators, together with flood irrigation. We believe that mining and extractive industries pose a significant threat to our enterprise through potential contamination and/or drawdown compromise of the aquifer. As we grow food crops, any contamination of the water supply would render the crops unfit for human consumption. If this occurred, our business, and the 7 permanent and 25 casual employees (all locals) and their families, would be lost to the Shire. Multiply this effect by the number of direct and indirect agriculture enterprises within our shire, and this will have a devastating impact, the results of which will spread through a multitude of other service related industries. Mining and extractive industries are unsustainable in the long term, whereas farming and agriculture has the ability to support this region indefinitely.

Given this, I move to the application before you. 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.

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 Dependent 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.

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.

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.

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.

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 urge caution in decisions that make Narrabri Shire the centre of the NSW gas export industry.

Yours sincerely
Sarah Ciesiolka

To Whom it May Concern

I write to you in relation to SSD 13_5934 currently on public exhibition. For the record, as avvery concerned ratepayer of the Narrabri Shire Council, I believe there should be a Moratorium on all infrastructure, exploration or production of coal seam gas in this Shire until the absolute independent science of safety is complete. At the very least this should continue until such times as the final report of the NSW Chief Scientist's investigation into the Coal Seam Gas Industry of NSW is delivered, including any recommendations.

A rapidly growing sector of this community now believes Council, together with the state and federal governments has the interests of Shire residents positioned as secondary in your deliberations and actions, particularly with regard to the pursuit of the rapid establishment of unsustainable industries, such as mining and extractive industries, to the mutual exclusion and sublimation of sustainable industries such as agriculture, which have nurtured this region for in excess of 150 years.

Together with my family, I am currently the operator of one of the largest potato and peanut enterprises in NSW. Our farm is located on the rich soils between Wee Waa and Narrabri. We rely totally on ground water to irrigate these crops utilising more than 18 centre pivot irrigators, together with flood irrigation. We believe that mining and extractive industries pose a significant threat to our enterprise through potential contamination and/or drawdown compromise of the aquifer. As we grow food crops, any contamination of the water supply would render the crops unfit for human consumption. If this occurred, our business, and the 7 permanent and 25 casual employees (all locals) and their families, would be lost to the Shire. Multiply this effect by the number of direct and indirect agriculture enterprises within our shire, and this will have a devastating impact, the results of which will spread through a multitude of other service related industries. Mining and extractive industries are unsustainable in the long term, whereas farming and agriculture has the ability to support this region indefinitely.

Given this, I move to the application before you. 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.

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 Dependent 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.

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.

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.

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.

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 urge caution in decisions that make Narrabri Shire the centre of the NSW gas export industry.

Yours sincerely
Matthew Ciesiolka

I submit that the coal seam gas industry will seriously jeopardise the future for my grandchildren It will industrialise an agricultural area and destroy the tourist industry. The 2km buffer zone does nothing to protect the lives of both humans and animals; as we know from the experience of those in Tara, Queensland where many children are suffering severe health problems which were not present before the gas fields surrounded them.
Also the right of landholders NOT to have wells on their properties means nothing, when people are being seriously affected by gas wells more than 5kms away from their properties. This is without considering the constant problem of heavy machinery traffic, 24/7 lights and compressor noise, fugitive gas emissions and depletion of their bore water.
Also in regard to the 2km buffer zone from horse studs etc., what about dairy cattle, sheep and crops?
We have enough gas reserves in the Bass Straights to provide for our domestic use for years to come. We should not jeopardise all that is precious to Australia for the sake of an overseas market

Below is a upload of my submission, Thank you.