Narrabri Gas

Regarding the Narrabri Gas Project I wish to put in a strong objection, on behalf of my children and grandchildren, to this ill-considered and potentially disastrous endeavour.
It will cause serious pollution to an area with extraordinary natural values - amongst others: the local groundwater and the great artesian basin; the Pilliga forrest; the gamillaraay people;
local agriculture; public health and most importantly, contribute seriously to climate change at a time that humanity's focus should be on renewable sources of energy. I emplore you: "Please put a halt to this project."

save australia

I object to any fracking taking place within Australia, especially on or near the Great Artesian basin.

I oppose a Coal Seam Gas development in the Pilliga forest of NSW.
The more I learn about the environmental risks of such a project and the unknown long term effect on human health, the more concerned I become.
However, the thing that concerns me the most is that the project is still being considered despite a 96% average of community opposition.
The region has never seen protests as it has from hundreds of farmers around the current issue. Additionally, the Gamilaraay people, whose song-lines, stories and cultural sites will be directly effected by the development are deeply involved in the fight to preserve the cultural, environmental and community significance of the Pilliga.

I am grateful to at least have this official opportunity to have my say and add weight to the voices who have spearheaded the campaign against the project for years. I am hoping that the opportunity isn't just for show - that the voices of individuals behind these submissions, who rely on the government to represent and take action for them accordingly, will be taken into account sincerely.

The significance of this goes beyond this one development, whose scale and impact alone is likely to inflict irreversible consequences. Opening the door to CSG companies such as SANTOS, (who have a history of water contamination with heavy metals and toxic CSG water), opens the door to more projects in the future. This is the last remaining CSG project proposed in NSW. We have an opportunity here to say NO and make a better, bolder, wiser decision for the future of NSW, for Australia and ultimately the world.

The Pilliga forest, asides from being beautiful, contains the Great Artesian Basin, which provides the only source of fresh water through much of inland Australia.
It is also a biodiversity hotspot, which means it is vital to the survival of many threatened species and is internationally recognized as an important bird area.

Allowing a CSG development into the Pilliga means risking contamination of the water supply that communities depend upon. It means fragmenting 95,000 hectares of a vital Eco-system with 850 gas wells, with water and gas pipelines and roads. It means increasing the risk of fire in a fire prone forest and feeding more methane to the climate crisis we are currently facing.

It is important to me that the government doesn't sacrifice the Pilliga for a Coal Seam Gas field. It is important to me because Australia, the land, its inhabitants both human and animal are important to me. We are responsible for the earth, the climate, the water and the energy infrastructure that generations after us will be in living in and effected by.
I don't think enough is being done to protect what is ultimately important. The road towards sustainability is a long term series of stepping stones, and denying SANTOS access to the Pilliga could be one of them. Every choice towards a sustainable future will make it easier for those after us to follow suit.
FIRST, DO NO HARM.

I have tertiary qualifications in Community Development and an agricultural background in NSW. I have traveled to, and witnessed the devastating consequences of this dishonest industry in other parts of Australia and North America. I reject any notion that the Narrabri Gas Project is necessary, safe, or important in anyway. I firmly believe, from personal and professional experience, that renewable energy makes this project utterly redundant. The 21st century has no place for the toxic fossil fuel industries, of which this project is one part. Any persisting market for methane gas is easily satisfied, as it's always been, by offshore conventional gas mining. Anyone with any time for researching the onshore unconventional gas mining industry knows this project is too risky, too expensive, too disruptive, and too invasive on local communities. The people, animals, plants, and environments of the Pilliga are too important to risk, with such a fickle and greedy project like this. The ancient cultures of this land have warned us about this dangerous project proposal. Please consider our future generations above today's profits, and reject the Narrabri Gas Project immediately.

Regards,
Daniel Peterson JP
2/139 Dawson St. Lismore NSW 2480

I am in favour of the Narrabri Gas Project going ahead.
I believe that this project going ahead will have a significant impact on the local economy and will provide the Narrabri shire and NSW with a much needed gas supply. In NSW we know more than one million homes 33000 businesses and approx. 300000 jobs rely on an affordable supply of Natural gas. If approved the NGP can supply up to half of NSW's gas needs. it makes sense that project is approved.
The project will deliver significant economic benefits including 1300 jobs during construction and 200 ongoing jobs.
Being an employee in the industry I want to see this project proceed to fruition as it is my livelihood and supports my small growing family. The industry supports local community programs and funds many small non for profit organisations. It creates careers for locals and provides locals with careers that wouldn't exist without the industry and the project.
The project is proven to have a small environmental footprint and will continue to do so. YES TO GAS and YES to the Narrabri Gas Project.

OBJECTION ON THE BASIS OF INADEQUATE BRINE DISPOSAL AND REVERSE OSMOSIS CONCENTRATE DISPOSAL ASSESSMENT AND MITGATION MEASURES

Brine management is a major bottleneck for coal seam gas (CSG) production in Australia . Solid Waste remains, even after 10-15 years of CSG extraction in Queensland, a significant logistics and disposal issue for desalination solid waste and chemical processes .
Coal seam gas brine and reverse osmosis concentrate are highly contaminated materials - they are not suitable for general waste disposal and must be handled as hazardous controlled waste in a licensed waste facility capable of handling the toxicity of the material. There is no current facility available in NSW and unlikely to be one that can handle up to 110 tonnes of brine waste PER DAY.
Both these waste streams will contain toxic heavy metals, ordinary salt, other salts, radioactive solids and hydrocarbon residues.
There is currently no treatment-disposal mechanism in place in Australia for the concentrated (solid salt-waste) produced after the reverse osmosis of CSG brine . This fact will create a legacy issue that the industry will, in all likelihood, pass on to the New South Wales taxpayer .
The Narrabri Gas Project should not be approved based on this issue alone.

re: Figure 1- Treated Water Management Options - Santos Narrabri Gas Project EIS

According to the Narrabri Gas Project EIS disposal could involve an estimated 110 tonnes PER DAY of toxic brine being sent to a registered contaminated waste dump/third-party landfill and/or 2 tonnes toxic of brine PER DAY being discharged into Bohena Creek.

The EIS states that the concentrated solid waste from the NGP Reverse Osmosis plant will be disposed of at a "Licenced Facility". There is none in NSW.

Even using a licenced facility does not make the waste disposal issue miraculously disappear. Santos simply hands the problem on to someone else- the taxpayer.

The eventual fate and impact of this reverse osmosis brine concentrate in the environment is not scientifically dealt with in the EIS.

The ultimate fate of CSG solid salt/waste in landfill is correctly described by Qld farmers as a "recipe for disaster" .

There has been a dramatic increase in waste residues in Qld as a result of the CSG industry.

Deliberate miscoding of the solid waste stream as general waste, rather than hazardous waste, is an identified issue in Queensland; this illegal miscoding masks a serious issue regarding the tracking and ultimate fate of CSG industry waste.
To comply with NSW laws, Santos is likely to have to truck waste over the NSW border, assuming they can find a suitably licensed facility that can handle that quantity of waste.


The option of creek-flushing to dilute produced water into the environment (using Bohena Creek as an industrial drain) is purely a corporate cost-cutting measure; the objective of which is to maintain gas supply and avoid creating (and paying for) the storage and alternative disposal of the toxic reverse osmosis salt concentrate.

The following except from the 2016 Blyth Creek (Qld) EA Amendment Application clearly states maintaining gas supply (economic), not environmental protection, is the primary objective of creek-dumping:
"The greatest risk to gas supply objectives are during very wet periods (e.g. 3-4 months when soils remain saturated following multiple rainfall events) is when no produced water can be utilised for irrigation. No amount of irrigation area can manage this risk. Critically, GLNG seeks the additional authorisation for the event-based release of produced water to Blyth Creek during flow events, as a sustainable water management option for produced water during wet weather and as waste avoidance and minimisation strategy that does not result in the generation of waste brine and solid salt."

There are a significant number of issues involved in stream-dumping of CSG waste and resultant bio-toxicity. For example, organic compounds and radionuclides Uranium 238, Radon 226, Radon 228 and Potassium 40 were detected in the raw CSG water and in the reverse osmosis brine in Qld. The Healthy Headwaters Hazard Characterisation (2012) stated that there are currently limited guideline values against which to assess the biological relevance of the radionuclides detected.

Given the variability of waste constituents across all wells within a gas fields and over the lifetime of a gas field; creek dumping of waste will require careful and costly monitoring. Given the economic constraints that are affecting the industry; ongoing allegations of environmental "cover-ups"; CSG companies choosing to pay fines rather than undertake costly remediation; it is questionable as to whether these necessary acts will be undertaken in a rigorous manner over the coming years .

This project should therefore be rejected out of hand as proposed mitigation measures will fail, as they have done in QLD.
Yours sincerely
Caroline Reid
3/5/17

My opinion is that the gas project will be of great benefit to the local & regional economy, while at the same time supplying a much needed energy source for the state & nation.

Santos has demonstrated the it's ability to conduct operations to a high standard of compliance, across the many & varied requirements placed on the development.

I object to the proposed Gas field because the use of water and the operation will harm the environment.

I object strongly to the Narrabri Gas project. Regulations are no protection against the harms that will occur.
Methane and volatile organic compounds will be emitted to the atmosphere at several stages of the process, eg during flaring, venting, leaks etc. Methane is a more potent greenhouse gas than carbon dioxide. Volatile organic compounds are harmful to health.
People living around gasfields suffer nosebleeds, rashes, headaches in the short term, and long term effects are yet to be seen.
Aquifers have been contaminated in Australia already by the gas industry. Leaks and spills of drilling materials have damaged ecosystems. This is unacceptable risk.
I oppose the industrialisation of farmland and forests. I oppose the negative effects on farmers lives, and on their products. I don't want produce that comes from gasfield regions.
China is importing milk from Tasmania because it has the cleanest air in the world. It is a very valuable commodity, fetching $15 a litre in China. Food security is important for our future, and so easy to achieve in Australia, unless we industrialise our currently clean farmland.
We must protect our water also, for now and for the future.

The Narrabri Gas Project 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.
This will only expand once started.
Gas is not the fuel to be developing. Renewables are a better option. Gas should stay in the ground. Depressurising coal seams leads to leakage of gas, which takes the easiest path, through cracks and faults to the surface, not only going up the gas well.

Human beings are 75% water. The very people who take place in this madness are literally killing there own bodies. Clean water is essential for our children and for many generations to come. I OBJECT

Please don't let this happen. Once the damage is done you will never undo it.
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.

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.

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.

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.

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.

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.

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.

As the largest remaining semi arid woodland in NSW the Pilliga should be protected from coal seam gas exploration, wells and processing facilities.

The environmental degradation proposed is unacceptable.

Coal seam gas does not have a good environmental record.
This is folly.

I support the Narrabri Gas Project.
The location of the project in the Pilliga is the best option for gas development in NSW at this time, and Santos is a company with the resources, reputation and capability to ensure the project meets the highest standards and conditions imposed by govt.
The expansive CSG industry in Qld developed by Santos and others is evidence that the industry can favourably co-exist with agriculture and the environment.
To delay or reject gas project will negative impacts on the long term energy requirements of NSW.

As an environmental chemist I am opposed to Santos' plans for the north west of NSW, especially the Pilliga Forest & surrounding farms.
The risks to some of the best farming land in the state cannot be ignored. Then there is the risk to the Great Artesian Basin recharge.
There are also a significant risks for the National Party in NSW if Santos is allowed to proceed.
I refer you to articles in the Sydney Morning Herald. Sean Nicholls' article titled"Aquifer poisoned" mentioned how Santos was fined $1500 by the NSWEPA. Frankly Santos can not be trusted.
I have also published a major study on the Coxs River and the many sources of contamination feeding into this river. Water is a major resource for our country. Pollution to our waters, as well as degradation of forest and tree areas are both significant issues.
The fracking methods together with the chance of fractures to pipes that run through underground water sources is a very significant risk - only one mistake could be one mistake too many.
The use of water for fracking is also considerable and too much for the water table level for many farmers' bores and no one knows the impact on reducing the Great Artesian Basin. It is considered by scientists as a significant asset not to be risked. Would you condone such a major risk to one of Australia's biggest assets?
The secretiveness of Santos' current explorations, etc. is a major concern.
Yours faithfully
Mr Chris Owens FRACI CChem
Santos was fined $1500 by the NSWEPA. Frankly Santos can not be trusted.
I have also published a major study on the Coxs River and the many sources of contamination feeding into this river. Water is a major resource for our country. Pollution to our waters, as well as degradation of forest and tree areas are both significant issues.
The fracking methods together with the chance of fractures to pipes through underground water sources is a very significant risk - only one mistake could be one mistake too many.
The use of water for fracking is also considerable and too much for the water table level for many farmers' bores and no one knows the impact on reducing the Great Artesian Basin. It is considered by scientists as a significant asset not to be risked. Would you condone such a major risk to one of Australia's biggest assets?
The secretiveness of Santos' current explorations, etc. is a major concern.
Yours faithfully
Mr Chris Owens FRACI CChem

I am totally against doing any more harm to our precious environment. There are alternative and more environmentally friendly ways to generate power.

I OBJECT TO THIS PROJECT because:

The lack of detail: Santos' EIS is very short on detail. It does not provide maps indicating
where these 850 wells and the lines and infrastructure that run between and around them
will go. Santos is seeking a blank cheque consent for this gasfield on the promise that it will
decide where the wells will go afterward using a "Field Development Protocol." No project
has ever been assessed this way before in NSW and the constraints Santos propose are
weak and subject to change later on. This is not an appropriate way to assess the largest
development project ever undertaken under the Environmental Planning and Assessment
Act and the Government must insist that Santos release details to the public about the
placement of its wells, pipelines and some other infrastructure.
There's no justification: The significant harm on the social, environmental and economic
values of the Narrabri Shire and New South Wales that this project will inflict needs to be
weighed against the economic justification for the project, but there is no such economic
justification. Santos is one of several large gas companies that threw the east coast gas
market and the industries that rely on it into turmoil by opening up CSG fields in Queensland
and contracting to sell more gas than those fields can produce to overseas customers. They
drove up the price of gas and are plundering supplies previously available to manufacturers
and power stations.
The gas produced at Narrabri might be as little as 4.9% of the volume contracted for sale out
of Gladstone. It's not going to bring down prices. In fact, it will force prices up, because
unconventional gas like CSG is so expensive to produce and yields are so low. Research
undertaken by gas company AGL shows that gas from the Pilliga would be the most
expensive gas of anywhere in the current east coast gas market. The number of jobs the
project will support once the construction is over is just 145. Weighed against damage to
the land, and the Great Artesian Basin, this makes no sense. We need sustainable jobs, not
plunder for profit.
Groundwater and the Great Artesian Basin: Santos' project is expected to remove 37.5GL
of groundwater over the life of the gasfield, mostly in the early years. The coal seam needs
to be dewatered to release the gas, but this aquifer lies beneath the Pilliga Sandstone, part
of the Great Artesian Basin recharge. Santos' EIS admits that the project will result in a loss
of water from the GAB recharge aquifer over time. CSG in Queensland has drawn down GAB
aquifers already. We can't afford to risk this crucial resource.
Salt: The water removed from the ground by Santos will be treated, but this creates another
problem: what to do with the salt? Peak salt production at Narrabri CSG will be 115 tonnes
per day, or two and a half B-double truckloads per day. In the peak year, this would mean
the creation of 41,900 tonnes of salt for disposal, which Santos says will take place in
landfill.
Cultural heritage and the Pilliga: The Pilliga is a spiritual, cultural and social icon for
Gomeroi/Gamilaraay people. Fragmentation and industrialisation cuts people off from their
heritage and connection to country.
Biodiversity and the Pilliga: The Pilliga is also the largest temperate woodland in New South
Wales. Santos propose clearing nearly 1,000ha of the Pilliga, including habitat for critically
endangered Regent honeyeater and for koalas, which are already in decline in the Pilliga.
Spread across the whole forest, this clearing will fragment much larger areas of habitat. The
gasfield will clear breeding habitat for Pilliga Mouse, which lives nowhere else, and breeding
habitat for other wildlife. It will fragment and degrade the forest. Without specific
information about where the wells and lines will be located, a proper ecological impact
assessment can't be completed. Regardless, the Pilliga is a cherished natural and cultural
icon and must be protected from becoming an industrial gasfield.
Social and health impacts: Santos' social impact assessment is three years old and utterly
inadequate. The compendium of health studies produced by the Concerned Health
Professionals of New York shows mounting evidence for health damage by unconventional
gas operations, including water contamination and respiratory illness. The Government
must insist that Santos conduct a proper health impact assessment including modelling
exposure pathways, reviewing literature and engagement with the Narrabri community. In
Narrabri, this project will have negative impacts on cost-of-living, the labour and housing
markets. The latter is cited in as a benefit of the project but it will not benefit low-income
renters. The effect of the project on cost-of-living in the Shire needs to be modelled,
assessed and considered, as do the labour dynamics of the project. The project entirely
surrounds Yarrie Lake, and Santos propose that wells might come as close as 200m from the
Lake.
Air quality: The air quality assessment fails to include health-damaging fine particulate
pollution with a diameter of 2.5 microns or less (known as PM2.5). With diesel generators at
each well pad and at the water treatment and gas compression plants, there will be
significant PM2.5 emissions. The air quality assessment and greenhouse section also fail to
model the likely substantial escape of fugitive methane emissions.
Dark sky: light pollution from flares, compressor stations and the water treatment plant will
ruin the dark sky needed by the internationally renowned Siding Spring Observatory.
Climate change: recent research by the Melbourne Energy Institute shows that Australia
may be dramatically under-estimating the fugitive methane emissions from unconventional
gas, including coal seam gas. It's not needed or useful as a source of energy: we have the
technology we need to replace gas with renewable energy sources.

The Narrabri Gas project should not go ahead for many reasons that i will not cover here. The key objections I make are founded on a good understanding of the project and my experience as a regional development professional and Engineer. The project is not viable for the following reasons:

1. Companies (like AGL) and institutions such as CSIRO have proven that Gas is not a transition fuel in the transformation of the Australian energy sector towards renewables. This gas is not needed for the Australian market. The current Gas debacle has shown the true intention of companies such as Santo and their pursuit of unconventional gas. There is no doubt that the Narrabri gas project is being developed so that Santos can sell it on the overseas market. This makes no sense for NSW nor Australia. Because the few jobs that this project will create and provide ongoing are minuscule compared to the ongoing jobs that could be generated through other development mechanisms for the Narrabri (as well as other regional NSW) area(s). This project is squarely about Santos ripping off the Narrabri region to make profits for multi-national shareholders.

2. The proven impacts of unconventional gas are devastating. These are not just risks, they are real impacts that have already effected the Pilliga forest and will present hazards well into the future. This future would be one in which the company is removed from responsibility and will leave the tax payers and people of the North West to clean up the mess. Unconventional Gas is fraught with risks: to the environment, our ground and surface waters, the workers, the public, the

3. The future of Australia is at stake. The biggest issue facing Narrabri and regional Australia is how to transition beyond coal and gas. The Narrabri gas project will perpetuate Australia's global impact on the climate which will have immense impacts on Newcastle into the future. But most of all this project (and any further gas projects across Australia) will perpetuate Australia's backward march into the ground. Many of our professionals and other workforces are caught in the mining trap. A trap that means they are not able to get the skills and experience necessary to transition to a renewable energy and innovative services or productive future. If we keep drilling into the ground we are missing the opportunities that are above it. Australia's position as a world leading nation is at stake. The world is turning to renewable energy and if we don't transition (as companies like AGL and other leaders are suggesting we should) then we will be left competing against 2nd and 3rd world countries in a fossil free economy, whilst the world leaders like German and China, reap the benefits of competitive advantage by being early adopters to renewables. Australian engineers, technicians and professionals should be working towards improving the Agricultural, high-tech and services sectors, not an industry that will be finished within the next 20 years. When not only these professionals will be without relevant skills, but we will be left trying to clean up the mess the industry has left.

4. The people have spoken. It's time government listened. Unconventional gas is not feasible, workable or wanted. Across NSW professionals, organisations, communities and businesses have confronted proposed CSG projects to stop them in their tracks. The only projects still going are ones that were started before people realised what they were dealing with. It's time the government gave up on the fruitless industry and moved onto long-term, sustainable and productive developments that are in the interest of all Australians.