Narrabri Gas

For years we have let the ignorance of our own kind, attempt to dominate nature through excavation, mining, polluting and mistreating.
This is an operation far greater then us- lives and homes are involved. I stand for the Earth and I stand for the animals who are directly effected in this uncouncious act of egoism.
If we won't consider them- let's consider us. The green house emissions it will emit, the loss of trees vital for our oxygen, the aesthetics of our bush, and the simple fact that we just. Don't. Need. It.
When did we all loose our humanity?

Submission: NARRABRI GAS FACILITY - CHAPTER 25 HAZARD AND RISK ASSESSMENT

Dear Sir/Madam
I object to the Narrabri Gas Project on the grounds that Santos has not properly assessed the major hazards and risks of the project, in that it has incorrectly applied the techniques of EPP33 and HIPAP 4, when the correct legislation it needs to comply with is Chapter 10 of the Work Health and Safety Regulation 2011 - Major Hazard Facilities.
EPP33 and HIPA4 are no longer the relevant legislative standards applicable to major gas/LNG processing plants in NSW. The correct legislation is the Work Health and Safety Act.
Leewood gas processing plant needs to be regulated as a licensed major hazard facility and undertake safety case assessment as required by the Work Health and Safety regulation 2011. Santos will be handling over 10% of a `Schedule 15' chemical i.e. methane. In addition, the gas processing equipment, wells, compressor stations will generate air toxics when need to be adequately safety-cased.
This legislation requires notification to WorkSafe NSW, licensing and production of a detailed safety case to ensure onsite and offsite risks to the public, workers, property and the environment are MINIMISED (as low as reasonably practicable).
The tests applied by the guidelines EPP33 and HIPAP4 are INADEQUATE to ensure safety and risk minimisation to the nearby suburbs of Narrabri. It is noted that a primary school, Narrabri West, is within a few kilometres of the active gas field and approximately 10 kilometres from the Leewood gas processing facility.
Santos has not adequately assessed, and as a consequence, not adequately mitigated the risks to the public, workers, plant and the environment of methane explosion, catastrophic toxic untreated produced water loss of containment, catastrophic air toxics cloud production and plant failure such as well blow outs, pipeline rupture, gas processing plant failure, compressor failure etc.
The Project should be rejected out of hand as inadequately assessed.
I note that even using the incorrect and out-dated legislative techniques, Santos has identified at least one `sensitive receptor' 350 metres from the boundary of Leewood at risk from `uncontrolled containment of gases'.
Further, Santos has identified a `moderate' level of bushfire risk with a potential to cause large bushfires. Again, this risk has been subjectively assessed and claimed mitigation measures are un-tested. Santos's own `risk assessment' may not be acceptable to the surrounding community and protected bushland areas.
There is no analysis whatsoever of lack of containment of air toxics from either catastrophic or normal operation of the gas processing plant at Leewood.
Santos has failed to adequately assess the safety of the untreated toxic coal seam gas produced water dams which are proposed to be re-built at Bibblewindi, nor of the risk of flood or loss of containment at the vast Leewood brine storage dams. Both of these areas risk contamination of the Namoi catchment area and the Narrabri town water source.
Unless an adequate safety case is approved by WorkSafe NSW in accordance with licensing requirements of the Major Hazard facility regulations, this project must be rejected out of hand and NOT approved.

Yours sincerely

Caroline Reid BSc (Hons1) USyd MSC(Saf.Sc) UNSW
8 Nott St Fraser ACT 2615

Please stop wrecking the environment to increase the use of outdated energy technology. Go 100% renewable. Your grandchildren will thank you for it.

I object to the Narrabri Gas Project.

Here are the reasons why:

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.

I have visited the Precious Pilliga for birdwatching many times over the years.
It is too precious to allow Santos to drill 850 wells. It is primary habitat for many species both flora and fauna and especially the avian fraternity.
Blow fossil fuels away.
Invest in renewable energy once and for all.
I would like to add how ashamed I am to call myself Australian at present. The governments are simply pawns for big global corporations and we the citizens have no rights at all. Democracy is dead.
Climate change is the biggest hurdle the globe has ever faced.
Block Santos at all costs.

There are so many reasons why I object to Narrabri Gas Project, these include the risks to the precious water sources, including the Great Australian Basin, the Pilliga is a haven for threatened wildlife and we should be protecting our endangered wildlife not contributing to its decline. The fact that the farmers and the local community are opposed as are the Gamilaraay who are the traditional custodians of the land, should be enough to put a halt to the project.

This project should not go ahead and the Australian government should not support it.

Santos' coal seam gas expansion risks contamination of aquifers and potential loss of water to farmers. There is also evidence of the salty brine damaging areas of forest in the Pilliga region from Santos' exploration wells.

I believe that Australia's underground water supply is too valuable to be put at risk by Santos' CSG expansion and that it should not go ahead. It is not in the national interest.

I am writing to oppose the mining of the Santos' Narrabri Gas Project in the Pilliga. Santos has mapped a total of seven huge gasfields across this region--and once the CSG industry gains a foothold, it's very difficult to stop.


This project has the very high possibility of risking our Great Artesian Basin, once this basin is damaged or poisoned it will have catastrophic impact on vulnerable species and forests in eastern Australia. We cannot risk our natural resources once damaged or destroyed they are gone forever.

I object to this for my self, my children and grandchildren. Stop this project now put the future of our ecosystem before big profit.

Dear Sir, Gas drilling would be far too risky in the Pilliga region,
as the probability of contamination of the Artesian basin is very real. This would cause devastation for the huge farming community in this area.

Please do not allow this operation to continue !

As a scientist I find it astounding that the government would even consider allowing Coal Seam Gas to be developed in the Pilliga region. The evidence of the damage caused by this method of natural resource extraction is so overwhelming there really should be no grounds for discussion. As a voter and proud Australian it breaks my heart that we continue to promote fossil fuels while the Great Barrier Reef dies from warming. Please show some consideration for the generations to come and halt this madness.

Coal seam gas pollutes waterways and harms animals in the process, we have seen this in Queensland already. The Great Artesian Basin is an important underground water source that if damaged, could spell disaster for eastern Australia. Please have the sense to deny these big corporations free access to destroy our water sources. Isn't Adani destroying the reef a big enough example not to allow this to happen, not to mention Australia sees no monetary value from these gas exports! Stand up like Victoria and say no!

My submission is very simple but extremely heart felt. I am it qualified to banter the economics of this project. I object to this project because I am thoroughly convinced that we (man) should not be doing or even considering an activity that contaminates or even jeopardises natural water sources.

I have a saying that I live by

" just because you can doesn't mean that you should"

I believe that when interacting with mother nature, we have to ask that question.

I strongly oppose the Narrabri Gas Project in the Pilliga.

To whom it may concern.
I feel this Gas project will not benefit the community in any way, just a short term financial gain to those directly involved. We all know that the agricultural industry and the gas industry do not mix well. The gas industry will pollute local water sources that the farmers and citizens need for food production and general drinking. The gas industry will use and abuse the area until it is not profitable to operate anymore, then pack up shop and leave the locals to clean up there mess. The long term environmental damage to the pilliga region far outweighs the short term financial gains that gas industry will bring.
Regards Glenn Smith.

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.

I am writing to object to the The Narrabri Gas Project which involves the progressive development of a coal seam gas field comprising up to 850 gas wells on up to 425 well pads over 20 years, and the construction and operation of gas processing and water treatment facilities, including:
- a central gas processing facility for the compression, dehydration and treatment of gas;
- a water management facility for the storage and treatment of produced water;
- an in-field gas compression and water management facility; and
- water and gas gathering pipelines and ancillary infrastructure.
The time has long past for humans to start taking better care of our planet, digging it up and adding further greenhouse gasses to an already overheated atmosphere is a kind of madness and wanton destruction of the only planet we will ever have to support human life. There is ample evidence around the world showing the damage to aquifers and land caused by coal seam gas mining and ample evidence to show that our planet is warming to a dangerous degree - witness the recent extensive bleaching of our Great Barrier Reef. As well as adding to the very critical problem of atmospheric warming when the gas is used there is so much risk to the water of the great Great Artesian Basin, our threatened species and our largest inland forest in eastern Australia. There are clean safe alternatives available to supply Australia with energy, we just need to put the energy and investment into a sustainable future for the sake of all of humanity and especially future generations.

The Planning Department.
I do not agree with SantosÂ' massive Narrabri Gas Project in the Pilliga, risking our Great Artesian Basin, our threatened species and our largest inland forest in eastern Australia
The CSG industry is very dangerous to the environment and our water resources.

With kind regards.

The Mullum Trust is a philanthropic foundation that supports projects aiming to improve the health of the Australian environment.

We are extremely concerned at the risks that are posed by the proposed Narrabri Gas Project in the Piliga. There are a number of areas of concern:

* The impact of the gas mining on the Great Artesian Basin, through the leakage of dangerous chemicals into this critical source of water for the agriculture that supports the population of eastern Australia, as well as a significant export market. Hydrological experts have informed us that knowledge about the behaviour of ground water is still very limited, and there are many questions that could have catastrophic consequences if not fully answered. The science MUST be further developed before we can have confidence that the impacts will be manageable. And that science MUST be independent of commercial interests in exploiting the resource.

* The impact of diverting water resources from the local wetlands and farming communities that rely on them.

* The impact of fugitive emissions from the CSG mining process on our climate. It is of vital importance that Australia meets its Paris targets, and that the world's temperature increase remains below 2 degrees celsius. The methane and other gases that routinely escape from unconventional gas mining are far more damaging than CO2, and independent monitoring has not shown that they can be avoided.

These risks are very significant: the financial, social and environmental cost of making the wrong bet could be unimaginably massive. The responsibility of government to protect our community and our environment demands much greater scientific understanding of these impacts than is currently available. Until we have that, the prudential principle requires a halt to this development.

Our government is voted in by the people. It works for the people. Ignoring us is completely in opposition to the fundamental responsibilities of government.
To serve its people.

The Pilliga forest is a unique ecological refuge, home to 25 nationally listed and 48 state-listed threatened species, such as the Pilliga Mouse, which rely on the Pilliga for survival. Their habitats will be destroyed by Santos' drilling for CSG through the Great Artesian Basin in the Pilliga. This will threaten the groundwater on which farmers depend throughout SE and inland Australia. The Great Artesian Basin is replenished in the Pilliga.
We need to conserve the Pilliga forest which is the largest intact woodland in eastern Australia. We need to protect the Great Artesian Basin.
I am opposed to any drilling for CSG in the Pilliga forest for the reasons outlined above.