Narrabri Gas - Dewhurst Exploration

The people MUST be consulted before a change of this magnitude is countenanced. It is highly irregular and undemocratic to put this through with such inadequate public discussion.
Shame.
Stop this and bring it to the proper forums, if you have any sense of democratic propriety left in you.

I wish to object to the Santos proposal based on the following submission:

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.

Yours faithfully,

Annalise Field

To the department of Planning & Infrastructure panel.
I would like to voice my opposition to the proposed Dewhurst Pilots in the great Pilliga forest.
The Pilliga forest is ecologically vulnerable to many aspects of industrial gas mining activities.
As an important recharge zone for the Great Artesian Basin (GAB) there is much at stake if accidental contamination of ground water and aquifers were to occur.
If the casings fail (none are guaranteed lifetime) or Santos cannot manage to secure the casings of the risky tri-lateral 13- 18 H at the 31 line, there is a risk of interconnectivity with brine aquifers, industrial drilling fluids or produced water, methane, radon and other gases escaping into the GAB. It is clear there will be a drop in the GAB levels related to these pilots, and the baseline water studies and modeling are yet complete.
Santos have yet to demonstrate or have approval for safely dealing with the vast quantities of toxic produced water from Dewhurst Pilot wells or future operations. There is already a tragic history of produced water spills in the Pilliga. This must not happen again. Yet Santos have yet to demonstrate that it will not happen again.
Santos identified a number of endangered flora and fauna species covered by the EPBC act to be/ or potentially be within a 10km radius of activities. The preparation and out-lay of Dewhurst pilots would create enormous disturbance within the Pilliga with drilling operations, clearing and digging 10 meter strips for pipelines, and clearing additional forest for access roads, well sites, a water storage facility and a gas flaring site. The potential disturbance of critical habitat, increasing noise, vibrations and works related traffic maybe fatal for rare fauna, such as the Pilliga Mouse, Koala's, the Black Striped Wallaby, Eastern Pygmy Possum.
Santos has not conducted baseline studies of air quality, to compare any potential and likely future fugitive methane emissions against pre-Dewhurst pilots.
The Pilliga is a bushfire prone forest. It appears there is not a bushfire strategy, unintentional fugitive emmssions and gas flaring pose a great risk.
Should Santos get approval for the Dewhurst pilots, and provided they find sufficient methane flows, Santos will seek further approvals with the aim of hundreds of gas wells in the Pilliga forest and surrounding farm lands. The cumulative effect on the Great Artisean basin, flora and fauna covered under the EBPC act, and cultural sites could be catastrophic.

I strongly object to this proposal. Please stop destroying us all and our future for short term financial gain.

Mr Hazzard,

There is enough gas off the W.A. Coast for decades to come.
The NSW Government must protect these important environment areas of the Piliga, the Great Artesian Basin and our threatened flora and fauna. Interfere with the Great Artesian Basin and what will economic growth mean then?

More than enough damage has already been inflicted upon the Hunter Valley and the Liverpool Plains. Protect the Piliga and the Great Artesian Basin.

I have reviewed Appendix 3 "Groundwater Impact Technical Report" of the RPS Dewhurst Gas Exploration Pilot Expansion EIS ("Report A"), Appendix 3 of the "Bibblewindi Gas Exploration Pilot Expansion EIS" of 9 July 2013 (Report B), the report "Referral of Proposed Action: Water Resource Assessment, Energy NSW Coal Seam Gas Exploration Program" of 7 June 2013, each prepared for Santos NSW (Eastern) Pty Ltd and the State Significant Development Application ("the application").

Report A is largely repetitive of Report B.

Importantly, Report A states "The findings of this report should be read in conjunction with the Narrabri Groundwater Model Report (CH2M HILL, 2013) which presents the basis for the creation of the groundwater flow model", and yet I have been advised this report, which one would assume to be critical to understanding the basis on which conclusions have been reached, is not available.

I am therefore greatly restricted in my capacity to make comment and have no choice but to limit it to the following:

No basic hydrogeological or geological data has been provided. As well, apart from a general location map and an even more generalized cross-section (referred to below), there are no maps or diagrams relating the Dewhurst wells to geology or hydrogeology. It is therefore not possible for any expert in these fields to make any meaningful comment as to whether the conclusions reached in the above mentioned reports are justifiable or not or if the applied for operations would be of risk to the environment, specifically water resources.

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

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

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

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

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

* On what basis is it predicted that horizontal wells can be drilled and remain wholly within the target coal seam (this would be dependent on coal seam thickness, facies continuity and structural aspects)?
* On what basis is it claimed there would be no aquifer interference?
* On what is the predicted 2m decline in groundwater head based on and if and how this prediction may relate to the application?

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

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

I would emphasise that the above simply provides a statement of the reasons I am unable at this time to either verify or dispute the findings and as well is an expression of some of my concerns. It is these concerns, exacerbated by an almost total lack of supporting data or evidence for the conclusions reached in the either Report A or Report B, that leaves me with no choice but to recommend that the Federal Government declines the application.

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

I object to the destructive CSG mining of this priceless and irreplaceable agricultural land and protected area of our nation, please do not permit it to continue.

As a resident and farmer in the central west, I have grave concerns regarding Santos's proposed expansion of the Dewhurst mine in the Pilliga forest.

As The Pilliga is a recharge area for the great artesian basin, I have grave concerns regarding the potential impacts this could have on underground water quality. Bore casing fail, and leakage does occur. The impact if this cannot be reversed if underground aquifers are contaminated. This industry is not a long term one, yet could put at risk agricultural industries that have been in the area for over a hundred years.

Having seen the site of the Eastern Star gas spill in the Pilliga, I am aware of the devastating impacts a spill of waste water from CSG wells can cause. This site, is not regenerating, despite the intensive efforts of Santos to show this as a success story of their management.

I believe that the company has not given any adequate explainations as to how they will deal with the mountains of waste salt that will be liberated from the wells, and has not agreed to full disclosure of all chemicals they wish to use in this sensitive area.

I also believe that the fire risks, and air pollution from venting of gas from water lines, are unacceptable in a region such as the Pilliga. Having experienced the wild fires in the Warrumbungles, this expansion will place significant risk for this area as well.

the other concerns that I have 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

Thankyou for taking the time to seriously evaluate the risks this proposed expansion will have on our future, and the future of this region, and I implore you to find against it.

I oppose the Dewhurst Gas Exploration Pilot Expansion and object to the industrialisation and dangerous drilling in the Pilliga Forest in north west NSW. The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. With catastrophic fire days predicted to increase in the future, Santos does not appear to have a clear bushfire strategy especially for shutting down gas flares which have occurred in other exploration sites.
The drilling of horizontal coal seam gas wells through the casing of existing wells in the Dewhurst Expansion poses great danger to the Great Artesian Basin and other aquifers. To seal the junction between the casing and the lateral is very difficult, if not possible. I am concerned for the pollution of aquifers by either drill fluids or gas escapes.
The NSW coal seam gas industry has a complete lack of solutions to deal with large quantities of salt and contaminated water and Santos has no long term plans for this produced water. There is insufficient baseline data of water, flora and fauna in regards to the long term impacts of coal seam gas exploration in the Pilliga forest.

What is proposed is an unlawful act and therefore it is my position to point this out.

1/ The act in question is unlawful as there is sufficient evidence to demonstrate that the act in question has the capacity to cause injury to people, property and the atmosphere.

2/ That the act in question is, on the balance of probability Knowingly reckless our done with reckless indifference and endangerment to human life.

3/ That the likelihood of contamination to water resources far out weighs the what is quantifiable by measure of statistical significance. (30% of wells have failed in operation process).

It is with great urgency that these matters are considered in approaching any gas exploration and such practices cease immediately.

Michelle Arquette

Dear Sir,


I write to you to express my concerns about the Santos Dewhurst Gas Exploration Pilot EIS around the following areas:


1. 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. I am reliably informed that (by drillers) that it is very difficult, if not impossible, to seal the junction between the casing and the lateral.
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.

2. ECONOMICS:

The assessment does not appear to 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 does not comply with Director Generals Requirements.
DGRs call for a demonstration of "net benefit" to the NSW community. As thinking tax payer, I would imagine that a cost benefit analysis is required, but 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.

3. 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.

4. 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.

5. 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.

6. 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.

7. 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.

8.HERITAGE:
It is extremely disappointing that Aboriginal Heritage requirements were taken out of the Director General Requirements. The Gomeroi people, 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 trust that you will take into consideration the short and long term risks presented by this project in comparison to the perceived profit.

To whom it may concern,
The following may be in point form and from a resident from the Hawkesbury region but this matter affects the entire country. I say NO to Coal Seam Gas anywhere in Australia and support the residents of the Pilliga region who are against Santos and others who are for this type of mining.

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.

Faithfully
Rebecca Sykes

The health and environmental effects that are evident in Queensland and else where around the world must be considered. This industry must be stopped until they can prove it is safe. They say it is different in the US but the earth is all the same.Where coal and gas deposits are found it is generally a similar geological area anywhere in the world.
Santos has no plans in place to dispose of the salt and produced water. No matter what you name them, they are constructing holding ponds which have been banned. They have no plans for a fire, the mere fact they can still flare and vent when the region is under a total fireban is just ludicrous. They have not seen a big fire go through the scrub and it will not be stopped. They should have been in the middle of the Coonabarabran fire earlier this year to realise with both flaring and fugitive emissions of methane it is a death trap. There is no proof that blasting apart coal seams is safe, even if they are not fracking. The evidence shows the opposite, that it is very likely that our groundwater will be both contaminated and wasted.
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.
The GAB is 22% of Australia, how can this be put at risk for a short term industry that will have catastrophic effects when they are long gone and the pressure has gone and the water of the GAB are wasted and poisoned.

No need for a dead energy when there is limitless free energy available from the zero point energy field surrounding
the whole planet.

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.

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.

There is only one Pilliga it should not be damaged by allowing the production of COAL SEAM GAS.
Water is a fare more important resourse than csg. If Santos cannot give a guarantee that the water in the other
aquifers will not be polluted buy their drilling into the coal seams for the methane then they should not be given
permission to proceed with further drilling.They should also guarantee there will not be any draw down other aquifers
such as the Great Artesian Basin.They have not done the base line studies for these important ground water
systems.Base line studies are not worth much when it comes to protecting this underground water because when a problem arises it will in most cases be impossible to fix.
Biodiversity Both plants and animals will be adversely impacted by the industrialisation of the Pilliga. A base line study will be worth while. We already know the plants and animals will be adversely impacted the study will only tell us buy how much. To bad for the plants and animals if Santos are given permission to continue drilling.
Economics Santos would not proceed with this project if they had to pay the true cost of insuring nothing happened to
our water and biodiversity.
They should also be made to pay when they pollute our air so they need to have base line studies and then monitoring
stations which are monitored buy an independent authority.
They should be made responsible for bush fires that are caused buy gas flaring.
The concerns of the aborigines should also be considered.

I am writing with great concern about the proposed CSG mine SANTOS DEWHURST GAS EXPLORATION PILOT
EIS at the Piliga forest for the following reasons:

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 andEnvironment 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), 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 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.
It begs insanity to pursue such a project to produce more fossil fuel emissiond and destruction of natural
environments. It must be stopped.

I object tot the Pilliga project as proposed.

I note that the project is only a small part of Santos's plans for the region.

The cumulative impacts cannot be determined and it is totally inappropriate for the company to be putting up piecemeal its project so that the cumulative impacts cannot be determined.

In fact no one knows what Santos has planned for the region except for a fully blown gasfield. They have said they will frack, won't frack, have 1100 wells, 400 wells, 550 wells depending on the audience and their whim.

Those people who will be impacted, the communities surrounding the Pilliga Forest have rejected the notion of a gasfield in the region with up to 98% of surveyed residents saying no to invasive industrial gasfields. I have attached photos of community celebrations declaring those communities gasfield free and a sample survey form.

The following points address the concerns of these residents and should be sufficient to deny the project. There is no gas crisis in NSW as there is plenty more gas in the Bass Strait and "Planning" departments should be working on how we get off fossil fuels and on to renewable energy as soon as possible.

If you are a "planner" reading this - ask yourself "Why am I working against the wishes of the local people, encouraging fossil fuels when we should be shutting them down and damaging our largest inland forest and adjacent farmland for the benefit of foreign owned companies?"

If you find yourself skipping that question - you are part of the problem.


<--------------------------------------------------------------------------->
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.

Santos are proposing methods that are proven dangerous to aquifers and therefore have failed to meet the Director General Requirements for this project.

Santos knows that their so called "multi-lateral drilling" or "triple stacked" process is dangerous and threatens the environment and the Great Artesian Basin. This alone is justification to impose an immediate moratorium until other more important considerations are PROPERLY EVALUATED.

Economically this project is a disaster for Australia. The so called assessment process has enumerated only the benefits and NONE of the costs to the community the environment and the nation. 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. SHAME on the government!

The granting of unrestricted use of ground water for CSG extraction is totally unconscionable. At the very least such usage should be on the same conditions and AT THE SAME COST as agricultural extraction. The discharge of hundreds and thousands of megalitres of so called "produced water" is an environmental disaster and a national shame!

Piliga State Forest is an environmental asset that has been long appreciated for its biodiversity. It supports many threatened species. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse.The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.

As a former operator of airborne exploration for mining companies in Canada USA Africa and Australia, I can attest that mining companies have NO interest in preserving the environment and are happy to dump their filth (read heavy metal tailings, "produced water" etc. etc.) in the most convenient (cheapest) place and leave behind their rusting infrastructure and a damaged environment when they have taken all they can. Miners are even less trust worthy than politicians bankers and internet fraudsters!

There are many other reasons to end this (and most other CSG projects) and they have been addressed by other submissions. They include:
AIR QUALITY - fugitive emissions, flaring and heavy equipment diesel exhaust
GREEN-HOUSE GASES - The latest studies of nconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought.
HAZARDS - The Pilliga is highly susceptible to fires; e.g. lightning & gas flaring
HERITAGE - Aboriginal Heritage requirements for were taken out of the Director General Requirements. SHAME!!!!

I am attaching a pdf file with the text of this submission FOLLOWING three graphics which show 1) the drilling pattern originally proposed for Piliga, 2) the same pattern adapted to the leases previously held on the floor of the Tweed Valley (where I live) and 3) an aerial photo of a typical CSG drilling operation. Remember that every one of those wells is attached to a grid of roads pipelines and power lines. This damage cannot and will not be reversed.

This will completely destroy the natural environment of the Piliga. The Pilliga Forest is a national treasure and no place for a coal seam gas field. For the sake of our grandchildren, stop this abomination NOW!

David M Palmer
partner bigvolcano.com.au, founding officer Northern NSW Ecotourism Association

See attachment number 1.