Narrabri Gas

- Economic benefits to economy:
o Creation of jobs - both locally and to other service providing businesses in the industry;
o Distribution of funds to community infrastructure through royalties paid to government;
o Funding of local community organisations through sponsorship and the Community Benefit Fund;
o Helping to diversify the local economy by adding an additional industry;
o Additional income to farmers / landholders who have infrastructure on their properties;
- Helping by bringing more gas to market thus helping with the energy crisis and gas shortage;
- Providing an additional resource to assist scientists and researchers conduct research on the gas industry and gain baseline data;
- Using "best practice" policies, methods and technologies thus raising the standards across all industries as those involved with Santos then utilise those processes in other work environments;

I wish to support the Narrabri Gas Project in order to generate more jobs within the community and allow the gas shortage in NSW to be addressed.

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 long term impact on ground water/aquifers and the vegetation surrounding the proposed CSG extraction area is unknown. The precautionary principle should be implimented until a detailed independent study to review the impact of CSG extraction on a landscape wide area is conducted including models of long term health impacts. The focus of this study should be the overall number of extraction sites within a ground water/ aquifer catchment and their impact of water, soils, vegetation and human and animal health risks.
Furthermore the impact to populations of endangered native flora and fauna will be detrimental to the long term survival.

NSW Department of Environment and Planning
RE: NARRABRI GAS PROJECT: APPLICATION NO SSD 6456

OBJECTION

I object to the Narrabri Gas Project for the following reasons:
* There is no gas shortage in NSW. We know this because the Chairman of Santos has told us so as well as various other sources. A new report from Melbourne University by Tim Forcey and Dylan McConnell says the predicted shortfall for gas will not eventuate. (Higher energy prices have little to do with 'gas shortages', researchers say SMH Peter Hannam May 18 2017) In fact, the report clarifies there is a shortage of "cheap" gas, but not a supply shortfall and there are cheaper options to developing new gas fields. The basis on which the proponent justifies the project is false.

* There is no evidence that the project would offer "greater energy security and economic sustainability" (Energy benefits EIS 32-3). The customer base for gas fired electricity generation has changed and the market is switching to renewable energy. The Australian Energy Market Operator has signaled that new technology and systems will replace coal and gas. Gas is just too expensive for the domestic and manufacturing markets. Major operators - like AGL - have dropped their NSW gas interests. The proponent has not shown that current or future demand for their product exists in NSW. Wind and solar are now the most affordable new build electricity generation technology. Every dollar we spend today on outdated electricity generation -like gas - will remain a future financial and environmental legacy.

* The proponent has no social conscience when it comes to climate change and limiting carbon emissions and has failed to address the climate risk of the project. The proponent states that the project could potentially reduce greenhouse gas emissions, but that is only the case if we compare gas to coal and ignore the likely fugitive emissions that will result from the project. The global community has shifted from reliance on coal and is now transitioning from gas to renewables. When it comes to market demand, it's all about the money and the costs. Gas has outpriced itself when cheaper and cleaner alternatives are available. The Chairman of Santos has announced the company operates to a 4⁰C climate change scenario. This is dangerous to the global community and is direct conflict with Australia's commitment to The Paris Agreement to stay below 2⁰C global warming. The Chairman's statement undermines any commitments made by the proponent's EIS with regard to minimizing greenhouse gas emissions.
* The proponent can only guess at the carbon emissions resulting from the project. The Chief Scientist has qualified that "considerable uncertainty" and better understanding of the industry's impacts over time and scale are required.

* Fugitive methane emissions from coal seam gas production remain unaccounted for and unknown, negating the proponent's claim that lifecycle emissions for the energy produced from the combustion of natural gas are less than the electricity that is currently supplied to the NSW grid.

* The EIS has failed to account for the fire related risks the project faces and poses, both from climate change and predicted extreme weather events.

* The project is massive and represents a future liability for the region. 850 gas wells are proposed in unknown locations throughout the State Forest. They will be located at a future operational level, determined by a "Field Development Protocol" when the project is given a go-ahead. This scant level of detail is unacceptable and dangerous. Far too often, the community has witnessed problems managed at "operational level" - yes, think Eastern Star Gas.

* The proponent cannot guarantee the integrity of Aboriginal or cultural significance will be protected. We are told that if issues arise, Aboriginal and environmental "offsets" programs will be developed. Trouble is, unless we (the community) know it is possible to replicate what is lost, the proponent's assurance is meaningless.

* The traditional industries of the region are threatened by the likely impacts the project presents. The existing agricultural and forestry industries rely on the maintenance and enhancement of natural systems which the project directly threatens. Wealth creation cannot be assured by the proponent, especially when the project's environmental impacts are not fully understood, transparently costed and are in conflict with the existing economic stability of the region.

* The vast majority of regional residents oppose the project. Agricultural producers in particular are threatened by contamination and are unable to plan to safeguard their investments and plan for the future. There is continued community concern over the lack of government support and resources to monitor impacts from the industry.

* The Siding Spring Observatory operations are threatened by the project. The gas flares in particular will add a damaging amount of light pollution to the region's "night skies" and could potential devastate the observatory's international scientific reputation. As well, the observatory is a major and sustainable contributor the region's economy.

* The APA pipeline is a consequence of the project and presents problems in terms of social disruption and dislocation over a wide area.

* Employment opportunities arising from the project are short term and cannot guarantee intergenerational equity.

* The project will fragment and degrade the Pilliga forest. Over 1,000 hectares of native vegetation will be removed as a result of construction and operation of the project. The Pilliga is the largest temperate woodland in New South Wales which includes the breeding habitat for the Pilliga Mouse, the critically endangered Regent honeyeater and koalas. The area is recognized by the Federal Government as one of only 15 national biodiversity hotspots within Australia. It forms the southern recharge area of the Great Artesian Basin and contributes surface water flows to the Murray Darling Basin. There are 24 matters of national environmental significance, as defined by the Environment Protection and Biodiversity Conservation Act 1999 that occur within the gas license areas of the Pilliga Forest. (Nature Conservation Council).
The impacts of increased traffic, road and infrastructure construction and the maintenance, dust, air contamination, night lighting and noise from the machinery, vehicles and personnel will undoubtedly impact surrounding vegetation and critical habitat. Weed species will be transferred to the project area. Accidents related to related spills or leaks are likely to happen. Incrementally and unavoidably, the environment will be degraded. This is unacceptable and unjustified.
The local environment is already under stress from climate change - both extreme heatwaves and rainfall/storm events are predicted to increase in frequency and intensity. This project may present the proverbial straw that breaks the significant biodiverse, environmental resilience of the Pilliga Forest.

* The waste generated by the project is unacceptable and presents a further long term legacy to the community. In particular, up to 115 tonnes per day of waste salt will be produced during the second to fourth years of the project, with an average of 47 tonnes daily over the proposed 25 years of operation. This totals over 430,000 tonnes of salt over the life of the project to go to unspecified landfills. Santos originally indicated that they would find an innovative solution to deal with waste salt - but haven't. Sites where salt is dumped require permanent management to ensure that groundwater contamination and leeching does not occur. That is an unfair, permanent cost to the community. There are alternatives to landfill - the proponent should be made to dispose of waste as per best practice as opposed to what is cost effective to the company.

* There are no energy benefits resulting from the project. The proponent states that the project will contribute substantially to the amount of gas available to the NSW market, providing NSW with energy security and economic stability. (EIS 32-3 Energy Benefits). This is simply not the case when we know there is no gas shortage, extra gas will not bring prices down, and the electricity market is transitioning to renewables. There is a high risk that the project is redundant before construction, noting there is substantial infrastructure in place that was speculatively developed on the project's anticipated approval.

* The economic and employment benefits are totally dependent on a biased assessment process. The accuracy of the project's economic model is dependent on unrealistic forecasted demands for gas. Add to that the high cost of gas to the consumer when cheaper alternatives for energy are available, means there is a high risk that this project becomes a stranded asset in the foreseeable future and cannot provide forecasted benefits.

When the NSW State government identified the Narrabri Gas Project as a strategic project for NSW, it was both ill-informed and complicit in continuing a seriously flawed approval process. The potential gas-shortage cited to fast track CSG production has not and will not eventuate. The project is not justified.
The present government has not garnered bi-partisan support for the project and there is overwhelming evidence that shows the project is not supported by the community.
The proponent has presented a biased EIS in favour of the project which fails to account for the likely adverse impacts on the society, environment and economy of the region. The risks that the project and its associated infrastructure present to NSW are too great for project approval. As a consequence, the project should be rejected.

I have not made a reportable political donation. I have read the Department's Privacy Statement and agree to the Department using my submission in the ways it describes. I understand this includes full publication on the Department's website of my submission, any attachments, and any of my personal information in those documents, and possible supply to third parties such as state agencies, local government and the proponent.

Yours faithfully,
Megan Benson.

Human society's relationship to the natural environment is running a disaster course and needs to be checked. This checking can only happen one step at a time. The step to protect the Pilliga from highly toxic coal seam gas mining is in your hands, now.

Coal seam gas extraction is an inefficient and unsafe method of obtaining resources for energy production. This has been demonstrated in many situations around the world where it has been applied. The only reason to pursue coal seam gas is to make profit at the expense of sustainability.

There are much cleaner and safer ways of providing electricity to the population. It is anachronistic to use coal seam gas extraction when clean and renewable technologies are available.

I feel the risks to the water table and other environmental risks for future generations in a far reaching area far outweigh the fleeting financial benefits of the operation for a priveledged minority

This is a destructive and unwelcome project. It is environmentally destructive in a key biodiversity hotspot. Its impacts on water security and purity in 1 of the driest continents in the world are so negative that it beggars belief that it would even be considered by the Government. Santos has a terrible track record in managing environmental impacts and cannot be trusted to manage this project. There is too great a risk to our nation's reputation in support such an environmentally damaging project. Australia already has a poor reputation in so many areas of environmental vandalism - Great Barrier Reef and Adani - this is only further grist to this mill! If we consciously pollute our air and night sky - our reputation in the astronomy sciences will be irreparably damaged also. This is alongside the ignoring of climate change acceleration potential and risk to health of all in the vicinity and further afield of the immediate project area. There are so many less impactful ways to generate power / energy - all Governments should be focussing their efforts along these avenues - not along dangerous and proven to be irreparably destructive paths.

Thank you for the opportunity to lodge a submission on the Narrabri Gas Project.
I am strongly opposed to this project, or any development of CSG in the Pilliga region. The proposed project threatens human health, animal habitat, increased bushfire risk, the viability of the Siding Springs Observatory, and most importantly, Australia's major water supply, all the while significantly contributing to on-going climate change.

Community surveys have shown that on average, 96% of the people here do not want CSG mining in the Pilliga. The Gamilaraay Traditional Custodians of the area, also opposed to the project, have participated in many protest actions. They have been joined by hundreds of farmers, who recognize the threat this industry poses not only to their livelihoods, but to an invaluable Australian water resource--the Great Artesian Basin.
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. There have also been more than 20 reported spills and leaks of toxic CSG water from storage ponds, pipes and well heads--demonstrating over and over again that Santos cannot be trusted with something as precious as Australia's most important water resource!
Santos also has no solution for disposing of the hundreds of thousands of tonnes of salt that will be produced!! The Narrabri Gas Project will leave a toxic legacy in NSW for our children and grandchildren to clean up--if they can.

And for what? To produce more coal seam gas for export? To line the pockets of more overseas investors? The project is totally unnecessary for Australia's energy needs, which can be more than adequately met by the reserves in the Bass Strait.

Finally, I oppose this project because of its impact on climate change. Coal seam gas extraction is touted as a `green' alternative to coal, which will help alleviate carbon emissions. But the truth is that during the production, transport, processing, and use of coal seam gas, the leakage of methane (a greenhouse gas 70 times more powerful than carbon dioxide) contributes to climate change just as much as coal.

For all of these reasons, I urges you to categorically reject Narrabri Gas Project proposed by Santos.

Sincerely,

The environmental risks associated with this project by far outweigh its potential economic benefits. Indeed the risks in relation to groundwater - the potential contamination of the Great Artesian Basin and the rivers which flow into the Murray Darling Basin, could result in potentially catastrophic economic, social and environmental consequences for this state.
I am also very concerned about the effects on the Pilliga forest, the largest and most intact temperate eucalypt forest in eastern Australia and as such a most important ecological refuge for a range of nationally and state listed endangered species. The construction of up to 850 wells as proposed in the region (or even a fraction of that number) would fragment the forest and destroy the last remaining intact habitat for these species.
I believe this project must be refused absolutely. It is not acceptable to simply impose environmental safeguards in relation to the project. Santos has a very poor record of compliance, as demonstrated by the number of contamination events during exploration. Potential fines and other penalties are inadequate to ensure compliance, and cannot restore the damage once it has occurred.
Thank you.

NA

It would be calamitous to allow a huge project like this to fragment and degrade one of the largest tracts of unbroken bush left in NSW.
It is a horrifying prospect. You only have to look at aerial photos of post-Newman S.E Q. to see what the impact of so many gas wells would be.
My knowledge of the ecological importance of the Pilliga is based on visits there as a birdwatcher and surveyor over a forty year period, during which time I've seen the clearing of much of the mallee and open woodland, with catastrophic results to biodiversity.
The Pilliga was listed as an IBA for good reasons, as it is home to a raft of bird [and other] species on the threatened and vulnerable lists.
Of equal concern is the very real risk to our State's water resources, not only the Great Artesian Basin, but also our river system, given the proximity of creeks flowing into the Namoi and on to the Darling. No wonder just about every farmer in the region is up in arms about the scheme.
Santos has a terrible record already, and there is no assurance that it won't do more damage before the regulators can intervene.
Finally, it would be far better to encourage clean energy companies to develop less sensitive solar and wind projects in less environmentally sensitive area.
Dr. C. E. V. Nixon
Ex-President, and Ex-Conservation Officer, Birding NSW
Ex-Coordinator, NSW Bird Atlassers
Ex-member of the Australian Committee, Regent Honeyeater Recovery Project.

This proposal threatens our groundwater supply through pollution as well as threatening the recharge system, the flow of local waterways, bird habitat, large land clearing. Santos has a history of spills and leaks of toxic CSG water and the drilling would produce 100 tonnes of toxic salt waste every day at peak production.
It is also a threat to Aboriginal land and culture.

I do believe that Australian Natural Gas should be part of the country's overall secure and sustainable energy future.
I seriously believe that this objective can not be achieved by drilling new CSG wells on land or in the sea. All the reasons against new drillings or exploration are clearly stated everywhere we look,read and have personal experience of but still commercial and political interests continue down tracks in blind objectivity for their own agendas. We have in the past made a positive contribution in establishing natural gas supply but more is not the way for the future.

We need to protect our aquifers, creeks and rivers for all species to live from - wildlife doesn't have a choice. I see wildlife drink from polluted creeks daily, accumulating toxins.

It's time we as a species learn to live within our means and impacts on planetary systems, fossil fuel is damaging our air, climate, and oceans.

Please no more damage to local and global environment, let's all live within our means...., for all our futures sake.

Santos' risky quest for coal seam gas in the Pilliga so far has met disastrous results - with over 20 pollution scares, including groundwater contamination, waste spills, and continuing leaks from evaporation ponds. The economic justification for the project, a gas supply shortage in NSW, has also been conclusively disproven. Moreover, the Pilliga forest, is the largest inland forest left in Eastern Australia and needs to be protected from this potentially disastrous project.

As a concerned community member, and also a Fellow of the Australasian Faculty of Occupational and Environmental Medicine, and Faculty of Public Health Medicine (Royal Australasian College of Physicians), I object very strongly to this proposal. The risks to the health of the local population, and to agriculture and food security locally and more widely, far outweigh any short-term economic benefits. Yes, we do need alternatives to coal, but this is NOT a viable solution.

I strongly disagree with the idea of having CSG in the Pilliga. It will put our groundwater at risk that is the lifeblood of the farming communities in the area and will make it impossible for Australia to make a significant headway at meeting our Paris Agreement.

This project is full of risk and the reward is not enough to make it worth it.

The Gloucester Knitting Nannas are opposed to the approval of the licence to allow Santos to drill 850 CSG wells in the Pillaga area on many grounds. Our major objection relates to water. On the world's driest continent, water is our most precious commodity, and should be receiving the highest level of protection from all levels of government. The wells would be drilled in an important recharge area for the Great Artesian Basin, the major source of water for rural communities across western NSW and beyond, and would cause this much needed water to be diverted. Local farmers are already reporting depleted bore water, thanks to Santos' current activities. The record of CSG companies in Queensland shows that their activities lead to loss of water, and this has the potential to affect our food security.

In the initial stages, it is anticipated that over 35 billions litres of toxic groundwater would be extracted, and whilst it is proposed that this water will be treated, it will generate many thousands of tonnes of salt, for which there is no safe disposal plan.

The Pillaga Forest is the largest temperate woodland in New South Wales, and is home to a unique range of wildlife, including endangered species. If allowed to go ahead, Santos would clear almost 1,000 hectares, and place many of these species at risk, and irreversibly damage this eco-system.

There has been much debate relating to the supposed gas shortage. Many reputable researchers refute that this shortage will eventuate. I would refer you to this article by Michael Slezak that appeared in the Guardian on 18 May :
https://www.theguardian.com/australia-news/2017/may/18/australias-2018-gas-shortage-will-not-eventuate-report-shows?CMP=Share_AndroidApp_Tweet.
It refers to a report by Tim Forcey and Dylan McConnell at Melbourne University's Australian-German climate and energy college, which notes "that wind and solar could produce cheaper electricity than gas, and if combined with storage, would protect electricity prices from the high gas price", and concludes "Gas has often been characterised as a `transition fuel', on the pathway to a zero-emissions power system. The falling costs of renewable energy and storage technologies, the increasing gas cost, and climate change objective suggest this transition is no longer necessary, and indeed a detour."
There is also little doubt that much of gas from the Narraibri field is destined for export, not for domestic consumption.

The internationally acclaimed Observatory at Siding Springs is in Australia's only Dark Sky Park and will be affected by the light from the flares if Santos is allowed to go ahead. The potential damage to our international reputation in this field needs to be taken into account.

The effect of delberate and fugitive emission of large quantities of methane on climate change should also be taken into consideraton. We believe that the rebates that would inevitably be granted to Santos could be better used as investment in renewable energy sources and reseach.

We do not feel that it is appropriate for us to comment on the impacts on the local Aboriginal community, on the spiritual, cultural and social life of the Gamilaraay people, but merely ask that these form part of your review.

There are well documented health issues relating to coal seam gas, both from overseas sources and the Queensland gasfields.

The philosophy of the Knitting Nannas as stated in our Nannafesto, is that "we want to leave this land better than we found it, for our children, grandchildren and future generations. They deserve to have a future with a clean and healthy environment, natural beauty and biodiversity."

In light of all the above, we would ask that this licence not be granted.

I strongly object to the proposed Santos development of CSG mining in the Pilliga region.
I am concerned about the potentially disastrous and irreversible environmental consequences.
There is a real risk that the Great Artesian Basin will be contaminated if the mining goes ahead. Already endangered native animals in the area will be put at increased risk.
I support a greater focus on the development of renewable energy technologies to meet Australia's future energy needs. We need to create jobs in a sustainable way, rather than turning our precious natural resources into an industrialized gas field.