Narrabri Gas - Dewhurst Exploration

I strongly oppose Expansion of Dewhurst coal seam gas exploration pilots due to the following points:
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 have not yet been commissioned and some are still to be 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.

Please see my comments regarding this proposal. We need governments to support development of renewable energy and slow down the unsustainable exploitation of natural resources.



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.

In regard to the Pilliga expansion, if we poison or fracture the great artesian basin or other aquifers, potentially we will destroy the feed producing capabilities of all the country that depends on the underground water. We shouldn't be jeopardizing the future of all Australians for a short term financial gain of coal seam gas. This insidious industry is destroying property values, peoples lives and communities.

I strongly oppose the development of CSG in the Pilliga because there have been no cumulative studies done to determine the impact on the Great Artesian Basin. The Water Trigger Amendment in the EPBC Act was introduced to assess the impacts on underground water supplies. Instead Santos have chosen to introduce this project on a piecemeal basis so that the impacts to water are seen as minimal. This is in defiance to a trigger that was introduced to protect the water at the insistence of communities and concerned landholders. Impacts must be assessed. Baseline testing has never been done in the Pilliga.

I arrived in Australia in 1971 and fell in love with the people and environment. These are the items that attract people from around the world. More recently we seem to have lost sight of both what is of value to our nation, but also of our vulnerability. Mining and resources have provide an immediate boom, but they are not our long term future. All over the world nations are moving to clean energy and finding it cost effective. Australia with its sunny climate is well positioned to be a world leader. I can not imagine that we would risk our precious underground water supply, prime agricultural land and rural communities in the pursuit of coal seam gas.
The Pilliga is an important recharge area for the Great Artesian Basin. Important issues that are of concern are the impacts of drilling, the storage and pruriication of wastewater. Why CSG? Why risk our land, people and resources for profits to multinational companies.

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

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

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

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

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

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

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

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.

It is unbelievable that any government would risk any landscape in NSW and expose any landscape in NSW to such permanently destructive and forever damaging processes all in the pursuit of a quick massive dollar for a very few (very little permanent employment in CSG fields) while those left in these despoiled landscapes struggle with ill health and air, soil and water that is forever never as pristine. ICAC should be investigating the Ministers and public servants pushing this horrendous CSG industry with its known toxic consequences ( see SE Queensland in just a few short years and of course places such as Wyoming in the USA) onto citizens who have demonstated and recorded that they do not want to live in CSG despoiled landscapes that will make them sick and difficult to use productively. The flora and fauna will be so negatively affected....we have a responsibility to them and not a few profit takers. Any government that cannot see the long term view and protect its citizens from industries which have known catastropic and permanent affects should not be our government.

I live on the irreplaceable Liverpool Plains of New South Wales; it is my home and I am protective of this area and the idyllic life it provides me. I am a young woman of 29 and I hope to be blessed with many decades more on the Liverpool Plains untainted by environmentally damaging industries. I am an active and passionate opponent of the coal seam gas (CSG) industry and Santos' plans to turn north-west New South Wales into a gas field.

I am utterly appalled that Santos' CSG exploration is being allowed in the Pilliga Forest. Utterly appalled! In my opinion the national significance of the Pilliga Forest is on par with the Liverpool Plains. We cannot afford to lose either of these national treasures. They are no place for the destructive practices of coal seam gas extraction. Both should be protected from this industry and what Santos has planned. Under no circumstances should companies like Santos be allowed to put their survival at risk.

I find it absolute madness that this significant forest which contributes to the health of Australia's natural environment is being put at such grave danger of irreparable damage. Coal seam gas is considered more important to the New South Wales Government than the sustainable future of our environment; the very same environment that supports human life. Santos is being allowed to operate against the wishes of people like myself who are fighting incredibly hard against coal seam gas' invasion of north-west New South Wales; all because of profit, and the furphy that we are headed for a gas shortage crisis. Santos has NO social licence to be operating here! Coal seam gas is not of national significance. It is most certainly not of greater national significance than the Pilliga Forest or the Liverpool Plains! Its extraction must be stopped!

If Santos gains a foothold in the Pilliga Forest, then what hope is there that the Liverpool Plains will be spared? I deeply fear that if the Pilliga is destroyed and lost to a gas field then so will my home, the Liverpool Plains. If the irreplaceable assets such as the native flora and fauna of the Pilliga are not important enough to protect then the irreplaceable soil and water of the Liverpool Plains stands no chance of protection either. My home is no place for extractive industries and I hold grave concerns for this region to sustain the way of life that is so dear to me. The Liverpool Plains cannot support the co-existence of CSG and other industries such as the unmatched productivity of its agricultural industry. CSG will destroy all that makes the Liverpool Plains unique and the only place that I wish to live my life.

I request and have high expectations that the New South Wales Government will carefully consider and genuinely take on board the importance of my home and its protection by nipping the coal seam gas industry in north-west New South Wales in the bud with the protection of the Pilliga Forest. I wish to also draw to the Government's attention the following points that have been provided to me, which I support fully.

There is deep concern about the triple-stacked horizontal wells that Santos is planning for Dewhurst 13-18H and 31. The `Triple-Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, 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 economic benefit of Santos' operations in the Pilliga is not even cemented by proof! The assessment that has been done doesn't take into account any costs of the project. They're only claimed benefits! This is scarcely enough evidence to prove that these projects are in the best economic interests of New South Wales. The ABS, the Productivity Commission, and the Land and Environment Court have respectively labelled this approach as "biased", "abused" and "deficient". It doesn't even 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 November last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.

Air, as our most critical requirement for survival, must not be compromised through CSG operations! And it is of great concern that if Santos forges ahead with its plans; 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. We currently have no way of pointing the finger at Santos when our air is polluted through its operations and proving they are the sole cause.

Second only to air, water is vital to our survival. We need clean, reliable water to survive. The drilling of Dewhurst 13-18H and Dewhurst 26-31 pilots wells will produce an additional 331, and 413 megalitres respectively over three years through their operation. They will bring to the surface water that is highly saline and contains heavy-metals and petrochemicals. Santos still does 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.

The Pilliga is home to magnificent and irreplaceable flora and fauna. 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 has 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. Santos threatens the Pilliga's biodiversity and its ability to home already endangered species.

What about the impact of the greenhouse gases Santos' wells will be emitting? It is a farce that CSG is a more environmentally friendly energy choice than coal for example. It is bollocks! 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.

Santos is also not addressing the fire hazard its operations pose to this irreplaceable forest. 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.

In regards to heritage; it is extremely disappointing to many 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.

The Pilliga Forest MUST be protected from coal seam gas. It MUST! My life here on the Liverpool Plains depends on it!

I thank you kindly for the opportunity to have my say in opposition to Santos' plans for the Pilliga.

The Pilliga forest deserves to be protected. We don't have the scientific evidence to support the long term non-detrimental effects from CSG. We only have to look at the long term damage that has been done in the United States to be very wary about what we allow here in Australia. We need to protect the Great Artesian Basin from possible toxic encursions.

Submission on the Expansion of Dewhurst coal seam gas exploration pilots

Produced water

The EIS Appendix 3 Ground Water Technical Impact Report states that 'the total volume of water to be abstracted from the Maules Creek Formation coals (five active pilots) is 1.41 GL.'.
According to the recent report commissioned by the NSW Chief Scientist and Engineer titled 'Coal Seam Gas: Produced Water and Solids' the management of produced water presents a highly challenging problem due to the generally high salt content of produced water (Khan and Kordek, 2013: http://www.chiefscientist.nsw.gov.au/__data/assets/pdf_file/0006/38157/OCSE-Final-Report-Stuart-Khan-Final.pdf). The authors of the report state that "such high salinity solutions can have significant detrimental impacts if discharged to freshwater streams or rivers."
However, the EIS does not provide adequate information on how salt contained in produced water will be managed and disposed of satisfactorily. In fact, the main body of the EIS only uses the word salinity once when it states that, in relation to aquatic ecosystems:
"The two pilot sites will be managed to ensure that no water used for drilling and operation is discharged to drainage lines and that existing salinity, turbidity and pH levels of surface waters are maintained."
This statement does not refer to the management of produced water but only to "water used for drilling and operation". There is not adequate information provided in the EIS to determine whether salty produced water will be managed effectively. In fact, Appendix 3 (Ground Water Impact Technical Report) or Appendix 4 (Ecological Assessment) of the EIS do not even make mention of the words salinity or salt.
In light of the complete lack of any solutions to manage high salt content of 1.4 GL of produced water, the project should not be authorised to proceed before a detailed plan for the management of salt from produced water has been published for public consultation and comment, and approved by the Director-General.

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 have not yet been commissioned and some are still to be 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.

A RESP0NSE TO SANTOS DEWHURST GAS EXPLORATION PILOT EIS
Concern must be expressed at a number of aspects of the proposed exploration:

Threat to the Great Artesian Basin and other aquifers:
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.
Santos has acknowledged that they have difficulty sealing these junctions. They appear to have little concern for the pollution of the Great Artesian Basin and other aquifers by either drill fluids or gas escapes and the down draining of aquifers.
The water model used by Santos lacks the basic data to assess impacts of drilling of coal seam gas on groundwater in the future.
Waste products
Santos' inabiliity to provide convincing responses to issues of problems of environmental degradation caused by waste products is of great concern:
Salt: The extraction process produces 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.
Concern must be expressed at Santos' `complete lack of solutions' as reported in the SMH (5/12/2013 `Coal seam gas industry faces salt overload') with regard to the salt brought to the surface during exploration and mining.
The report observes: `University of NSW's Stuart Khan and Geena Kordek cited Santos' recently approved drilling project in the Pilliga Forest....It will probably produce an average of three tonnes of salt a day over three years, or as much as five tonnes daily during peak output.'
The company's record is not a reassuring one. As the SMH report reminds us: `The company is now building two 300-million-litre ponds adjacent to Pilliga to hold water produced from its gas wells. Part of the operations were suspended in 2011 after 10,000 litres of untreated saline water leaked from a pipe.'
Methane leakage and gas flaring:
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.
Again Santos' record is not reassuring with accounts of Rural Fire Service access being blocked by Santos to parts of the Pilliga during the recent severe bushfire period and catastrophic fires in NSW.
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.
Indigenous Heritage
The Gomeroi people have been denied their rights to have their traditional knowledge considered as part of this Planning proposal. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through sacred sites, bush-medicine and cultural practices.
Threatened species:
The further drilling threatens species that live in 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, including the internationally protected Rainbow Bee-eater. Santos have acknowledged 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 all threatened species.
Economic Consideration:
The assessment that has been done fails to take into account any costs of the project, only claimed benefits. The Director General Requirements call for a demonstration of "net benefit" to the NSW community. There is no cost benefit analysis in the EIS. The guidelines established by NSW Treasury and Department of Planning in November, 2012 specifically to guide cost benefit analysis of mining and CSG projects have not been followed.

Thankyou for the opportunity to submit,on behalf of my family and self to this proposed Dewhurst Gas Expansion.
As self employed dryland farmers and graziers,in the Narrabri Shire, underground water is our ONLY source of water.
It is difficult for the millions of people across Australia including city bred, Government employed politicians and bureaucrats to envisage the scenario ie their only source of water disappearing from their taps or being rendered unpotable from contamination.
The above is what we face with the ceaseless inundation of csg wells that, if allowed to commence, will proliferate by the thousand upon thousand. Refer to the GSOO report Nov. 2013.
If the government proceeds to allow the csg extraction industry to commence, the inevitable consequence will be the damage to the only reliable source of water the people and stock have available to sustain life.
There is NO legal protection for any singular farm operation.
There is only a whole aquifer requirement of accountability for water.
Is the Australian government prepared to allow this to happen to their citizen farmers, for the financial gain of the government?
I reiterate, is the Government of Australia and NSW going to legally accept that an individual farmer, must use their own assets to fund a law suit to prove that they have suffered damage or loss to their potable underground water by a mining company, or government or other landholder.
The scenario is this, if Dewhurst is eg. 6 kms away, from a private farming operation and whence, if allowed, the SANTOS site commences exploration/ pilot production and the farm 6 kms away develops lowering of water in bores or contamination, it is up to that suffering farmer to take the whole of SANTOS( or the limited subsidiary company) to court to prove it or just walk away from the farm?
Is this really, the scenario that the three tiers of Governments of Australia are going to allow to happen to their farmers?
YES, this is the scenario we are facing.
There are many people who have had the entire PR machine of SANTOS telling them that it wont happen. But it IS happening to landholder, as we speak, in the Narrabri area close to SANTOS operations. Someone I spoke to recently said their water "has changed" and they now must change their filters every fortnight on their bore. These are good, honest Australians, who you, the government are going to allow to be the 'collateral damage'. The whole of agriculture is going to be the collateral damage eventually, if we allow it.
The farmers in the North West of NSW have overwhelmingly said they want to be CSG FREE. Therefore there is no social license in the North West for SANTOS to expand and expand they must if the cost to benefit ratio is to implemented. We urge you, the government, to acknowledge that you have been advised by your farmers that they have a majority of NO CSG development until the legal liabilities are confirmed.
I have spoken this morning with a farmer from Roma QLD who states that some bores have dropped 8 metres.
We the farmers of the North West will not allow our ONLY water resource to be lost. As a member of the SANTOS community consultative committee in Narrabri, I urge the government to please look into the legal aspects of protection for individual farmers assets rights of WATER against the might of SANTOS. Make good arrangements from SANTOS only apply if the farmer can prove that SANTOS caused the damage, and that means a court case.
The farmers are between a rock and a multinational mining company. That is why we are against the commencement of any wells either at Dewhurst or any site in PEL 238 until the full legal liability is set clear to all, including all levels of Government. There will be no social license for the advancement of CSG in the NW of NSW from our family business or the next until these matters are resolved to our satisfaction. We implore you to NOT sign off on any application by SANTOS IN PEL 238.
Thankyou,
regards,
Victoria, Charles and Angus Hamilton
ERROLDOON
WEE WAA
NSW 2388

SANTOS DEWHURST GAS EXPLORATION PILOT EIS

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 have not yet been commissioned and some are still to be 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.

Dear Director General

We write to you in relation to the Dewhurst Gas Exploration Pilot Expansion (SSD 13_5934) currently on public exhibition. For the record, we believe the Dewhurst Gas Exploration Pilot Expansion to be prevenient and entreat the Department to veto any such proposals until at least such times as the final report of the NSW Chief Scientist's investigation into the Coal Seam Gas Industry of NSW is delivered, including any recommendations, and to seek further consultation on her findings.

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

To the broader concern, the community increasingly is worried about what mining and coal seam gas industries will mean for this Shire. Industrialisation of agriculturally-productive land on a very large scale, particularly with coal seam gas, is not a prospect that I want to leave my children and grandchildren. I do find it alarming that Council appears ready to jettison 150 years of sustainable food and fibre production together with the prosperity and the communities that it has nurtured, for an export industry that will result in a trebling of prices of gas in Australia and a decimated community. Removing the restrictions on CSG extraction in NSW will not stop the wholesale price from tripling, nor will it stop the gas industry from exporting most of the east coast's gas. In pursuing higher profits, the industry has constructed large gas export facilities near Gladstone in Queensland. The rest of the world is willing to pay much higher prices for gas than Australians on the east coast are currently paying. When the gas industry links the eastern Australian gas market to the world market, consumers will have to match the price producers will be paid if they sell their gas overseas. The result is likely to be up to a tripling of wholesale gas prices - certainly not a boost to Australian manufacturing jobs. The gas industry has manufactured this crisis and is seeking Narrabri Shire to be complicit in solving a problem of the gas industry's own making.

Given this, we turn our attention to the specific proposal. Once again, it seems that coal seam gas giant Santos have yet more plans for dangerous multi-lateral drilling in the Pilliga Forest. 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. Santos have stated publically that this exploration project is just the beginning and that they plan to drill up to 400 wells across the pristine Pilliga Forest, the largest inland forest left in NSW. Santos already have approval to build two enormous 300 million litre wastewater holding ponds, drill eight new wells without adequate groundwater monitoring or modeling, and bulldoze extensive areas for pipelines and roads. This is all taking place in a critical recharge zone for the Great Artesian Basin!

It seems that Santos is applying for approval well by well to hide the cumulative impacts that this exploration will have on the Pilliga Forest.

The specifics of our concerns include -

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.

We urge the Director General and his Department to urgently declare a Moratorium on all infrastructure, exploration or production of coal seam gas in this State, including within the Narrabri Shire, until the absolute independent science of safety is complete. This proposal should not be permitted to proceed.

Yours sincerely
Sarah Ciesiolka

Dear Director General

We write to you in relation to the Dewhurst Gas Exploration Pilot Expansion (SSD 13_5934) currently on public exhibition. For the record, we believe the Dewhurst Gas Exploration Pilot Expansion to be prevenient and entreat the Department to veto any such proposals until at least such times as the final report of the NSW Chief Scientist's investigation into the Coal Seam Gas Industry of NSW is delivered, including any recommendations, and to seek further consultation on her findings.

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

To the broader concern, the community increasingly is worried about what mining and coal seam gas industries will mean for this Shire. Industrialisation of agriculturally-productive land on a very large scale, particularly with coal seam gas, is not a prospect that I want to leave my children and grandchildren. I do find it alarming that Council appears ready to jettison 150 years of sustainable food and fibre production together with the prosperity and the communities that it has nurtured, for an export industry that will result in a trebling of prices of gas in Australia and a decimated community. Removing the restrictions on CSG extraction in NSW will not stop the wholesale price from tripling, nor will it stop the gas industry from exporting most of the east coast's gas. In pursuing higher profits, the industry has constructed large gas export facilities near Gladstone in Queensland. The rest of the world is willing to pay much higher prices for gas than Australians on the east coast are currently paying. When the gas industry links the eastern Australian gas market to the world market, consumers will have to match the price producers will be paid if they sell their gas overseas. The result is likely to be up to a tripling of wholesale gas prices - certainly not a boost to Australian manufacturing jobs. The gas industry has manufactured this crisis and is seeking Narrabri Shire to be complicit in solving a problem of the gas industry's own making.

Given this, we turn our attention to the specific proposal. Once again, it seems that coal seam gas giant Santos have yet more plans for dangerous multi-lateral drilling in the Pilliga Forest. 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. Santos have stated publically that this exploration project is just the beginning and that they plan to drill up to 400 wells across the pristine Pilliga Forest, the largest inland forest left in NSW. Santos already have approval to build two enormous 300 million litre wastewater holding ponds, drill eight new wells without adequate groundwater monitoring or modeling, and bulldoze extensive areas for pipelines and roads. This is all taking place in a critical recharge zone for the Great Artesian Basin!

It seems that Santos is applying for approval well by well to hide the cumulative impacts that this exploration will have on the Pilliga Forest.

The specifics of our concerns include -

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.

We urge the Director General and his Department to urgently declare a Moratorium on all infrastructure, exploration or production of coal seam gas in this State, including within the Narrabri Shire, until the absolute independent science of safety is complete. This proposal should not be permitted to proceed.

Yours sincerely
Matthew Ciesiolka

Dear Director General

I write to you in relation to the Dewhurst Gas Exploration Pilot Expansion (SSD 13_5934) currently on public exhibition. For the record, I believe the Dewhurst Gas Exploration Pilot Expansion to be prevenient and entreat the Department to veto any such proposals until at least such times as the final report of the NSW Chief Scientist's investigation into the Coal Seam Gas Industry of NSW is delivered, including any recommendations, and to seek further consultation on her findings.

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

To the broader concern, the community increasingly is worried about what mining and coal seam gas industries will mean for this Shire. Industrialisation of agriculturally-productive land on a very large scale, particularly with coal seam gas, is not a prospect that I want to leave my children and grandchildren. I do find it alarming that Council appears ready to jettison 150 years of sustainable food and fibre production together with the prosperity and the communities that it has nurtured, for an export industry that will result in a trebling of prices of gas in Australia and a decimated community. Removing the restrictions on CSG extraction in NSW will not stop the wholesale price from tripling, nor will it stop the gas industry from exporting most of the east coast's gas. In pursuing higher profits, the industry has constructed large gas export facilities near Gladstone in Queensland. The rest of the world is willing to pay much higher prices for gas than Australians on the east coast are currently paying. When the gas industry links the eastern Australian gas market to the world market, consumers will have to match the price producers will be paid if they sell their gas overseas. The result is likely to be up to a tripling of wholesale gas prices - certainly not a boost to Australian manufacturing jobs. The gas industry has manufactured this crisis and is seeking Narrabri Shire to be complicit in solving a problem of the gas industry's own making.

Given this, I turn my attention to the specific proposal. Once again, it seems that coal seam gas giant Santos have yet more plans for dangerous multi-lateral drilling in the Pilliga Forest. 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. Santos have stated publically that this exploration project is just the beginning and that they plan to drill up to 400 wells across the pristine Pilliga Forest, the largest inland forest left in NSW. Santos already have approval to build two enormous 300 million litre wastewater holding ponds, drill eight new wells without adequate groundwater monitoring or modeling, and bulldoze extensive areas for pipelines and roads. This is all taking place in a critical recharge zone for the Great Artesian Basin!

It seems that Santos is applying for approval well by well to hide the cumulative impacts that this exploration will have on the Pilliga Forest.

The specifics of our concerns include -

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 urge the Director General and his Department to urgently declare a Moratorium on all infrastructure, exploration or production of coal seam gas in this State, including within the Narrabri Shire, until the absolute independent science of safety is complete. This proposal should not be permitted to proceed.

Yours sincerely
Carolyn Nankivell

Dear Director General

I write to you in relation to the Dewhurst Gas Exploration Pilot Expansion (SSD 13_5934) currently on public exhibition. For the record, I believe the Dewhurst Gas Exploration Pilot Expansion to be prevenient and entreat the Department to veto any such proposals until at least such times as the final report of the NSW Chief Scientist's investigation into the Coal Seam Gas Industry of NSW is delivered, including any recommendations, and to seek further consultation on her findings.

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

To the broader concern, the community increasingly is worried about what mining and coal seam gas industries will mean for this Shire. Industrialisation of agriculturally-productive land on a very large scale, particularly with coal seam gas, is not a prospect that I want to leave my children and grandchildren. I do find it alarming that Council appears ready to jettison 150 years of sustainable food and fibre production together with the prosperity and the communities that it has nurtured, for an export industry that will result in a trebling of prices of gas in Australia and a decimated community. Removing the restrictions on CSG extraction in NSW will not stop the wholesale price from tripling, nor will it stop the gas industry from exporting most of the east coast's gas. In pursuing higher profits, the industry has constructed large gas export facilities near Gladstone in Queensland. The rest of the world is willing to pay much higher prices for gas than Australians on the east coast are currently paying. When the gas industry links the eastern Australian gas market to the world market, consumers will have to match the price producers will be paid if they sell their gas overseas. The result is likely to be up to a tripling of wholesale gas prices - certainly not a boost to Australian manufacturing jobs. The gas industry has manufactured this crisis and is seeking Narrabri Shire to be complicit in solving a problem of the gas industry's own making.

Given this, I turn my attention to the specific proposal. Once again, it seems that coal seam gas giant Santos have yet more plans for dangerous multi-lateral drilling in the Pilliga Forest. 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. Santos have stated publically that this exploration project is just the beginning and that they plan to drill up to 400 wells across the pristine Pilliga Forest, the largest inland forest left in NSW. Santos already have approval to build two enormous 300 million litre wastewater holding ponds, drill eight new wells without adequate groundwater monitoring or modeling, and bulldoze extensive areas for pipelines and roads. This is all taking place in a critical recharge zone for the Great Artesian Basin!

It seems that Santos is applying for approval well by well to hide the cumulative impacts that this exploration will have on the Pilliga Forest.

The specifics of our concerns include -

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 urge the Director General and his Department to urgently declare a Moratorium on all infrastructure, exploration or production of coal seam gas in this State, including within the Narrabri Shire, until the absolute independent science of safety is complete. This proposal should not be permitted to proceed.

Yours sincerely
Kate Nankivell

Dear Director General

I write to you in relation to the Dewhurst Gas Exploration Pilot Expansion (SSD 13_5934) currently on public exhibition. For the record, I believe the Dewhurst Gas Exploration Pilot Expansion to be prevenient and entreat the Department to veto any such proposals until at least such times as the final report of the NSW Chief Scientist's investigation into the Coal Seam Gas Industry of NSW is delivered, including any recommendations, and to seek further consultation on her findings.

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

To the broader concern, the community increasingly is worried about what mining and coal seam gas industries will mean for this Shire. Industrialisation of agriculturally-productive land on a very large scale, particularly with coal seam gas, is not a prospect that I want to leave my children and grandchildren. I do find it alarming that Council appears ready to jettison 150 years of sustainable food and fibre production together with the prosperity and the communities that it has nurtured, for an export industry that will result in a trebling of prices of gas in Australia and a decimated community. Removing the restrictions on CSG extraction in NSW will not stop the wholesale price from tripling, nor will it stop the gas industry from exporting most of the east coast's gas. In pursuing higher profits, the industry has constructed large gas export facilities near Gladstone in Queensland. The rest of the world is willing to pay much higher prices for gas than Australians on the east coast are currently paying. When the gas industry links the eastern Australian gas market to the world market, consumers will have to match the price producers will be paid if they sell their gas overseas. The result is likely to be up to a tripling of wholesale gas prices - certainly not a boost to Australian manufacturing jobs. The gas industry has manufactured this crisis and is seeking Narrabri Shire to be complicit in solving a problem of the gas industry's own making.

Given this, I turn my attention to the specific proposal. Once again, it seems that coal seam gas giant Santos have yet more plans for dangerous multi-lateral drilling in the Pilliga Forest. 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. Santos have stated publically that this exploration project is just the beginning and that they plan to drill up to 400 wells across the pristine Pilliga Forest, the largest inland forest left in NSW. Santos already have approval to build two enormous 300 million litre wastewater holding ponds, drill eight new wells without adequate groundwater monitoring or modeling, and bulldoze extensive areas for pipelines and roads. This is all taking place in a critical recharge zone for the Great Artesian Basin!

It seems that Santos is applying for approval well by well to hide the cumulative impacts that this exploration will have on the Pilliga Forest.

The specifics of our concerns include -

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 urge the Director General and his Department to urgently declare a Moratorium on all infrastructure, exploration or production of coal seam gas in this State, including within the Narrabri Shire, until the absolute independent science of safety is complete. This proposal should not be permitted to proceed.

Yours sincerely
Warrick Nankivell