Narrabri Gas

Agriculture no longer employ the workforce that it once did. Narrabri has been built on this very industry that is employing less people. We need an alternative industry that requires local workforce.

CSG mining needs to be established in NSW. It is a cleaner fuel than coal and I do not believe that renewable energy has the technology to sustain our lifestyles. I am a gas user and I would like to see the price lowered by developing a local source for NSW, instead of it coming from interstate.

Provide local jobs and a strong economy for Narrabri into the future to promote new industries into the region

We have lived in Narrabri our whole lives. We support the Narrabri Gas Project as it will provide opportunities for my children and their children.

Santos using the Pilliga Scrub for the development of the project is a better proposal than forcing themselves onto peoples farms.

I support industries that supply employment opportunities. I come from a town that has both coal mining, agriculture and tourism. Having this diversity, gives us a strong economy. This could be the case for Narrabri, should the Santos project be approved.

I object to the Narrabri Gas Project for several reasons as follows.
1. I believe the risk to ground water including the Great Artesian Basin is too great. These projects have a history of polluting ground water with drilling fluids and salty extracted water.
2. The extraction of large amounts of ground water for the purpose of coal seam gas extraction is a very poor use for this resource which is relied upon by rural communities throughout the Murray Darling Basin.
3. An over whelming proportion of people living within the affected area are against the project.
4. The Gamilaraay people are deeply opposed to this project.

I support the Narrabri Gas Project for growth of the community and district and for a cleaner future energy.

Narrabri Gas Project. Let's not go forward with this. Let's look at the future in wind and solar projects.

My family has been in business in Narrabri for over 50 years. When Santos drilled their exploration wells a couple of years ago, I witnessed a boom in the town. I can vouch that there are positive flow-on-effects from the Narrabri Gas Project - because I felt it in my own business. This flow-on effect will also encourage new businesses to come to Narrabri.

I object to the Narrabri Gas Project because :

* It is using fertile land which Australia would benefit from in growing and harvesting food for our people rather than relying on expensive imported foods and hence supporting another countries economy.

* This will have a huge impact on the mental health of the people who live in this area and the surrounding districts. Many of these people are farmers that rely on fresh water and clean air to make a living. The stress from this project has the potential to break families and destroy townships. This in turn has a negative effect on those of us who live in the suburbs of Sydney.

I feel that this will benefit our area.

Its great for the local economy

I support the Narrabri Gas Project for the following reasons:

1. It will benefit the town and district
2. It will increase employment opportunities for our region
3. Gas is a needed product for the benefit of both local and Australian consumers

Santos will
- provide much needed jobs and support to regional areas
- help regional areas grow and provide a safe economic future

I support the Narrabri Gas Project:

1) It will be beneficial for the town of Narrabri and District
2) It will increase employment opportunities
3) Gas is a needed product for both local and Australian consumers

I am a supporter of Santos and their proposed Narrabri Gas Project.

The Narrabri Gas Project will provide local job opportunities

I support Santos because of the jobs it will create

Attn: Executive Director, Resource Assessments
Department of Planning and Environment
GPO Box 39
Sydney NSW 2001

This is a submission to the Santos Narrabri Gas Project EIS.

I object to this project and believe it should be rejected for the following reasons:


1. Threatened species and threatening processes

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 threatened species.

A fauna survey was completed by the Inland Council in 2011 that highlighted several significant facts:

The Pilliga State Forest is the only habitat for the pilliga mouse (Pseudomys pilligaensis); this species is listed as Vulnerable under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) and Vulnerable under the NSW Threatened Species Act 1995 (NSW TCA).

The Pilliga State Forest represents one of the largest koala (Phascolarctos cinereus) habitat areas in NSW. The koala is listed as Vulnerable under the EPBC Act and NSW TCA.

The EIS for the project recognises that threatened flora and threatened ecological communities will be impacted by the project. In terms of fauna, 16 birds, 10 mammals and 1 reptile are listed as threatened under the TSC Act; 3 mammals, 1 bird are listed as threatened under the EPBC Act.

The fact that the authors of the EIS stated that brushtail possum and koala scats are similar puts into question their ecological credentials and the results of the surveys. I am an ecologist and I find them vastly different.


2. Vegetation clearing

The development will clear approximately 1,169.9 hectares of the Pilliga Forest, seriously fragmenting the largest temperate woodland in New South Wales. I have completed fauna and flora surveys in state forests in Queensland and have seen the reality of well pads 750m apart combined with access roads and pipeline gathering which can be up to 50m in width and must be maintained as a cleared area.

Well pads are developed at 100x100m and are supposed to be rehabilitated to 30x30m however the reality is that the soils are extremely fragile. There is rarely enough topsoil to re-spread and the seed bank is usually absent or has sprouted and died within the top soil stockpiles. When a pad is cleared the roots are completely destroyed and thus there is no revegetation. Consequently the 100x100 pad remains barren.
There are also problems such as the spread of weeds that colonise the roadsides and infiltrate the forest. This has been a serious problem in forested areas in Queensland.

An example from Queensland is the Condamine State Forest which has been completely covered by wells with little to no revegetation occurring two and three years from construction. It is possible to observe this from Google Maps. Trees over 1m wide, hundreds of years old full of hollows, beautiful wildfowers, threatened animals and plants, all destroyed.

The Pilliga State Forest should be kept as a State Forest or National Park, not as a mine site that will destroy the ecological, visual and recreational amenity.

After 30 years the CSG infrastructure is supposed to be removed and the entire area rehabilitated. This is extremely unlikely given the history of coal mine rehabilitation in NSW. Even if it was rehabilitated I doubt whether the result would be successful, more likely it would remain as cleared tracks and well pads.

NSW is currently relaxing land clearing laws (http://www.abc.net.au/news/rural/2016-12-28/landmark-changes-to-nsw-land-clearing-laws/8123918). This puts more importance on protecting areas that are forested and not in agricultural areas.

3. The Pilliga State Forest timber industry is close to exhaustion

A recent article on the ABC in 2015 detailed that the timber resources within the Pilliga State Forest are at risk of destruction.

`Sawmill owners fear Pilliga forest in NSW being destroyed by timber contract pressures' (http://www.abc.net.au/news/2015-09-12/sawmill-owners-fear-overlogging-impact-in-nsw/6769416)

"Forests that shouldn't be logged any more than every 40 to 110 years are being logged every 10 or 15 years and there's nothing left"

Over logging the Pilliga Forest is a significant concern. If CSG is developed here it will further reduce the timber resources and put the industry at risk. In addition, over logging can severely impact on the number of hollows available for bats such as the long eared pied bat and the number of trees available to koalas. If CSG is developed here it will further stress the animals that are already under threat from logging.

We should be mindful that the Pilliga State Forest represents an important refuge for many fauna species that have lost habitat due to farming. Australia has cleared approximately 70-85% of the coastal and sub coastal vegetation for agriculture and housing. This means any remaining bushland is even more important. It would be far more appropriate to place a CSG development in already cleared land but it seems Santos is largely avoiding this politically charged arena for an easy exploitation of the Pilliga. In Queensland the state forests were the first areas to be developed because State Forests are public land and not subject to landholder negotiation.

4. Water concerns -the Narrabri Gas Project risks precious water sources, including the Great Australian Basin--Australia's largest groundwater aquifer

The Santos CSG development will drill through a recharge aquifer of the Great Artesian Basin and draw water down from a water resource relied upon by rural communities across western NSW. This will involve the extraction over 35 billion litres of salt laden groundwater, much of it in the first five years. This water will be treated and will generate almost 500,000 tonnes of salt waste, for which there is no safe disposal plan.

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.

5. 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.

6. 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.

7. 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.

8. 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.

The Santos CSG development will lead to large deliberate and emissions of methane from venting and leakage, adding to climate change. This has already been an issue for wells in Queensland. Many of the wells I encountered were venting methane, some at dangerous levels which required remediation. This is despite the high standards of well construction.

9. 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.

10. 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.

11. 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.

12. 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.


The NSW government 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 on the Pilliga region.

Yours Sincerely,


Justin Armstrong.


¹SoilFutures Consulting 2014, Great Artesian Basin Recharge Systems and Extent of Petroleum and Gas Leases. http://www.gabpg.org.au/wp-content/uploads/2014/11/GAB-Report1.pdf
²http://www.smh.com.au/environment/santos-coal-seam-gas-project-contaminates-aquifer-20140307-34csb.html
³BirdLife International (2017) Important Bird Areas factsheet: Pilliga http://www.birdlife.org
⁴Marion Carey Doctors for the Environment Australia (DEA), Air pollution from coal seam gas may put public health at risk The Conversation, November 20, 2012
⁵https://www.theguardian.com/science/2014/oct/21/siding-spring-observatory-threat-coal-seam-gas-light-pollution
⁶http://darksky.org/first-dark-sky-park-in-australia-designated/