Narrabri Gas - Dewhurst Exploration

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 am strongly against this expansion of drilling in the Pilliga. One reason is stated below...
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.

No exploration or drilling in the Pilliga! The new coal seam gas wells known as triple-stacked horizontal wells have inherent risks involved due to the re-drilling of wells and the inability to seal off the groundwater from contamination.

For some years I have been researching the problems caused by CSG extraction, especially its impact on water resources. There are serious issues both here and in places like the USA where longer experience has revealed a number of irreversible problems like water contamination, health effects on both humans and animals, and lack of management of toxic produced water. In the light of this research I have to strongly oppose this plan to further impact on the Pilliga, its water resources, its farmers and its wild life. The lack of any credible plan for disposing of toxic water, and the depletion of water from the Great Artesian Basin - where already we are using more water than can be recharged - should surely ring alarm bells. The short term profit should never outweigh permanent long term problems and the well-being of a community and its environment.

Our objection is based on environmental grounds that have been fully and extensively outlined by the various objectors to the project.

In particular we are concerned by the introduction of toxins into the earth and water. Secondly, the enormous amount of water used in the CSG process.

Assurances that the process is safe will not enable the clock to be turned back when (more) damage becomes apparent.

I think the CSG industry is pushing their agenda way too hard on a country which needs times to learn of the efforts other countries who have these mines in place are now having to deal with. This is the age of communication and it shouldn't be hard to put a moratorium on an industry that still has a lot of answers to what they are doing with their waste water and if it will affect the underground water that is the life blood of a parched dry land such as ours.
Yours sincerely
Satya McVeity

Dear Sir,

Fracking the Pilligra is fraunt with danger. It could destroy our water supplies and arable land.There is no guarantee that this isnt possible.Playing God with our ecology is crazy. Nor is it economically practical. It is a ponzy scheme. The People of NSW willl suffer well into the future if this goes ahead.Believing scientific studies carried out by the benefiting companies is a joke as well. Our environment is far to important.The whole of the Artesian basin is at stake for the sake of a few measily dollars in the state coffeurs. This would be a betrayal of the people of NSW.

Yours faithfully,
Judith Cousins

Santos does not have a very good record in all things environmental. If they are permitted to mine the Pilliga, anything could happen.

Once the water-table is contaminated by dangerous chemicals, which are used in coal-seam gas mining,
the damage has been done

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.

CONCLUSION
There has already been more irreversible damage been done than ever anticipated and another approval CANNOT BE GIVEN.
IT IS AGAINST THE INTERESTS OF OUR CITIZENS NATIONWIDE !
Birgit Graefner

I am objecting to CSG mining in the Piliga Forest. CSG only benefits the mining industry. At the same time it's destroying our beautiful country. There is little or no recovery of the environment after the destruction of CSG.
Our land it too precious. Mining is all about greed.

Dear Planners,

I am sending this submission in regards to the Pilliga CSG mining undertaken by Santos, and wish to point out the following facts for you to consider.

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.


It is obvious that these companies are working purely out of self interest and are not in the least concerned about the effects of their mining efforts. It is also obvious how deviously they will manipulate laws and regulations to their advantage, in the full knowledge that their mining is not safe. I am calling on you to scrupulously check every claim made by them, to rely on independent reports rather than company produced ones, and to think a little further than the tiny bottom line.

There is so much more at stake here than a few dollars, for companies that fail to give anything back in return. Now that the mining tax is being abolished, we really are being sucked dry.

You can make or break our country in your decisions. I trust that you will exercise your intelligence on all levels and block these mining efforts on every level.

The projected usefulness of CSG is until 2018. The damage will last much longer, and those companies will be long gone. We will have to bear the full brunt of all of it - and we will not thank you.

Many countries and states of America are now banning fracking due to the risks associated with the environment, water and community health.
NSW is not heeding the warnings in relation to these risks I submit that all fracking in NSW should be banned. This Dewhurst Gas Exploration project is no exception. It should not go ahead.

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.
* 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, 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 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 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 am a farmer and irrigator in the Namoi Valley we rely on the quality of our water and air to produce quality farm products for the world. I do not want that put at risk by Santos's short term Coal Seam Gas developments that will increase carbon emissions not reduce them. I am concerned about their drilling Technics and polluting the ground water systems. I do not believe that their treatment of produced water is safe to the environment. And the destruction of the Pilliga Forest is not warranted, the timber industry has all but been shut down because the Pilliga was thought to be worth saving so is the verdict now changed and this area is a waste land? Well it soon will be!

I am a farmer and irrigator in the Namoi Valley we rely on the quality of our water and air to produce quality farm products for the world. I do not want that put at risk by Santos's short term Coal Seam Gas developments that will increase carbon emissions not reduce them. I am concerned about their drilling Technics and polluting the ground water systems. I do not believe that their treatment of produced water is safe to the environment. And the destruction of the Pilliga Forest is not warranted, the timber industry has all but been shut down because the Pilliga was thought to be worth saving so is the verdict now changed and this area is a waste land? Well it soon will be!

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.

GREENHOUSE 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 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.

This is a significant environmental corridor. I do not believe short term monetry gain will recompense future generations for such a loss in biodiversity.

TRIPLE-STACKED HORIZONTAL WELLS -
I totally support the case as made below by land/water/community in Canberra.

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.

GREENHOUSE 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 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.

The new coal seam gas wells known as triple-stacked horizontal wells have inherent risks involved due to the re-drilling of wells and the inability to seal off the groundwater from contamination. 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 have grave concerns about this 'pilot' project, for many reasons:

* The scale is more that of a gasfield and the environmental damage there is already evident in the clearing for pipelaying and lack of site studies for habitat species such as the Pilliga Mouse as they do so.

* Danger of methane and drill fluids leaks into the aquifers due to the 'Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells . It is known to be very difficult to seal the junction between the casing and the lateral.
NSW Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions.

* Produced water disposal?? 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.
The evidence of past spills as at Bohena Well should be enough to make extreme caution the benchmark. But 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. This must be done before Santos proceed further.

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.

* The clearing and drilling required for these wells and infrastructure could be slow death for the Federal and State listed threatened species of the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koalas, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, an internationally recognised Important Bird Area ( IBA) .


Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The clearing underway already should not be happening before baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse and other threatened species.

* The dry bush of 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. The Dewhurst 22 well, their first, is clearly not managed well for fire risks and is of great concern to local farmers who saw it.

* It is shameful that Aboriginal Heritage requirements 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.

* The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. 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.

* The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

* The 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.