Narrabri Gas - Bibblewindi Exploration

Thank you for the opportunity to make a submission into this application.

I am opposed to this development as there has been insufficient baseline testing and water monitoring in this area. Furthermore, this area has already been fracked by original partners of Santos, Eastern Star Gas so any subsequent monitoring would be fundamentally flawed. This is a recharge area of the Great Artesian Basin and should be protected.

The fact that Santos chose to make many small submissions on the proposed development of the area strongly suggests to me that Santos is avoiding "Water Trigger" legislation passed by the previous Federal Government. This legislation only applies to those projects which will make a significant impact on water resources.

On many visits to the Pilliga I have been alarmed at the shoddy workmanship of this development with cheap poly pipe lying on top of the ground to transport waste water. I have seen sump ponds overflowing into the creeks which ultimately end up in the Murray Darling. I have also seen sunken well heads leaking methane into the atmosphere. The attitude of these companies was very clearly "out of sight and out of mind".
To proceed with the development of this industry when there is no suitable disposal plan for the wastewater or accompanying salts is short-sighted indeed.

I recently was part of the Stakeholders Advisory Group for the Namoi Catchment Water Study and was alarmed at the lack of information supplied by Santos for this study. Clearly if they could not supply relevant information then, how can information provided for this project be seen as sufficient?

Yours sincerely
Rosemary Nankivell

Traditional owners not consulted.

Santos must be required to address cultural heritage matters with the Gomeroi elders of the Pilliga region.

Dear Sir/Madam
The above-mentioned proposal should be rejected on the basis of the five points listed below.
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.

Finally you should also consider your constitutional responsibility as elected officials and Governmental Staff not to destroy crown land. This land is meant to be preserved for future generations and not to be used for irresponsibly mining. I understand that weighing up political will and fiscal gain against the environment may be hard decision. I implore you to look at the long term devastation as seen in Wyoming USA as something that is very likely to happen in the Pilliga.

I object to this project due:
the damage it will do to this unique biodiversity (flora and fauna) of this area,
the damage it will do to indigenous land and culture,
the threat to water supplies,
and the cumulative effects of climate change from the carbon emissions of this project.

General requirements:
Santos have not yet come clean with their future developments in the area. This is despite the Director General requiring Santos to state "the likely interactions between the development and existing, approved and proposed gas exploration and production"

Water:
The Pilliga Forest is a very 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.

To whom it may concern,

It is difficult for me to believe, let alone accept, what is going on this country and others, in what one would have thought was a period of information, education and - as a result - a more enlightened 'mankind'.
Indeed I find it difficult to refer to us as "mankind"; perhaps I should stick to 'homo sapiens' to avoid any positive reflection upon our species, given what we are wantonly and knowingly visiting upon the environment in which we live, and upon which we depend for our very existence.

My reasons for this, some may consider, 'harsh' summing up of the human race can be encapsulated by the events we see unfolding before our very eyes in the Pilliga.

I object, with every fibre of my being, to the activities that have, are, and which are still intended to take place, with respect to Santos' Gas Mining in The Pilliga region.

A summary of my complaints follows:

BIODIVERSITY - Santos have gone so far as to admit that their CSG exploration will destroy habitat for the Pilliga Mouse. It is quite apparent that the breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. In order to assess the population dynamics and status of the Pilliga Mouse, Eastern Pygmy Possum and Barking Owl, there must be baseline ecological surveys.
Where are they? I am certainly not aware of any having been independently and comprehensively completed.

And if this is not enough, on its own, to warrant an immediate moratorium on CSG activities in the Pilliga, there is a plethora of other reasons for same.

Let me expand:

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.
Are we to assume that the intention is to allow the opportunity to "slip past" us, as per the Queensland Gas Fields, so that there IS no uncompromised air left to test, thereby exonerating any particular party of responsibility for future pollution?
If this is NOT the case, I think one could be forgiven for imagining that it is, given that comprehensive independent testing has not ALREADY been insisted upon by the 'powers that be'.

HAZARDS - As we have clear and current evidence of via recent fires throughout NSW, the risk of bushfires is a real and present concern.
The Pilliga, in particular, 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.
The arrogance of Santos to assume that flaring, required as a part of their CSG activities and which cannot do anything but increase the risks of fire in the locality, is an acceptable practice in such an area is beyond rival.

WATER - Above all considerations is the importance of our most precious commodity; Our water.

Once again, on the subject of corporate arrogance - not to mention Governmental inability to recognise their sworn and 'paid for 'responsibilty to the people of this state and country - it appears necessary for me to remind the reader that The Great Artesian Basin amongst other sources of water available to the inhabitants of this land ARE NOT the property of Santos, or any other collective for that matter, but is - by every moral and ethical argument one could bring to bear - the property of every lifeform that requires it. Therefore, to compromise it any way whatsoever, even 'potentially' (given that predictions about future impacts is little more than an educated guess) must surely be a crime of the highest order?

Our governing bodies MUST consider:

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.

For there to be any other decision than to insist upon the immediate cessation of Gas Mining exploration and operations of ANY description in The Pilliga Region could only be considered to be aiding and abetting the aforementioned crime against Australia's inhabitants which Santos appears to be prepared to commit.

Thank you for your consideration of my opinions.

Bibblewindi Gas Exploration Pilot Expansion

Please accept this as my submission to the above.

The Pilliga Forest is a national icon, a recharge area for the Great Artesian Basin and place of unique biodiversity - it is no place for a coal seam gas field.

The development of a gasfield in the Pilliga forest will fragment and clear native vegetation where a number of threatened species occur. The construction of pipelines, roads and drill sites will undermine the ecosystem integrity and lead to loss of species habitat.

The integrity of coal seam gas wells cannot be guaranteed and studies show that leakage of drilling fluids and natural gas cause harm to the environment and risk the contamination of aquifers.

Santos clearly haven't met the Director General Requirements on water, biodiversity and bushfires. The cumulative impacts of any future drilling and development must be taken into account when assessing this development. Baseline studies on water, flora and fauna must be completed by independent consultants because the last intact fragment of NW NSW vegetation is a precious natural asset to the local community, to NSW and to Australia. Its wellbeing, longterm sustainability and value to landholders and traditional owners must not be taken lightly. Detailed public consultation and further rigorous scientific studies must be undertaken.

Further expansion of a Pilliga gas-field will increase the potential negative impacts on biodiversity, water and the chance of bush-fires occurring throughout the forest. Lightning strike in the area is a common occurrence and Santos does not appear to have a clear strategy for dealing with bushfire. Flaring of gas wells during extreme fire conditions could also pose catastrophic impacts to the Pilliga landscape.

Importantly, many farmers in the Narrabri district have locked their gates to invasive gasfields, with a majority declaring opposition to coal seam gas mining due to the toxic nature of natural gas production, the cumulative negative impacts to rural landscapes and more critically, the uncertainty of the impacts to water supply and the potential to harm the Great Artesian Basin - the lifeblood of the upper Murray-Darling system.

If farmers think this development is a bad idea I have to agree with them, - protecting our land and water is a high priority - risking the natural capital of the Pilliga forest to 'suck every last molecule of gas from NSW' will have serious long term implications for biodiversity, water quality and downstream communities.

Please do not put short term energy needs and gas industry export plans (to amass corporate profits), ahead of the communities who make our country a great place to live. Farming families already feel the impacts of climate change, if government planning policy and energy industry proposals continue to fragment the Australian rural landscape, our rural towns will suffer, both environmentally and socially.

Imposing ever-expanding invasive industrial gas-fields into the rural landscape will damage rural areas, impact on long term future sustainable farming and force unwanted change onto unwilling communities.

Development of a gas industry in Australia threatens our future existence because it risks damaging our water resources. In Australia a damaged water resource will be passed to our grandchildren, who will suffer the consequences of our generation's short-sighted, industrialised society.

Rural communities work hard and could be empowered by innovative regional development policies to create renewable energy power hubs and provide food, education and healthcare with vibrant local sustainable business models. The age of fossil fuels is a luxury the earth can no longer afford as resource depletion and population growth drive the carbon emissions to dangerous tipping points.

Rethinking sustainable energy is at the core of my objections to unconventional invasive, industrial gas-fields. I think it madness for Santos to consider building a coal seam gas field in the midst of one of the last extensive, biodiverse remnants of native vegetation in western NSW. Both the Pilliga Forest and Leards forest provide ecosystem services that are too valuable to risk. Removing and fragmenting native vegetation will compromise threatened species habitat and water security and ironically, prioritise the profits of the coal and gas industry - profits which will benefit only a few people in our rural communities.

Thank you for the opportunity to comment.

The submission I send you today about the proposed Coal Seam Gas Drilling and Fracking in the Pilliga, is to express my 'shock / horror' that the Government of this country is leading this country into total annihilation

While we debate this issue, the government of Japan are trying to work out how to save the planet, and clean up the Fukushima Reactor Unit No 4 disaster. Professor Mitsuhei Murata has been interviewed on U-tube telling the world this could be an major catastrophy.

And believe it or not we continue to drill and Frack the underground in our desperation to extract the riches and sell them overseas for huge profits.

But at WHAT COST?

We now know that Scientific studies by very qualified independent people have told us, without any doubt, our human intervention in the underground will cause an increase to unstable world wide conditions. Increased seismic activity; earthquakes, sink holes, floods and fires.

The scientific reports; plus evidence, where Coal SeamGas & Fracking have been in full production, around the world; also tells us; that as well as irreversible destruction of the environment; the negative health impacts to human, animals and wildlife, will be massive and ongoing into decades to come.

Both the Federal and NSW State governments, need to look at the evidence everywhere and let that evidence bring some common sense to this debate.

Coal Seam Gas & Fracking need to be banned, as it has already been in many overseas countries.

If we continue to rape the planet for personal greed there will be no future for our children and grandchildren.

I thank you for your attention , for and allowing me to state my opinions about this very serious subject.

I object to the proposed activity because I believe there is a high likelihood that it will have significant adverse effects on resources that are important now and will be important into the future to the people of NSW, to the species and ecosystems of the Pilliga forest and district, and to people and other species of the world.

This activity involves lateral drilling from 2 existing wells and an extractive operation as part of a gas resource assessment and mine planning process. While the physical activities covered by the EIS may be localised, they need to be viewed as intimately connected to many different processes, and their impacts need to be seen as core parts in the cumulative impacts of those processes. It is clearly a core part of Santos' resource assessment process which in turn is a core part of their current business plan for a major fossil fuel mining operation, otherwise they wouldn't have prepared the EIS.

It is also an integral part of the cumulative process of grossly altering more of the Pilliga forest - adding to what has happened in the past and an enabling part of more alteration proposed by Santos in the future.

It is part of the cumulative process of adding more greenhouse gasses to the world's atmosphere which is puting at risk all the human and ecological processes that function best with no or very only limited slow changes in climate. Greenhouse gas coming from so many of our society's activities contribute to increasingly rapid climate change because people have reduced and already overloaded the planet's ability to capture atmospheric carbon. Emissions due to the proposed development (including the methane that is likely to escape because Santos' capture processes will be imperfect) and from subsequent burning of the gas they do capture, will have a cumulative impact. If this development enables Santos to plan and operate a larger gas mining operation it will be part of a far larger cumulative addition to greenhouse impacts.

The project is also part of other processes directing our society's human and financial resources towards increased use and reliance on fossil fuels. This includes Government agencies staff time in assessing this activity and other components of schemes to extract and sell coal seam gas from under the Pilliga and other parts of the NSW coal measures. If this proposal proceeds time will have to be spent supporting and oversighting its operation subject to conditions (e.g. checking information sent to Dept of Energy and Resources, a POEO Annual Returns to the EPA, various agencies policing conditions). Then even more time will be spent assessing and oversighting the subsequent proposals for developing a full scale mine. The community of people who oppose such mines will also have to direct more of their time and resources to minimising impacts of this and future proposals. Whereas if the proposed development is stopped now those human resources and the financial resources that would be spent on it could be directed to achieving other societal objectives. If the financiers pull out, the people who would have worked on this project can find other things to do with their time and skills.

The proposal involves extracting publicly owned petroleum resources and operating on publicly owned land that supports ecological resources which have previously been acknowledged by NSW and Commonwealth Governments as being of great value. The project site is not just a small part of a 'biological hot spot' - it is known that the Pilliga Mouse and other threatened species occur very close to the project site and depend on the particular habitat conditions for their survival. Areas of suitable habitat may be reduced by the proposed activity or unintended consequences such as spills or increased fires.

The proposal also involves deliberately changing the location and quality of publicly owned water resources and puts at risk other public water resources such as those in the intake beds of the Great Artesian Basin. The NSW Government has a responsibility to manage our resources wisely for the truly long-term benefit of our society's many interests, not to suit the short term financial and political interests of the current crop of Ministers. The NSW Government not only has this moral responsibility but also has a legislated responsibility to apply the Precautionary Principle.

Given the role of the present proposal in the processes discussed above and its consequent contribution to cumulative impacts, whether approving the proposal involves a wise use of our resources or unacceptable risks to their value should be assessed in the context of the cumulative impacts not just the most likely direct effects or even the less likely but high risks of the individual activities for which approval is currently sought.

I have visited the Bibblewindi area and seen some of the mess made by Eastern Star Gas including areas where trees died when extracted water polluted land around the wells and original water treatment facility. I have considered reports of the effects of operating coal seam gas developments, read parts of the EIS, and read an analysis of the EIS. I believe that the risks posed to our ecological resources and our water resources are far too high. For example, extracting more gas, water and chemicals under pressure from lateral drilling will increase the risk that the casing and grouting of the bore holes will develop fractures at some time in the future and leak pollutants into aquifers above the coal. The surface works and attempting to store and "dispose" of the water and chemicals will increase the risk of damage to the surrounding environment and surface waters along with whatever locations the chemicals go to. The vehicle and machinery operations and the gas being stored in or moved through the Pilliga increase the risks of fires - risks to fire fighters as well as to the forest ecosystem and to surrounding properties. I am also concerned by many other issues raised by The Wilderness Society, National Parks Association and other community groups. I will refrain from copying the issues they raise. Approving this proposal would approve unacceptable damage to and risks to ecological and water resources.

The petroleum resources of NSW are best used as an undisturbed underground store of carbon: by remaining underground and unburnt this store limits the greenhouse effects of solar radiation reaching our planet's atmosphere. These resources are being very well used at present. Extracting any more of them and enabling their release into the atmosphere would be an unwise misuse of the resource. If we were all suddenly stopped from burning any fossil fuels that would have unacceptable social impacts, however this is not suggested by anyone. We do not need to use any coal seam gas in our transition to a more sustainable, low carbon economy. There are enough fossil fuel mines already approved around the world. We should be trying to put the energy from those approved mines to use to enable rapid change to alternative energy sources and ways of doing things that are much more energy-efficient. Approving more fossil fuel developments enables people to postpone or avoid finding ways to make this shift. It also increases the risks of climate change to people and ecosystems around the world. This is most unwise.

Please do not approve this activity.

Thank you for the opportunity to make a submission on an EIS for this proposal. It is good that someone decided the EIS process was triggered because this activity is likely to have a significant effect on the environment. Many other activities undertaken as part of exploration or preparations for mining also warrant an EIS.

Please refer to attached PDF

Please refer to attached PDF

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 Claimants, Gomeroi Traditional Owners of the Pilliga and the Narrabri Local Aboriginal Land Council in their consultation.

As a citizen of this country I expect legislation to support clean air and water, health of people and preservation of our unique environment and the flora and fauna within.

Please see attached.

Please see attached