Narrabri Gas

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.

To Whom it May Concern,
The issue of CSG should be of great concern to every Australian. I have read that the government has established this process to hear from the public.I would like to think that in our democracy,the public would be heard and actually listened to.
I am seriously concerned about CSG operations in any area but understand the grave concerns that the people in the Pilliga region have,particularly in regard to the Great Artesian Basin.My father,who died 2 years ago at the age of eighty,was able to explain to me his same concerns. Having had a background in farming I have no doubt that he was correct in saying that such damage would be irreparable. The studies are there, the examples of devastation are ongoing in this country and others.People's health,lives and livelihoods are in serious danger and it needs to stop. CSG is not worth the many risks it poses.
Our government(s) are supposedly concerned about mental health issues,suicide rates, indigenous issues, environmental protection-the list goes on! End the hypocrisy,listen to Australians and allow us to preserve this amazing country

NSW Dept. of Planning & Environment.
Sir / Madam---I am submitting that the NSW Gov't. MUST NOT support nor approve the 'Coal Seam Gas' (aka, Fracking)mining proposal for the Pilliga Scrub (nor ANY other area of NSW). Available evidence (worldwide) & common sense show such activities to be detrimental to the environment (which we all have to exist within) & the water table, both of which are critical to Australia, both as a Farming nationality & a NICE place to live. I have used various parts of the Pilliga, purely socially & don't want to see the landscape made barren, inhospitable, the water table destabilised, nor otherwise made much more user unfriendly than the area is already. This is a harsh part of our Country & does not want to be made any more unstable with the uncontrolled emission of toxic gasses or chemicals that WILL result from this form of mining. Such evidence is available from other parts of the world where this process has been used & we (Australians) don't need to follow suit here.---Please use your power here, 1), to support the local population & 2), to support the environment---(there is no 'going back' to fix the already known problems of Fracking), & 3), take note of the PEOPLE of Australia & what they want, need & demand, NO FRACKING.

1. The Narrabri Gas Project threatens the Great Artesian Basin. This is not exaggeration, in other parts of the world, drilling and fracking for gas have contaminated aquifers. There is evidence to suggest this has occurred in Queensland around Chinchilla.
The footprint for this development is the southern recharge area of the GAB. We should be making sure nothing happens to it.

The suggestion by those promoting this that the drill holes will be sealed is a joke. Concrete fails eventually. Sooner or later all the drill holes will leak and lead to cross-contamination of aquifers.

2. The process will lead to Gigalitres of highly contaminated water being brought above ground and the holding ponds for this are also prone to leakage. The contaminants are radioactive salt compounds, that, when they end up downstream in the Murray Darling Basin as they will do in a flood have the potential to contaminate the above ground water sources as well.

3. The water usage for this project is not being calculated. Santos are basically allowed to take all the water they need when farmers and others have to abide by strict limits as it is already recognised that the GAB is not a limitless supply.

4. This process has significant fugitive methane emissions. The baseline data of background methane has not been established and again, evidence from Queensland show that these emissions are significant. Methane is a much more potent greenhouse gas than carbon-dioxide. Gas is not a transition fuel if its productive leads to massive methane releases into the atmosphere. There is no record being kept of fugitive methane emissions. Furthermore these emissions are not counted as part of Santos' extraction. So they don't pay royalties on them and have no incentive to minimise waste.

5. This project is strongly objected to by the traditional owners.

6. Turning the Pilliga into an industrial gasfield, with roads and pipelines everywhere will destroy this 'million wild acres'. There are numerous endangered species, including the koala, that call the Pilliga home. Some like the Pilliga Mouse are endemic to the area. The carving up of the area, combined with increased fragmentation, traffic, contamination, increased risk of bushfires will make like impossible for these species and they will be pushed closer to extinction.

7. Siding Springs Observatory scientists have publicly stated that having hundreds of flaring gas wells will make it harder for their telescopes to operate. They depend on the lack of light.

8. There have already been dozens of leaks, spills and contamination events. More gas wells, means more such events.

9. Lots of gas flares in the middle of a forest already subject to serious bushfire threats in summer is madness. The bushfire risk will seriously increase.

So many more reasons, including that most of the population don't want CSG, don't want fracking and think SANTOS should just frack off!

I am against all mining in the Pilliga for gas. I have spent a considerable amount of time in the Pilliga enjoying nature, it is the home for many birds and animals. The habitat for animals and birds is more important than fracking for gas. Fracking also has a detrimental affect on the water. Santos has already polluted the area on previous occasions.
Australia is the driest continent, fracking has proven to be detrimental to groundwater, therefore expansion of mining should not be allowed.
All too many times these mining companies make promises to protect the environment, then when they are given approval, these promises fall by the wayside.
Added to this is that the area will very quickly become an eyesore.

Santos' plans for Coal Seam Gas wells in the Great Artesian Basin adds to the environmental insult of a possible Adani mine.

Is the Government prepared to trade a few short-term jobs for a level of environmental pillage unprecedented in Australia's mining history? Surely not!

Santos' Coal Seam Gas exports from Queensland have traded inflated gas prices and unstable supply, for extensive environmental and social damage.

Now Santos plans to perpetrate further environmental, social and economic rape in NSW. The NSW Government has an opportunity to deny Santos that crime, and invest in more reliable and ultimately cheaper renewable energy.

Coal Seam Gas extraction has been irrefutably proven to be harmful to our health and to our environment.

The NSW Government has extensive community support to deny Santos' plans. If it chooses to support Santos it will see it's own support diminish significantly.

I Object to the Narrabri Gas Project, because of ALL of the following reasons:

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 barium. 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 Area. 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 coordination. 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 pollution. The area has been internationally recognised as a `dark sky park' 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.

Please do not allow CSG extraction in the Pilliga. Australia already suffers from extended periods of extreme droughts, so to risk any damage to water supply is totally irresponsible. The risk to farming and our future food supply is far too great.

Please protect the Pilliga forest by rejecting outright the Santos CSG proposal in NSW.

I was born in NSW I am a long-term NSW resident. I do not want CSG in NSW, or anywhere in Australia.

Surely you must know by now the devastating effects that the extraction of coal seam gas has on every aspect of the environment.

Drilling and "tracking" can only result in degradation of soil and water. Any economic advantage gained (only for corporations and their shareholders!) comes at a cost to our farmers and overall well-being. The misuse of valuable water supplies and ensuing pollution of water in rivers and in the Artesian basin can never be reversed.

Quite simply, we can't eat coal and we can't drink gas. Why would right-thinking ever Australians support the destrucion of our farming lands and our environment?

Santos is interested in only one thing money/greed. It has no regard for our lands, as has already been demonstrated.

Tell Santos "no!" And send them on their way. Do not risk our farms and farmers. Do not put at risk our precious water supplies!

Rod Miller

Objection to Santos' Narrabri Gas Project in the Pilliga.

Dear Sir,
I wish to object to the proposed Santos Narrabri Gas Project for the following reasons.

1. Locals do not want this Project, as recent surveys have suggested. Nor do most Australians.
2. This Project is controversial in that it involves local aboriginal cultural sites, which have not been addressed yet.
3. The Narrabri Gas Project risks precious water sources, including the Great Australian Basin. Cross contamination of various levels of aquafers is common in America with this type of drilling.
4. As the creeks of the Pilliga run into our major river systems, these rivers will be contaminated with tons of salty water and other contaminates.
5. Health risks from gas emissions, toxic fumes, poisonous water discharges and fires, the result of which may take decades to realise. Methane is far more dangerous to globing warming than CO2 gas.
6. Santos has a very poor track record in keeping the environment clean. There is no guarantee that they will improve. They have already been seen to discharge salty water that has killed trees and made the soil unusable.
7. The famous Siding Springs Observatory is sited in this area, and its potential will be diminished with dust and light pollution from this Project.
8. Wildlife will be disturbed and displaced in this Project, and some species may disappear altogether.
9. We need to keep resources in the ground for future generations. Australia has more gas that it requires, in fact it is the largest exporter of gas in the world. The trouble is that we don't keep it for ourselves, we export it. This is not a valid point for production.

Faithfully Yours,
John Dyer

This is the water for the future.
Our underground water stores need to be protected.
I spent my youth in Narrabri.
It is crazy that we allow this kind of CSG drilling anywhere.
It's effects are so unpredictable and unknown.
No to CSG !

No to CSG

I object to the development of CSG in the Pilliga and in places where CSG extraction poses any risk to agriculture and the water sources on which agriculture depends.
Food prices are already strained, and any developments that are likely to reduce supply - amid increasing demand - should be avoided.
CSG industries will provide only short term income while posing long term threats to a proven source of income in the form of agriculture. Growing global food demand and increasingly open markets mean any reduction in food supply - e.g. as a result of CSG temporarily or permanently reducing the quality and quantity of available ground and surface water - will increase the cost of living while reducing GSP over the medium and long term.
I strongly object on these grounds.

SECRETARY PLANNING & ENVIRONMENT NSW
Level 22, 320 Pitt St, Sydney 2000
GPO Box 39, Sydney NSW 2001
RE- NARRABRI GAS PROJECT SUBMISSION
Dear Sir, there are koalas in the Project Area but Santos EIS failed to identify them (see attached report). Chapter 15 Terrestrial Ecology Impact assessment is totally inadequate. Santos's flora and fauna surveys were inadequate. Koalas are a threatened species. I object to this Project on the grounds that terrestrial ecological impacts have not been adequately assessed and mitigated.
Following a review of Chapter 15 of the Narrabri Gas Project (NGP) Environmental Impact Statement (EIS), a number of serious omissions within the assessment are evident, and several questions regarding the adequacy of the assessment remain unresolved, in particular:
* The adequacy of the methodology used to describe direct impacts is questionable. The lack of a development footprint by which impact could be measured according to `whole of government' guidelines gives uncertainty to the outcomes.
* Levels of indirect impact haven significantly under-estimated. Using fox predation as a measure, pre-mitigation levels of indirect impact should be at least doubled in magnitude, based on available evidence.
* Survey effort for some key fauna species appears to be deficient and would have adversely affected the ability of the EIS to adequately account some species.
* A NSW and Commonwealth-listed threatened ecological community White Box Blakely's Red Gum-Yellow Box Woodland (and derived native grassland) has been mis-identified and presumed to be not present in the study area. New data confirms its presence along Bohena Creek.
* The description of important habitat for a number of key fauna, such as the Regent Honeyeater, Pilliga Mouse, Koala, Black-striped Wallaby and Five-clawed Worm-skink does not appear to be accurate.
* New information regarding the presence of the Koala in the study area discounts the assertion made in the EIS that it is not currently present.
* Due to deficiencies in the in the survey and assessment for two `matters for further consideration' (Regent Honeyeater and Five-clawed Worm-skink) statutory requirements under the NSW Biodiversity Offset Policy have not been met.
* Direct impacts upon Brigalow Park State Conservation Area remains uncertain as do the magnitude of indirect impacts upon the adjacent Nature Reserve and existing corridors.
* A Biodiversity Offset Strategy does not provide any surety for how well it will `retire' the impact of the Project because the strategy provided in the EIS does not provide any like-or-like land-based offsets apart from an unproven rehabilitation plan and rests on the hypothetical efficacy of a feral animal control proposal. The suitability of the offset package with respect to the statutory requirements under the NSW Biodiversity Offset Policy is poor.
Based on these findings, the Secretary for the Environment should reject this part of the overall Project assessment as being data-deficient and inadequate under the terms of NSW Biodiversity Offset Policy or request the matters outlined above be addressed by the proponent.
Please do NOT approve this Project:
Yours sincerely
Diana Edwards
14 April 2017

SECRETARY PLANNING & ENVIRONMENT NSW
Level 22, 320 Pitt St, Sydney 2000
GPO Box 39, Sydney NSW 2001

RE- NARRABRI GAS PROJECT SUBMISSION

Dear Sir, there are koalas in the Project Area but Santos EIS failed to identify them (see attached report). Chapter 15 Terrestrial Ecology Impact assessment is totally inadequate. Santos's flora and fauna surveys were inadequate. Koalas are a threatened species. I object to this Project on the grounds that terrestrial ecological impacts have not been adequately assessed and mitigated.

Following a review of Chapter 15 of the Narrabri Gas Project (NGP) Environmental Impact Statement (EIS), a number of serious omissions within the assessment are evident, and several questions regarding the adequacy of the assessment remain unresolved, in particular:
* The adequacy of the methodology used to describe direct impacts is questionable. The lack of a development footprint by which impact could be measured according to `whole of government' guidelines gives uncertainty to the outcomes.
* Levels of indirect impact haven significantly under-estimated. Using fox predation as a measure, pre-mitigation levels of indirect impact should be at least doubled in magnitude, based on available evidence.
* Survey effort for some key fauna species appears to be deficient and would have adversely affected the ability of the EIS to adequately account some species.
* A NSW and Commonwealth-listed threatened ecological community White Box Blakely's Red Gum-Yellow Box Woodland (and derived native grassland) has been mis-identified and presumed to be not present in the study area. New data confirms its presence along Bohena Creek.
* The description of important habitat for a number of key fauna, such as the Regent Honeyeater, Pilliga Mouse, Koala, Black-striped Wallaby and Five-clawed Worm-skink does not appear to be accurate.
* New information regarding the presence of the Koala in the study area discounts the assertion made in the EIS that it is not currently present.
* Due to deficiencies in the in the survey and assessment for two `matters for further consideration' (Regent Honeyeater and Five-clawed Worm-skink) statutory requirements under the NSW Biodiversity Offset Policy have not been met.
* Direct impacts upon Brigalow Park State Conservation Area remains uncertain as do the magnitude of indirect impacts upon the adjacent Nature Reserve and existing corridors.
* A Biodiversity Offset Strategy does not provide any surety for how well it will `retire' the impact of the Project because the strategy provided in the EIS does not provide any like-or-like land-based offsets apart from an unproven rehabilitation plan and rests on the hypothetical efficacy of a feral animal control proposal. The suitability of the offset package with respect to the statutory requirements under the NSW Biodiversity Offset Policy is poor.
Based on these findings, the Secretary for the Environment should reject this part of the overall Project assessment as being data-deficient and inadequate under the terms of NSW Biodiversity Offset Policy or request the matters outlined above be addressed by the proponent.

Please do NOT approve this Project:

Yours sincerely Pamela Doyle

Better to take heed of the lessons learnt from Bentley and not even consider activity which threatens water supplies and precious wilderness, than to spend stupid amounts of money for nothing more than a very large headache.

Supported.

RE- NARRABRI GAS PROJECT SUBMISSION

Dear Sir, there are koalas in the Project Area but Santos EIS failed to identify them (see attached report). Chapter 15 Terrestrial Ecology Impact assessment is totally inadequate. Santos's flora and fauna surveys were inadequate. Koalas are a threatened species. I object to this Project on the grounds that terrestrial ecological impacts have not been adequately assessed and mitigated.

Following a review of Chapter 15 of the Narrabri Gas Project (NGP) Environmental Impact Statement (EIS), a number of serious omissions within the assessment are evident, and several questions regarding the adequacy of the assessment remain unresolved, in particular:
* The adequacy of the methodology used to describe direct impacts is questionable. The lack of a development footprint by which impact could be measured according to `whole of government' guidelines gives uncertainty to the outcomes.
* Levels of indirect impact haven significantly under-estimated. Using fox predation as a measure, pre-mitigation levels of indirect impact should be at least doubled in magnitude, based on available evidence.
* Survey effort for some key fauna species appears to be deficient and would have adversely affected the ability of the EIS to adequately account some species.
* A NSW and Commonwealth-listed threatened ecological community White Box Blakely's Red Gum-Yellow Box Woodland (and derived native grassland) has been mis-identified and presumed to be not present in the study area. New data confirms its presence along Bohena Creek.
* The description of important habitat for a number of key fauna, such as the Regent Honeyeater, Pilliga Mouse, Koala, Black-striped Wallaby and Five-clawed Worm-skink does not appear to be accurate.
* New information regarding the presence of the Koala in the study area discounts the assertion made in the EIS that it is not currently present.
* Due to deficiencies in the in the survey and assessment for two `matters for further consideration' (Regent Honeyeater and Five-clawed Worm-skink) statutory requirements under the NSW Biodiversity Offset Policy have not been met.
* Direct impacts upon Brigalow Park State Conservation Area remains uncertain as do the magnitude of indirect impacts upon the adjacent Nature Reserve and existing corridors.
* A Biodiversity Offset Strategy does not provide any surety for how well it will `retire' the impact of the Project because the strategy provided in the EIS does not provide any like-or-like land-based offsets apart from an unproven rehabilitation plan and rests on the hypothetical efficacy of a feral animal control proposal. The suitability of the offset package with respect to the statutory requirements under the NSW Biodiversity Offset Policy is poor.
Based on these findings, the Secretary for the Environment should reject this part of the overall Project assessment as being data-deficient and inadequate under the terms of NSW Biodiversity Offset Policy or request the matters outlined above be addressed by the proponent.

Please do NOT approve this Project:

Yours sincerely

Get out of destructive gas and coal and into the future with renewables. Give the world a chance, after all it is where we live!