Narrabri Gas

This is an environmental disaster,before it has even happened.
The water is being poisoned.

There is an abundance of evidence of the damage CSG does to our environment - both in terms of water contamination and the impact of burning yet more fossil fuels. It's time to ban fracking altogether. Water is more important.

I am asking that my submission is treated as "CONFIDENTIAL".

I am welcoming the opportunity to make a submission in regards to the Narrabri Gas Project and would like to comment on the following issues:

Water

The National Water Commission in its report (1) stated that coal seam gas mining risks having significant, long-term and adverse impacts on water resources, including from depressurisation and contamination of aquifers.

Unconventional gas mining requires large scale dewatering of aquifers, impacting on hydrology and water availability and introducing large volumes of often saline groundwater to surface water systems. Fracking is an extremely water-intensive practice. The Australian gas industry provides a figure of 11 million litres per frack (2), however a range of other sources suggest that water use is often much higher. Wells are often fracked on multiple occasions, sometimes up to ten times, thereby multiplying the water use. Significant amounts of water are also used in drilling processes. The large volumes of waste water produced from unconventional gas mining are likely to be reinjected into aquifer formations, partially "treated" and reused or released into waterways, or trucked to holding ponds for storage. The latest information even suggests to use so-called "treated wastewater" to irrigate crops, therefore, possibly introducing chemicals and radionuclides into the food chain. The chemicals used in fracking have been shown to include many hazardous substances, including carcinogens, neurotoxins, irritants/sensitisers, reproductive toxins and endocrine disruptors (3). I have seen firsthand the effects of a spill of waste water from a holding pond in the Pilliga Forest (Santos Narrabri Gas Project), that killed all vegetation and where, even after a few years, nothing has grown back on that particular site. Farmers living near gas fields in Australia and overseas have reported a noticeable drawdown in their water bores, deterioration of water quality and contamination of water, with a very high likelihood of this being caused by unconventional gas mining. There cannot be ANY risk of pollution to groundwater and surface water from ANY industry. How can the vast use of water for any industry in a dry continent such as Australia be justified, when a lot of agricultural industries rely on groundwater for the irrigation of crops/watering cattle and towns rely on groundwater for their only water supply.


Agriculture

Across Australia large areas of highly productive farmland are under threat from unconventional gas mining. This activity has the potential to severely disrupt virtually every aspect of agricultural production and potentially even remove the land from production.

Rabobank (4) has listed the risks from coal seam gas mining to include reductions in farm productivity, efficiency, land values and credit availability. They state that "land assets are likely to be 'severely discounted' for a number of reasons, including a reduction in area of productive land, operational risks, the effect on property aesthetics, and the risk of future project expansion."

Food production for an ever increasing global population should rank first. A government that allows unconventional gas mining (and any other mining for that matter) to go ahead on or near fertile agricultural land willingly threatens the food security of this country.


Health

There are a number of serious risks to public health associated with unconventional gas development. Research by Doctors for the Environment (5) found that the current level of assessment, monitoring and regulation of unconventional gas exploration and mining activities in Australia is inadequate to protect the health of current and future generations of Australians. They have outlined three key areas where there is the potential for adverse human health impacts:

- through contamination of water, air and soil
- through diversion of water and land away from agricultural food production
- from mental health impacts on communities who have had environmental changes imposed upon them.

An independent health survey was conducted in the Tara rural residential estates and environs by Geralyn McCarron (6). It is mentioned in the executive summary, that the pattern reported was outside the scope for what would be expected for a small rural community. In all age groups there were reported increases in cough, chest tightness, rashes, difficulty sleeping, joint pains, muscle pains and spasms, nausea and vomiting. Approximately one third of the people over 6 years of age were reported to have spontaneous nose bleeds and almost three quarters were reported to have skin irritation. Over half of the children were reported to have eye irritation. A range of symptoms were reported, which can sometimes be related to neurotoxicity (damage to the nervous system), including severe fatigue, weakness, headaches, numbness and paraesthesia. Approximately a third of the children surveyed were reported to experience paraesthesia. Almost all the 31 children aged 6-18 were reported to suffer from headaches and for over half of these the headaches were severe.

Research by the National Toxics Network (7) found that there are serious risks associated with BTEX chemicals which are used in the fracking process and can be naturally occurring and mobilised by the process of hydraulic fracturing. The National Toxics Network outlines the health hazards associated with exposure to BTEX chemicals as follows: "... in the short term causing skin irritation, central nervous system problems and effects on the respiratory system. Prolonged exposure to these compounds can also negatively affect the functioning of the kidneys, liver and blood system. Long-term exposure to high levels of benzene in the air can lead to leukaemia and cancers of the blood."

Environment

No government seems to recognise the value of the environment for the well-being of its citizens. Planet Earth is the only planet we have to live on, but we treat her as if there were many more. The Pilliga Forest is the largest temperate woodland west of the Great Dividing Range, covering more than 500'000 ha, and is one of the most biodiverse areas of Australia and home to many vulnerable species of fauna. It was recognised as one of Australia's biodiversity hotspots in the early 2000's due to its mixture of coastal and inland species. The Pilliga Forest lies in the southern recharge zone of the Great Artesian Basin. Despite all this, the NSW Government has plans to allow Santos to develop a coal seam gas field in this area. If this project is allowed to go ahead, not only will it fragment and destroy the forest and the animals that live within, but there is also a great risk of aquifer contamination. Santos has already contaminated a fresh water aquifer in the Pilliga Forest with uranium - at levels 20 times higher than safe drinking water guidelines - as well as lead, aluminium, arsenic and barium. Unbelievably, they were fined just AUD 1'500 for this pollution incident.

An article (8) in SMH of 15 November 2012, "Gas body fired up over reports of methane leaks", covers a study done by researchers of Southern Cross University. Testing inside the Tara gas field, near Condamine on Queensland's Western Downs, found some greenhouse gas levels more than three times higher than nearby districts. "Methane, carbon dioxide and other gases appear to be leaking through the soil and bubbling up through rivers at an astonishing rate", the researchers said. "The concentrations here are higher than any measured in gas fields anywhere else that I can think of, including in Russia,'' Damien Maher, a biochemist who helped conduct the tests, said. ''The extent of these enriched concentrations is significant.'' Fugitive methane gas emissions are contributing greatly to global warming and climate change.

Recommendations

I do call for a national approach to the conduct of Unconventional Gas mining that includes:
- A moratorium on any new unconventional gas mining or exploration until further important research has been completed and proper baselines put in place.
- Exclusion zones to protect agricultural land, significant water resources, national landscapes and tourism icons, and residential dwellings from unconventional gas exploration and mining impacts.
- The creation of new legislation to implement the goals of the National Food Plan and to give statutory weight to the Australian Council on Food.
- Improved Federal environment laws that properly protect water sources, cultural heritage and significant environmental areas.
- Identification of best practice methods for baseline monitoring of health impacts, water resources, air quality, soil quality, and fugitive emissions.
- The creation of a Clean Air and Water Act that sets national standards on pollution from unconventional gas mining to protect human health and the establishment of a national Environment Protection Authority.
- Proper measurement and accounting of greenhouse gas emissions from unconventional gas operations.

I do call for changes to the regulatory frameworks governing Unconventional Gas mining to address the deficiencies in current legislation, including:
- Federal legislation to ensure that cumulative impacts from gas mining on nationally significant water resources, natural areas and cultural heritage sites are assessed, prevented and mitigated.
- Expansion of the EPBC Act `water trigger' so that all forms of Unconventional Gas extraction (coal seam gas, shale gas and tight sand gas), are covered by it, as well as all coal and unconventional coal developments.
- Banning of "flaring" which releases noxious air pollution and which has been banned in overseas jurisdictions.
- Require full hazard assessments and compulsory disclosure of all chemicals used in unconventional gas mining, and prohibit the use or production of chemicals that are harmful to human health or the environment.
- Use of existing federal powers to create national legislation to give Traditional Owners, landholders and communities the right to say NO to Unconventional Gas operations.

Conclusion

I am calling for a total ban of any form of unconventional gas mining in Australia. No matter what regulations are put in place or how strict they are, the risks of contamination of water and air can never be alleviated. A government that allows this industry to go ahead acts in a negligent and criminal way by putting our nation's water and food security at risk, by putting people's health at risk and by contributing greatly to the effects of global warming and climate change.

Yours faithfully,





References:
1 The Coal Seam Gas and Water Challenge, December 2010

2 APPEA: The Natural Gas Revolution

3 National Toxics Network: Toxic Chemicals in the Exploration and Production of Gas from Unconventional Sources

4 http://www.parliament.nsw.gov.au/Prod/parlment/committee.nsf/0/318a94f2301a0b2fca2579f1001419e5/$FILE/Report%2035%20%20Coal%20seam%20gas.pdf

5 http://dea.org.au/news/article/the_mining_and_burning_of_coal_effects_on_health_and_the_
environment which references this article https://www.mja.com.au/journal/2011/195/6/mining-and-burning-coal-effects-health-and-environment

6 http://www.gabpg.org.au/wp-content/uploads/2013/11/2013-04-symptomatology_of_a_gas_field_Geralyn_McCarron.pdf

7 http://www.ntn.org.au/wp/wp-content/uploads/2012/04/NTN-CSG-Report-Sep-2011.pdf

8 http://www.smh.com.au/environment/gas-body-fired-up-over-reports-of-methane-leaks-20121114-29ck7.html

I oppose any coal seam gas extraction in the Pilliga because a) the production of more methane at a time when the world is trying to reduce greenhouse gases and limit climate change is irresponsible; b) coal seam gas extraction has been proved to pollute underground waterways, which in the case of the Pilliga would mean the Great Artesian Basin is at risk; c)The Pilliga State Forest is a listed "biodiversity hotspot" and invasive mining would threaten many endangered species; d) The Gamilaraay Traditional Custodians of the land do not want this mining; e)the risk of bushfires (already prevalent in the Pilliga) would be increased manyfold due to methane burn-offs, endangering the habitat of many threatened species.

I object to any exploration for gas in the Pilliga Region on the grounds that this is a unique and invaluable environmental and economic resource in the form of the forst ecology and the water resource that lies beneath it, which will be at unacceptable risk due to the diaturbance and risk of contamination from the drilling and extraction technology of gas exploration and extraction.

Our Artesian Basin water is too precious to allow this project to go ahead

Developing onshore gas fields, be they labelled CSG, Fracking, unconventional or any other name, is an unacceptable risk to water, climate and wildlife and increases the risk and danger of wildfire.
It is entirely unnecessary to develop the Pilliga CSG project at this time. The gas will be there long into the future when, perhaps, extraction methods will be safer. However, at present, there is no need to extract this gas. Any perceived "need" is politically and industry created. There is enough gas being extracted offshore and processed onshore to satisfy domestic markets but it is all exported. This should be addressed, and sustainable energy developed, in priority to caving in to industry greed.

I am one of thousands of Australians totally opposed to the extraction of coal seam gas in this country and including my state of NSW. This gas is a fossil fuel derivative with the same pollution potential as burning coal.
I also object to companies such as Santos making money from destroying parts of NSW such as the Pilliga Forest.

Australia is sooooo behind in making new enegy choices, as a nation we have choices, fracking & drilling for gas is not the way forward,

Moving toward 2020 is about making decisions with integrity and for the betterment of our environment, letting Santos or any other large multinational corporation destroy our ecosystem in the name of profits & false needs for gas or any other arcade energy source is not the evolutionary path to take.

There has to be another way!

I strongly oppose the Santos bid to drill for coal seam gas in the Pilliga region, for the following reasons:

1. This remnant woodland supports a suite of endangered plants and animals. So called offsets could never redress their loss.

2. The indisputable facts of climate change mandate that we rapidly phase out fossil fuel use. Certainly, no new resources should be exploited.

3. The hydraulic fracking process of CSG extraction poses unacceptable risk of contaminating aquifers essential to agriculture.

Leave it in the ground!

We all know that frac - ing is polluting, contaminating - downright dangerous to the local environment to all local inhabitants including ALL FAUNA that live in the area.

Develop a clean way to extract the gas
THEN EXTRACT IT.

As the Pilliga Forest is the ONLY inland remnant woodland forest of a significant size, it MUST be retained to ensure there is some habitat for the remaining wildlife, birdlife etc - all of which are already under threat.
I have visited this extensive forest (including the caves), and admired the flocks of red-tailed black cockatoos who live in the forests.
As this distinct forest zone is under the major flight path to Asia and Europe (from Sydney) you cannot miss it's mark on the landscape in a sea of cleared agricultural or grazing land.
Its existence is also crucial for rainfall patterns.

A. The Pilliga is a haven for threatened wildlife. There will be well pads, roads, and water and gas pipelines--damaging vital habitat and threatening the survival of endangered species.

B. No one can tell me what will happen to the artesian water resource.The Great Artesian Basin and the Murray-Darling Basin are at real risk for degregation of our two most precious water resources.

C. Santos has no solution for disposing of the hundreds of thousands of tonnes of salt that will be produced. No permission should be granted until a full study of salt disposal is conducted and a plan mandated by Gov't.

Every time I learn of more CSG projects like this I cringe, for several years I have collected U.S. and Australian information of the terrible happenings that go with this horrible industry, Morewell Vic is one of many, Dalby Qld still burning underground it appears for years, the illnesses forced on people living nearby, George Bender a once successful farmer at Chinchilla whose 4 water bores that went motherless bone dry, the 15 month failed promise to deliver more water for his family's survival, a proud man brought to his knees it appears, his story on U Tube, A much earlier Santos report in the O'Farrell years of major contamination at a site let loose it appears, it was on public record back then, then we go to Tara and Casino gas fields once farmer friendly properties no more than scarred landscapes of barren land filled with cement pads fertile no more,discovered by two Drs from Southern Cross Uni' with spectrometers to measure for gas leaks, they were not disappointed it was extreme, again on Public record, Lets us think of those Gas Flares hot and pumping excess gas in the atmosphere polluting it, think of Climate change damage CSG and coal assisted wiping out any hope from the Paris conference now brought into International law. The lost farms and environments with wrecked aquifers, I think of the carcinogenic chemicals and radioactive it appear supplied to each well by the tons per application with enmasse water blasting that rock down below causing fissures and leaks it appears. I rest my case E&OE

Hi
Give up on this. While the Pilliga may be poor country with rubbishing scrub, gas fracking affects the water table. Where does this damage start and end? There is a lot of good country around this area, especially the Liverpool plains and surrounds, up and down the Namoi river and north of Narrabri. Water table damage is hard to predict and impossible to repair. I understand the need for energy, but there are better ways. It should not proceed in any area that relies on ground water.

On behalf of the Environmentally Concerned Citizens of Orange (ECCO) I would like to express our concerns about the serious environmental damage risks posed by the Narrabri gas project.
The project threatens habitat availabllity for state listed threatened species through vegetation clearance. If successful, the project will cause the destruction of 150 ha of habitat and will result in the fragmentation of 1700 ha of native vegetation, the result of which will be that of weed infestation.
Santos has no solution for the disposal of the 1700 to 4200 tonnes of salt waste produced each year.Unless removed from the area, this could have a devastating effect on district soil productivity.
In addition, the water removed for CSG extraction could have the effect of reducing the pressure in the recharge areas-potentially stopping the free flow of water to the surface of springs and bores across the whole Great Artesian Basin.
Methane flare stacks up to 50 metres high would be operating day and night, even on total fire ban days. The Pilliga is prone to severe bushfires . The project would increase ignition sources as well as extracting, transporting and storing a highly flammable gas right within this extremely fire prone environment.
Methane is by far the major component of natural gas. It is a greenhouse gas 72 times more powerful than carbon dioxide. CSG fields contribute to climate change through the leakage of methane during the production, transport processing and use of coal seam gas.. CSG adds to climate change risk when used in homes and factories, producing CO2 emissions.
ECCO wishes to ensure that the Pillaga scrub, a national icon, is safe from future inappropriate development which poses a threat to its ecology. We ask that theNarrabri Pilliga be declared as a mining-free area.
NIck King President, ECCO

To whom it may concern,
This submission has been written to draw attention to the unacceptable impacts of Santos current plan with light pollution from their upcoming 850 gaswells and flares near Siding Spring Observatory. It is a simple solution, as recommended by the NSW EPA to enclose all flares, not just for emissions and cleaner burning, but also to reduce the amount of unnecessary light pollution from giant flames lighting the night sky.
Siding Spring Observatory is AustraliaÂ's only unique science research facility using the largest optical telescopes for astrophysics and astronomy. First established in Coonabarabran NSW, on the Warrumbungle Ranges in the 1960Â's it was built here because of the dark skies in this region. While there is historic value of this site from telescopes established over 50 years ago, this observatory hosts the largest optical telescopes from national and international universities and research entities. Not only hosting the largest, this site hosts the second, third, fourth, fifth largest telescopes etc in Australia, playing a key role in science research across the Southern Hemisphere. Over 50 telescopes are listed across the site being used by over 30 universities, institutions and private businesses using cutting edge technology, with some of the most advanced telescopes being used is astrophysical research. Future plans include another 50 telescopes to be built on site within the next decade. All this is reliant on keeping the dark sky dark! If this area was to lose the dark sky, this observatory would not be replicated again in Australia, but moved elsewhere in the Southern Hemisphere.
From 2013 onwards light emissions from the Santos gasfield exploration have increased to the point that, just the Bibblewindi large flare and unmanned facility alone, creates more light pollution than the entire town of nearby Coonabarabran with over 3500 people residing there. Santos have listed plans to triple the amount of pilot flares and double the amount of large flares including constructing 50 metre high flare stacks, with an average 30 metre high flame above it. Nowhere do they list the EPAs recommended practice to enclose flares, as has been done in NSW areas such as Gloucester. Enclosing flares is the only acceptable mitigation to protect the scientific community from the unnecessary light pollution they plan to emit. Siding Spring Observatory already has to deal with light pollution from existing mining and regional towns. Even Sydney itself, from over 400kms away can affect research from its light glow. Santos are a lot closer than this. Every bit of extra light pollution is making it more difficult to continue the leading scientific research, and while each pollute in different levels, most consider they arenÂ't doing any damage. But itÂ's the combination with the existing light sources, adding a cumulative effect which is becoming worse as more pollution is created.
In summary, this is a simple fix in this case, as while Santos building infrastructure is willing to comply with shielded lights for buildings, they need to go a step further and enclose all current and future flares as the NSW EPA recommend. It is the only acceptable solution.

I strongly object to Narrabri Gas Project for the following reasons:1. The Narrabri Gas Project risks precious water sources, including the Great Australian Basin--Australia's largest groundwater aquifer

The Narrabri gasfield poses a real risk to our two most precious water resources: the Great Artesian Basin and the Murray-Darling Basin. The area of the Great Artesian Basin with the highest recharge rates is almost entirely contained within the Pilliga East forest. In a worst-case scenario, the water removed for CSG extraction could reduce water pressure in the recharge areas--potentially stopping the free flow of waters to the surface at springs and bores across the whole Great Artesian Basin.¹

Creeks in the Pilliga run into the Namoi River--a part of the Murray Darling Basin. This system is vulnerable to contamination from drilling fluid spills and the salty treated water produced from the proposed 850 wells.

2. The Gamilaraay Traditional Custodians are opposed

There are hundreds of cultural sites as well as songlines and stories connecting the Gamilaraay to the forest and to the groundwater beneath. Gamilaraay people are deeply involved in the battle against CSG, and have told Santos they do not want their country sacrificed for a coal seam gas field.

3. Farmers and other local community reject the project

Extensive community surveys have shown an average of 96% opposition to CSG. This stretches across a massive 3.2 million hectares of country surrounding the Pilliga forest, including 99 communities. Hundreds of farmers have participated in protest actions unlike any previously seen in the region.

4. The Narrabri Gas Project has a long history of spills and leaks of toxic CSG water--Santos cannot be trusted to manage the project safely

Santos has already contaminated a freshwater aquifer in the Pilliga with uranium at levels 20 times higher than safe drinking water guidelines, as well as lead, aluminium, arsenic and barium². In addition, there have been over 20 reported spills and leaks of toxic CSG water from storage ponds, pipes and well heads. Santos cannot be trusted.

5. The Pilliga is a haven for threatened wildlife

The Pilliga is one of 15 nationally listed 'biodiversity hotspots' and is vital to the survival of threatened species like the Koala, Spotted-tailed Quoll, Black-striped Wallaby, Eastern Pygmy-possum, Pilliga Mouse and South-eastern Long-eared Bat. The forest is home to over 200 bird species and is internationally recognised as an Important Bird Area². The Santos gasfield would fragment 95,000 hectares of the Pilliga with well pads, roads, and water and gas pipelines--damaging vital habitat and threatening the survival of endangered species.

6. Coal seam gas fuels dangerous climate change

Methane is by far the major component of natural gas, and is a greenhouse gas 72 times more powerful than CO². CSG fields contribute to climate change through the leakage of methane during the production, transport, processing and use of coal seam gas.

7. Human health is compromised by coal seam gas

A range of hydrocarbons and volatile organic compounds can be released into the air from coal seam gas operations, including flaring of gas wells. The effects of volatile organic compounds vary, but can cause eye, nose and airway irritation, headache, nausea, dizziness and loss of coordination⁴. These impacts have been documented in human populations nearby to existing gasfields in Queensland, Sydney and in America.

8. The nation's premier optical astronomical observatory is at risk

The Siding Springs Observatory, situated in the Warrumbungles and adjacent to the Pilliga, is under threat from the Narrabri Gas Project due to light and dust pollution⁵. The area has been internationally recognised as a 'dark sky park'⁶ and the 50m high gas flares proposed by Santos threaten the viability of the facility.

9. Thousands of tonnes of salt waste will result from the project

Santos has no solution for disposing of the hundreds of thousands of tonnes of salt that will be produced. Between 17,000 and 42,000 tonnes of salt waste would be produced each year. This industry would leave a toxic legacy in NSW.

10. Risk of fires would increase throughout the Pilliga's tinder-box conditions

Methane flare stacks up to 50m high would be running day and night, even on total fire ban days. The Pilliga is prone to severe bushfires. The project would increase ignition sources as well as extracting, transporting and storing a highly flammable gas right within this extremely fire-prone forest.



SoilFutures Consulting 2014, Great Artesian Basin Recharge Systems and Extent of Petroleum and Gas Leases. http://www.gabpg.org.au/wp-content/uploads/2014/11/GAB-Report1.pdf
http://www.smh.com.au/environment/santos-coal-seam-gas-project-contaminates-aquifer-20140307-34csb.html
BirdLife International (2017) Important Bird Areas factsheet: Pilliga http://www.birdlife.org
Marion Carey Doctors for the Environment Australia (DEA), Air pollution from coal seam gas may put public health at risk The Conversation, November 20, 2012
https://www.theguardian.com/science/2014/oct/21/siding-spring-observatory-threat-coal-seam-gas-light-pollution
http://darksky.org/first-dark-sky-park-in-australia-designated
References

Great Artesian Basin coal-seam gas 'risk', The Australian, 7 November 2014
'Not seen anything like it': Pleas for extension to examine huge Santos CSG plan, Sydney Morning Herald, 21 February 2017

We most strongly object to the proposal for Santos to carry out CSG mining in the Pilliga forest for the following reasons:
1. Santos has a proven record of polluting the environment.
They've poisoned an aquifer at Narrabri with uranium 20 times over safe levels, and there have been over 20 other reports of spills and leaks of toxic CSG water.
2. Santos' mining could permanently damage the Great Artesian Basin - the sole water source for farms and townships across 22% of rural Australia.
3 It will produce 100 tonnes of salt every day at peak production.
4. No new gas fields are necessary. Now, solar and battery storage can provide power cheaper than coal or gas.
5. There is a world glut of gas so it is economically foolish to mine for more.
6. CSG mining has been banned in Victoria and it is time NSW did the same. Australians overwhelmingly want renewable energy, not more coal and gas.
7. Preserving our environment and our water should take precedence over new mining projects.