Narrabri Gas - Dewhurst Exploration

Dear Sir,

It is difficult to believe that coal seam gas mining is even contemplated, let alone permitted, anywhere in the immensely fragile eco-system of eastern Australia.

I will not rehearse the many awful things that happen when CSG is mined anywhere, as this is currently being rehearsed in Sydney's courts with regard to the Pilliga itself.

But I would remind the government that under legislation enacted by itself, minning is not permitted:
Within 2 km of residentail areas.
Within 2 km of vineyards
Within 2 km of horse-breeding station.

If CSG mining is detrimental to these activities, it is detrimental to all farming and cultivation, and all living (rural as well as urban.

I urge you not to let yourselves be hood-winked, coerced, or bought, by exploitative companies like Santos and Metgasco.

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:
TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.
BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.
AIR QUALITY -
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.
GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.
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.
HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:
TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.

ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.

WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.

BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.

AIR QUALITY -
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.

GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

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.

HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

Santos must get out of the Pillaga, and CSG extraction must be brought to a stop throughout not only this region, but throughout the whole of Australia. Our water and agricultural land resources are scarce and we must protect them from degradation. This is a matter of urgency as the climate changes and food shortages worldwide are beginning to impact. The disastrous effects of the CSG industry is clearly evident in the USA, and already in Australia and the Pillaga ( for example the waste water spillage in 2011) . The environmental degradation and spoliation that is inevitable with CSG extraction is something we cannot afford. STOP COAL SEAM GAS - not only in the Pillaga, but get it out of Australia.

The Pilliga Forest is a national icon, a refuge to so many threatened birds, marsupials and wildflowers and is no place for a coal seam gas field .

Santos has failed to meet the Director General Requirements as outlined below and I strongly object to further destruction of this vitally important forest..

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:
TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.
BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.
AIR QUALITY -
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.
GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.
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.
HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

* New wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively, of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills. Can this ever be rectified??
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet been constructed.

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:
TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.
BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.
AIR QUALITY -
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.
GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.
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.
HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:
TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.
BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.
AIR QUALITY -
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.
GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.
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.
HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:

Dear Sir,

The Pillaga Forest is one of my favourite places to drive past and through on my way to Queensland. As a bird observer I have spent some memorable moments watching the wildlife in this unique forest. It is the lungs of New South Wales. We need clean green energy, not fossil fuels which pollute and impact on all the remaining strongholds for our native wildlife. The aquifers in this region must not be polluted. The Government should be adopting the policy of "if you are not 100% sure that this development can be done without any harm to the environment, then it should not proceed. Ask the people of Tara what their health impacts are from CSG; all of which have been completely ignored by Queensland Health.
TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.
BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.
AIR QUALITY -
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.
GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.
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.
HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

Drilling for coal seam gas in the Pilliga Forest poses great dangers to the Great Artesian Basin and other aquifers. Triple stacked wells, as proposed for Dewhurst 13-18H and 31, pose an even greater danger than oridinary wells, as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.

Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills. Despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet been constructed. 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.

I am also deeply concerned about the effects this proposal would have on the ongoing connection of the Gomeroi Traditional Owners with the Pilliga Forest and the risks it poses to human health, biodiversity and the climate.

No CSG exploration in the Pilliga , or anywhere !!

Although I live far from the beautiful Pilliga, I am deeply concerned with the plans for multi-lateral drilling in the Pilliga Forest. Why is this being allowed - well it seem to me its a matter of money because any thinking person would be hesitant about allowing this drilling to go ahead. This risks are enormous, and what right does this government have to take these risks. Not on my behalf! I ask that any drilling or mining in this precious forest be banned, not just for now, but permanently. The following information says it all:

TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.
BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.
AIR QUALITY -
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.
GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.
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.
HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

To whom it may concern,
I am bitterly opposed to gas mining of any kind in Australia. I am aware of the enormous damage gas mining has incurred to USA water catchments and that well- known scientists such as David Suzuki oppose such underground industrial activity because of the "unknown" factors involved. Why risk our precious underground water reserves to greedy private interests whose only issue on this earth is the making of money in any way they can? I value the Pilliga Forest. Why is it's value being ignored?

This cannot be allowed to take place - Please consider the following:
TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.
BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.
AIR QUALITY -
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.
GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.
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.
HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

TRIPLE-STACKED HORIZONTAL WELLS -



The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.

ECONOMICS -



The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.

WATER -



The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.

BIODIVERSITY -



The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
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 and other threatened species.

AIR QUALITY -



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.



GREEN-HOUSE GASES -



The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.



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.



HERITAGE -



It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.


http://majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=6038



From the Santos EIS



Santos Project description -



Santos NSW (Eastern) Pty Ltd (Santos), as the coal seam gas (CSG) operator of Petroleum Exploration Licence 238 (PEL 238), is seeking consent to expand operations at the Dewhurst 13-18H and Dewhurst 26-31 pilots, and operate both expanded pilots for up to three years (the proposed activity).



The Dewhurst 13-18H Pilot is an existing pilot well set that comprises three vertical wells (Dewhurst 13, 14 and 15) and three single horizontal wells (16H, 17H and 18H). The proposed activity includes drilling an additional two horizontal wells at each of the Dewhurst 16H, 17H and 18H pilot wells to target additional coal seams, installing surface infrastructure (including a flare at Dewhurst 14) and operating the whole pilot set for up to three years.



Dewhurst 26-29 is a four well pilot approved under Part 5 of the EP&A Act and is scheduled to be drilled in the fourth quarter of 2013. It is proposed to add two additional wells, Dewhurst 30 and 31, to this pilot which are proposed to be drilled in the second or third quarter of 2014 should approval be granted. The proposed activity includes drilling the two additional pilot wells (Dewhurst 30 and 31), installing surface infrastructure (including a flare at Dewhurst 28) and operating the six pilot well set for up to three years.



The proposed activity includes:

construction: site preparation activities at existing and new well lease areas; establishment of necessary
equipment, temporary structures and facilities on the lease areas to enable drilling; re-entering three
existing wells to convert single horizontal wells to triple-stacked horizontal wells at Dewhurst 13-18H;
drilling one vertical well (Dewhurst 30) and one triple-stacked horizontal well (Dewhurst 31);
construction of a flare at Dewhurst 14 and 28; and construction of associated surface facilities and gathering systems operation: operating the expanded Dewhurst 13-18H and Dewhurst 26-31 pilots for a period of up to three Dewhurst Gas Exploration Pilot Expansion
Environmental Impact Statement (EIS) years, management of the water and gas produced during operation and general maintenance activities
post operation and rehabilitation: decommissioning and rehabilitation of pilot wells and ancillary infrastructure or suspension of wells for potential future use.
Additional clearing - Approximately 2.2 hectares of vegetation will be cleared from within the construction footprint at Dewhurst 26-31 as part of the proposed activity.

Yours truly,
Ken Brown

Nobody I know supports Coal Seam Gas and everybody I know are horrified that this could happen in Australia. Listen to the people and not the corporations. We do NOT support Coal Seam Gas for so many reasons.

Submission
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.

* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.

ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.

* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.

WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.

* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.

BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.

* 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 and other threatened species.

AIR QUALITY -
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.

GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

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.

HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS:
TRIPLE-STACKED HORIZONTAL WELLS -
* The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
* When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -
* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
* DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -
* The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
* In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet 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.
BIODIVERSITY -
* The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
* 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 and other threatened species.
AIR QUALITY -
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.
GREEN-HOUSE GASES -
The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.
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.
HERITAGE -
It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

I wish to register my dismay at the ongoing threats to the natural value of the Pilliga. This proposal should be rejected on the grounds that any further destruction of this area will lead to the industrialisation of a vital biodiversity hotspot. We can ill afford to continue the destruction of nature in pursuit of ephemeral financial gains for the few.

Santos has failed to meet the Director General Requirements for this project.

The `Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger 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.
When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions, known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.

The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis, yet there is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects, but these have not been followed.

The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
In addition, despite the risks posed by the new tri-lateral wells, there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet been constructed.
As well, 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.

The further drilling required for these wells could threaten the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.
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 and other threatened species.

The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

Finally, it is extremely disappointing that Aboriginal Heritage requirements for Heritage assessment were taken out of the Director General Requirements. The Gomeroi, Traditional Owners of the Pilliga Forest, have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.