Narrabri Gas

I wish to state that I agree with Santos using the resources of the Pilliga Scrub.

The Minister

Dear Sir,
I strongly object to the Narrabri Gas Project on the following grounds :
1. Poisoning and extraction of a huge quantity of ground water, no safe disposal plan for the poisonous salt and no replacement of this essential water resource needed by farmers and rural communities over western NSW.
2. Enormous clearing of this valuable forest, the largest temperate woodland in NSW and home to precious wildlife.
3. It will create huge emissions of poisonous methane gas adding to dangerous climate change.
4. There is plenty of evidence of the harmful effects of coal seam gas and the mining process, people should not be subjected to this danger.
5. Renewable energy is the way of the future. We need to protect our land, particularly farming land, not pollute it and increase the risk of disastrous climate change. We should be investing in clean renewable energy if we and our children are to survive into the future.

Thank you.

This is my submission in relation to SSD 6456, the Narrabri Gas Project.
I have not made a reportable political donation in the last two years.


I object to the proposed Narrabri Gas Project, for each of these reasons:

CSG appears to be even worse than burning coal as a way of generating energy, because of its fugitive emissions -- although we don't have useful measurements of how bad those emissions are. But even if we make optimistic assumptions about low fugitive emissions from this project, it's still pretty greenhouse-gas intensive, and certainly a LOT worse than any renewable source of energy!

The proposal would reduce the pressure of the Great Artesian Basin and/or the Gunnedah Basin, and pollute the waterways (Bohena Creek in particular).

The locals - the Gamilaraay (Gamilaroi?) people - object.

The Pilliga Forest is a biodiversity hotspot; we should leave it alone.

I understand that the proponent plans to produce lots of salt - but does not have the facility to store all that salt on site, but also has no plan for disposing of all that salt.

Further, several other aspects of the proposed Narrabri Gas Project have not yet been specified, such as exactly where the well pads will be located, and how much PM2.5 particulate pollution will be generated. (This may be a reason to send the proposal back to the proponent as unfinished, rather than just rejecting it.)

Finally, consider what good would come of approving the project:
Some presumed profit for the proponent (in the form of a higher sale price, I believe), some energy which we could obtain in far better ways, and a relatively small number of jobs. That's the complete list of positives, so there's not much to recommend the project, and much to argue against it.
(Even the proponent is not sure that it wants to go ahead!)

It is clear that the Narrabri gas project is a poor decision by the government. The project puts at risk the precious water resources of the Pilliga region; farmers are against the project due to issues of water contamination; the traditional custodians of the land - the Gamilaraay people are against the project due to the destruction of areas that are important for the continuation of their ancient culture; Santos has a record of contaminating freshwater supplies in the Pilliga region. It's time that governments across this country took as sensible stand and put the necessary investment into renewable energy sources. Do not go ahead with this project.

To: the NSW Department of Planning and Environment. This is a Submission to the Narrabri Gas EIS.

I object to this project for the following reasons:

1* It will extract over 35 billion litres of toxic groundwater, much of it in the first five years. This water will be treated and in the early years will generate tens of thousands of tonnes of salt, for which there is no safe disposal plan.

2* It will clear close to 1,000 hectares of the Pilliga Forest, fragmenting the largest temperate woodland in New South Wales, home to unique wildlife.

3* It will cause significant diversion of water from a recharge aquifer of the Great Artesian Basin, which is a water resource relied upon by rural communities across western NSW.

4* It will lead to large deliberate and fugitive emissions of methane, adding to climate change.

5* It will cause more trauma to the regional Aboriginal community because the area of impact is crucially important to the spiritual, cultural and social life of Gamilaraay people.

6* It is not justified: Santos' own Coal Seam Gas export activities in Queensland have caused gas prices to rise and supply to become unpredictable. NSW should respond to this by investing in more reliable and ultimately cheaper renewable energy, not by letting Santos inflict more environmental, social and economic harm.

7* It will cause economic upheaval in Narrabri and put agricultural industries at risk, as well as causing light pollution that will ruin the dark night sky needed by the internationally renowned Siding Spring Observatory.

8* Coal Seam Gas is harmful to health. Neither the NSW Government nor Santos have investigated or dealt with the serious health effects of coal seam gas now appearing in peer-reviewed research in the United States. I have visited the gasfields of Queensland's Western Downs on many occasions and have raised money for the Health Testing of 18 residents ranging in age from 3 years to 68 years and all showed signs of:chemicals of concern in their urine, with the exception of one. The samples contained Hippuric acid (the main metabolite of Toluene)along with varying combinations of phenol, cresol, PAH and methyl ethyl ketone. Tank water testing (which was funded from another source)in some cases showed extremely acidic pH and concerning levels of heavy metals such as lead as well as radio-activity. All these chemicals are linked to gas extraction and can clearly be linked to the neurological condition of at least one of the children. It is also in keeping with other symptoms particularly in children, such as bleeding noses, eye irritation and breathing difficulties etc. To ignore all of these test results and the resulting health conditions would be a dereliction of duty by any government.

I am opposed to the Narrabri Gas Project due to its large potential for harm to human health, and its adverse impacts on the climate and the local environment.

The Narrabri Gas Project risks contaminating two very significant natural water resources: the Great Artesian Basin and the Murray-Darling basin. Drilling fluids have the potential to get into the waterways and contaminate these otherwise pristine water resources. Secure access to clean water is crucial for the livelihoods of farmers and rural communities in the area.

The Narrabri region holds cultural significance to the Indigenous people in the area, the Gamilaraay people. Hundreds of cultural sites are located in the area, along with many songlines and stories that strongly connect the Gamilaraay people to the land. A coal seam gas (CSG) project has the potential to damage these cultural sites and destabilise these connections, which would be a great loss for these Indigenous people who have lived successfully in the area for many, many years.

Santos has a long history of chemical spills and leakages from the storage ponds, pipes and well-heads associated with the infrastructure that has been built at test sites in the area. A freshwater aquifer in the Pilliga has been contaminated with uranium (contaminated to 20 times higher than safe drinking levels). There have also been leaks of lead, aluminium, arsenic and barium. Toxic CSG water has also leaked from storage ponds in the area. This track record is not a good one and I do not believe that Santos can be trusted to operate in a safe manner.

There are several other reasons that I oppose the Narrabri Gas Project. These include:
1. The Pilliga is a haven for threatened wildlife such as the Koala, Spotted-Tailed Quoll, Black-Striped Wallaby, Eastern Pigmy Possum, Pilliga Mouse, and South-Eastern Long Eared Bat.
2. CSG projects have the potential to contribute to global warming by inadvertently releasing methane into the atmosphere during CSG production, processing, transport and use. Methane is a far more potent (global warming potential wise) greenhouse gas than carbon dioxide.
3. Human health is compromised by coal seam gas. Hydrocarbons and volatile organic compounds are released into the air from coal seam gas operations. These chemicals are harmful to humans; they may result in eye, nose and airway irritation, headaches, nausea, dizziness, and loss of coordination.
4. Methane flare stacks would be operating day and night. This would increase the risk of bushfires in an already highly bushfire prone area.
5. The viability of AustraliaÂ's premier optical astronomical observatory Â- the Siding Springs Observatory Â- is at risk, as light and dust pollution from the CSG operations could inhibit the ability to see the night sky in that area.
6. Thousands of tonnes of salt waste would be produced from the CSG operations and, with no clear method of processing or disposing of this waste, it has potential to become a toxic leftover of the mining operations.

"I am employed by Santos in NSW with the majority of my work responsibilities relating to the development of the Narrabri Gas Project. However, I would like it noted that I am making this submission in a private capacity as an individual that has knowledge of the gas industry; the Narrabri Gas Project; and who also lives locally. Please note that my comments, observations and opinions are solely my own and may not be attributed to Santos and do not necessarily reflect the official policy or position of Santos."

I am providing a submission to the NSW Department of Planning and Environment in relation to Santos' proposed Narrabri Gas Project's EIS. I would like to raise some points regarding the proposed Narrabri Gas Project (NGP) and corresponding Environmental Impact Statement (EIS):

I have worked for Santos in NSW for approximately 5 years. During that time, I have witnessed the integrity of this company, the lengths it goes to protect the environment and the respect it holds for the communities in which it works and for the landholders who host our activities on their land. I am proud to say that I work for Santos, an Australian Company. I can honestly say, if I wasn't confident that Santos could operate with minimal to no harm to the environment I would not be writing this submission, nor, be working for the company.

We have stated publically that we will reserve the Gas produced from our Narrabri project for the NSW Domestic market. Internally, there has never been any other discussions that I have been privy to, to suggest otherwise.
This project could stand to supply up to half of NSW's gas needs. Currently more than 1,000,000 homes and 33,000 business in NSW rely on the supply of affordable natural gas.

Working for Santos has also given me the opportunity to return home to my family and to our small country town and live. If it wasn't for the opportunity provided to me by Santos, I wouldn't be able to live here, I would be forced to relocate to a larger area or back to the city to seek employment.

It is also through Santos that I have been able to purchase my first home. A dream that was impossible to achieve living in Sydney. If our project doesn't go ahead, I will be forced to sell my home and relocate back to Sydney away from my family.

I do not want to leave town. I want to see this project go forward, I want to see the local communities grow and develop. I want to see local people employed, both directly by Santos and indirectly by the other industries that our industry affects, such as other trades, hospitality and hotels. I want to see NSW benefit from the possible $1.2 billion in royalties that this project could create. I want to see improvements to local hospitals, roads, child care and aged care, all of which will be possible with the Community Benefit Fund Santos has pledged to support local community groups and programs.

This will be a fantastic project for the Community and the state of NSW. I hope to be a part of it for a long time to come.
I believe in this project and can proudly walk around town in my Santos uniform with my head held high knowing that we are doing the right thing by everyone involved in our project, now and into the future.

Thank you for your consideration.

This is an issue for the entire country. We don't need the gas to survive there are many alternate sources of power production. We need clean water and farm land. It is beyond belief that people can't see this, it just doesn't make sense.

The Narrabri Gas Project risks precious water sources, including the Great Australia Basin ~ Australia's largest groundwater aquifer.

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.

The Pilliga is one of 15 nationally listed biodiversity hotspots. The Santos gasfield wold 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.

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.

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.

First I object to the Narrabri Gas Project, and I will never have anything to do with Santos again ... ever.
I am so disappointed that we have even had to get to this submission writing stage. Does the NSW government not care about public health or the state of the environment at all? This project makes no sense and I want to make clear it is not done in my name. My faith in politicians has been completely trashed. Clearly today's elected representatives are only in it for themselves and the short term.
The Narrabri Gas Project is valueless and capable of great destruction.
I object to the project for many reasons, and the following points are reasons why I believe that it should be rejected:
1. The Narrabri Gas Project is worthless and everyone knows it including Santos.
2. Santos' environmental impact study is extremely short in detail. It does not provide maps indicating where exactly the wells, lines and infrastructure that run and around them will go.
3. It is unconscionable the NSW Government would consider granting Santos a blank cheque for this gasfield on Santos' promise that it will decide where the wells will go afterwards using a `Field Development Protocol.' No project has ever been assessed this way before in New South Wales and the constraints Santos propose are weak and subject to possible change later on.
4. There is no justification for this project whatsoever. The Narrabri Gas Project will wreak havoc and significant harm on the social, environmental and economic values of the Narrabri Shire and New South Wales, and Australia at large. Let us not forget that 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 could ever produce to overseas customers. Misleadingly and deceptively, they drove up the price of gas and are plundering supplies previously available to manufacturers and power stations.
5. Cultural heritage and the Pilliga will be destroyed by fragmentation and industrialisation, and this devastation will cut off the Gomeroi / Gamilaraay people from their heritage and connection to country.
6. Our precious groundwater and the Great Artesian Basin are at risk and even Santos has admitted that the Narrabri Gas Project will result in a loss of water from the Great Artesian Basin recharge aquifer over time. W cannot afford to risk this crucial resource.
7. The issue of salt is a major concern. Water removed from the ground by Santos will be treated leading to peak salt production which Santos says they will dispose of in landfill - 41,900 tonnes of salt per year ... are you kidding?
8. The Pilliga is the largest temperate woodland in New South Wales. Santo propose clearing nearly 1,000ha of the Pilliga, including habitat for the 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 Narrabri Gas Project will decimate the breeding habitat for the Pilliga Mouse which only lives in the Pilliga (nowhere else) as well as other breeding habitat for other wildlife. The Narrabri Gas Project will conclusively fragment and degrade the Pilliga Forest.
9. There is ever-growing international evidence pointing to the health damage attributed to unconventional gas operations including water contamination and respiratory illness. Does this international evidence cause any concern for the NSW government?
10. The air quality assessment fails to include health-damaging fine particulate pollution with a diameter of 2.5 microns or less (known as MP2.5). With diesel generators at each well pad and at the water treatment and gas compression plants, there will be significant PM2.5 emissions.
11. Goodbye dark skies, and Siding Spring Observatory and international interaction with eminent scientists such as Professor Brian Cox - hello light pollution from flares, and compressor stations and the water treatment plant. Siding Spring is a critical facility and shareholders and the government should not accept the damage that the Narrabri Gas Project will create on Siding Spring.
12. Australia's continued denial of the science of climate change is reprehensible. 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 is not needed or useful as a source of energy: we have the technology we need to replace gas with renewable energy source.
13. Why are we continuing with this gas charade? With export markets evaporating, prices falling (except for in Australia due to unconscionable behaviour ... sigh) why would Santos want to continue to develop the highest cost gasfield on the east coast? Santos has written off $1.4 billion dollars on the Narrabri Gas Project to a current value of $0.00 - essentially this project is not worth a cent - what is this all about? Please explain. Santos shareholders and the New South Wales government should be asking themselves why the Narrabri Gas Project is still supported by Santos management when all the key economic indicators demonstrate an immediate closure is the prudent decision.
14. There is there little community appetite for the Narrabri Gas Project as evidenced by all the submissions written so far, as well as the protests, the letters, the meetings, the change of party seats in formerly safe seats. Everyone knows that Santos is in financial turmoil with its share price at near record lows. It is completely mystifying as to why Santos would want to continue trashing its brand. There is wide-spread rejection of the CSG in New South Wales, and the Narrabri Gas Project is not changing that view.
15. Santos' claims of working with the community are laughable and completely rejected. The community does not feel listened to. Public companies have legal obligations to listen to the concerns of the community and to act appropriately.
16. At the risk of repeating myself, essentially the Narrabri Gas Project is a stranded asset - and Santos knows it. Santos' reporting makes it clear that it does not have its sights set just on the Pilliga and the vital southern recharge area of the Great Artesian Basin. While Santos is telling the community that it is only focused on its Narrabri Gas Project it is at the same time mapping to its investors seven prospective gasfields across productive agricultural land in New South Wales, making it very clear that the long term intention for this region is gasfield expansion and interconnecting pipelines.
17. All gas wells fail at some stage and there is substantial evidence that well integrity can be compromised at any stage of a well's existence. Don't let that happen to us.
18. Drilling through aquifers is a risk - do I really need to write that? We are all reliant on groundwater and surface water. Santos does not have the information to say categorically that the Narrabri Gas Project will not affect other groundwater systems or contaminate surface water systems. Furthermore it is unable to provide concrete assurances the impact can be confined to the deeper systems as the current interconnectedness between the Great Artesian Basin and the deeper coal seams is presently unknown. Groundwater contamination of the Great Artesian Basin is a major corporate and community risk for Santos. They are and they know so, that they are responsible for how this all pans out. Surely Santos shareholders are increasingly concerned that putting the Great Artesian Basin at risk weakens community confidence in the company and perhaps explains the already considerable loss in shareholder value.
19. The risk and the impact of the Narrabri Gas Project on existing industries are high and grave. Santos shareholders and the New South Wales government should not be willing to be part of the systematic dismantling of existing sustainable industries that represent core Australian values.
20. Community health impacts have not been properly considered. To date they have been poorly addressed causing growing community concern and scepticism, further eroding the acceptability of the Narrabri Gas Project.
21. I am gravely concerned about spills and leaks - they are inevitable yes, but they are never acceptable. The Narrabri Gas Project has been responsible for a succession of spills, leaks and unapproved releases of produced water from sources that range from drill rigs, well sites, cuttings ponds, storage reservoirs, tankers, poor operating practices and poor container cleanout practices by contractors. Santos' internal records show that many have not been reported as required by the Conditions of Operating and many of these events have been recorded and communicated only by community members. In 2011 a large spill (not reported at the time) of alleged produced water from the Bibblewindi facility decimated approximately two hectares of vegetation. Santos declared that "the spill was only 10,000 litres of water, some of which was recovered" which would equate to two cups of water per square metre. Obviously far more water than this was spilt as significant pH changes were measured (and reported by Santos' consultant CH2M Hill) 277 metres from the spill site, to the depth of measurement (pH 10.0, 8.5 and 8.2 at depths of 0-50, 50-150 and 500-600 mm respectively, compared to a background level of 5.6). The response by Santos destroyed its credibility in the eyes of the community and was highly disappointing for shareholders. All vegetation in the area has remained dead for the past 6 years, resulting in further ridicule of Santos' response.
22. The days of denying anthropogenic climate change are over. The science of climate change is well and truly proven. Temperature records are being smashed monthly. The majority of greenhouse gases come from burning fossil fuels to produce energy. As outlined by a number of Australia's leading CEOs on Santos' website before the page was removed: "Climate change is affecting our businesses and the communities in which we operate ... the longer we wait, the harder it will be and the more it will cost us ... We are also vulnerable to climate impacts and we have a strategic interest in managing climate change." So in a nutshell, for Santos to continue to deny the role that fossil fuels (including CSG) play in climate change is morally reprehensible.
So, my NSW Government, please please abandon the Narrabri Gas Project and please please resume (or buy back ... whatever) the petroleum exploration licences for good. We can no longer ignore the overwhelming evidence that the Narrabri Gas Project is doomed, and ought not to be allowed to proceed. If it is permitted, the Narrabri Gas Project will consign us to a very grim future. We have our children, and their children to think of - we must say no.

There is a need for that water.
The NSW government found that the money paid to mining companies doesn't accurately reflect the true cost of rehabilitating mine sites. Furthermore, 75% of mines closed under 'unforeseen circumstances', and have been unable to pay any further rehabilitation costs. The bonds that secure our water and land's future do not take into account any unmitigated risks and are not being adequately regulated. That means the large extraction pits and mine sites are leeching heavy metals and acids into our ground water and no one is rehabilitating it.

It is of critical importance that the gas from this project is transported (via Stage 1 of the Queensland Hunter Gas Pipeline) from Narrabri to Newcastle, which has DA approval. This approval means the Queensland Hunter Gas Pipeline is the fastest, cheapest and most certain way to get gas from Narrabri into the domestic NSW market.

Building the Queensland Hunter Gas Pipeline will ensure that the newly developed Narrabri Gas Project supplies the domestic NSW market (Hunter and Sydney Basin) rather than be diverted via a short-cut along the Moomba-to-Sydney Pipeline through Moomba and into the LNG plants in Queensland for export.

The Queensland Hunter Gas Pipeline will also increase competition in the east coast pipeline network.

Reconsider this, there is still so much unknown about the dangers of CSG and so much better and more profitable to turn your attention to renewable energy. It is dark ages to be even thinking of anything but renewable energy. History will not look well upon enterprises that in the face of such overwhelming evidence to the contrary still pushed the degradation of the earth and all who live on her.
Notice that Victoria continues its Moratorium on CSG and the people of Victoria are very grateful.

Please forget about drilling for gas. What we need to focus on now are renewables. Australian heritage is precious and should be preserved for future generations.Short term solutions for long term problems never succeed.If we destroy the very land we live on we will not survive.

U do NOT need further argument 2 OPPOSE your short sighted deal as a "Quick grab 4 dough!" EARTH COMES FIRST!

The magnitude of this proposal in the current context of uncertainty in relation to guaranteed prevention of damage to the water table and surface waters make the gas project totally unacceptable. The potential for irreparable environmental damage to water, land and biodiversity in general is enormous and in no way counterbalanced by any economic concerns.
Santos must not be allowed to threaten our artesian water supply and environment with this enormously dangerous scheme.

At the time when the world is concerned about fossil fuels, opening up a giant new gasfield is madness--especially when it risks our water, our farms and our endangered species. Our environment is precious to every human being and creature on our planet. SAY NO to new gasfields.

I do not want to see the land destroyed by mining and digging. Please stop now.

If you want your children and granchildren to be proud of you,dont allow this land rape.
Respect the indigenous caretakers.
Fossil fuels have had their day.
Think of the damage to wildlife and to the eco system.
Dont be a corrupt or ignorant pawn of these depoilers for profit.

Dear Minister,
I have recently moved to Queensland for a short period of time but I am a long-term NSW resident and voter. I have watched closely the developments in the Pillaga with regard to Santos's plans to develop coal seam gas in this area and I want to lodge my very strong opposition to this move.

I base my opposition on three points.
1. The Pillaga is part of the Great Artesian Basin which is a very significant source of water for a huge area. As a very dry country, Australia cannot afford to follow any mining activities that will jeopardize the quality and quantity of water from the Great Artesian Basin and I believe that experience in Australia and internationally have shown this risks exist.

2. Coal seam gas extraction is an 'unconventional' form of gas extraction and we know very little about its long term impact on the environment. We have a duty to future generations to leave the countryside in a state that they too can make a living from the land.

3. This whole process of allowing Santos to even set up the waste water plants before the EIS was completed and put out to public examination, let alone ask NSW residents if they want CSG mining is completely undemocratic. We may not be scientists but we are informed people and we have the right in our democracy to have a voice about these matters.

Putting it simply, I want to add my voice to those who oppose the application by Santos to conduct coal seam gas extraction in the Pillaga area.

Yours sincerely

Louise Redmond