Narrabri Gas

This country needs to stop thinking about short term gain and think about what the side affects are.
Much of the gas taken from the ground is only taken out of the country anyway with Australia making minimal money. We are the Second biggest exporters of gas and minerals with a 500 Billion det and still climbing.
I just see this as more raping of our land.
This area and surrounding has one of the largest underground aquifers and we have no idea what this mining will do as there is not enough research been done.

No Coal Seam Gas mining. It has not been proven to be safe. The many parts of the world that have done CSG have seen issues with aquifers and water tables. The risk is too high and a lot of the country's ability to feed its people and be able to export is dependent on the country's ability to farm. This cannot be compromised.
Besides it is high time to move to renewables. Gas is not a renewable form of energy, it is on par with coal.

Public Submission Narrabri Gas Project

To whom it may concern,
I, Yodit Ackerman, object to the Narrabri Coal Seam gas project.
This project is set to remove 37.5 GL from the Great Artesian Basin. The importance of this resource to our environmental and agricultural health cannot be understated. As we have known since the 1900Ã,Â's without careful regulation of its use the basin can quickly become depleted. Santos has admitted that this project will significantly deplete the aquifer in the projects early years, contributing to a trend of significant water drawing the coal seam gas industry has been responsible for in recent years. I do not find this acceptable.
Of even greater concern is the high likelihood of contamination. Santos has proposed to drill 850 wells, to frack each of these water and chemical additives are pumped at high pressure to break the rock, fracturing the underground coal seams. This toxic liquid must them be removed and disposed of, a lengthy, costly and complex process. In multiple report the United Nations Environmental Program has warned of the dangers of this unconventional gas exploration. There is a high risk that the toxic chemical liquid used to frack the land will escape into the Great Artesian Basin, contaminating the worldÃ,Â's largest aquifer which we as Australians depend upon to support our farming industry. The CSG industry has additionally not shown itself to be trustworthy in following through on clean up and rehabilitation projects already existing in Queensland.
There is growing evidence that CSG projects seriously damage the health of those living in the area. The Government must insist that Santos conduct a proper health impact assessment including modelling exposure pathways, reviewing literature and engagement with the Narrabri community.
The Pilliga is a site of cultural, social and spiritual significance to the Gomeroi/Gamilaraay people. Complete disregard for the opinions of our first nations people is unacceptable, especially in a country which has already caused so much damage to its Indigenous people
I hope these concerns are taken seriously, especially given that Santos has no social license to operate by being at odds with the entire population and government of Australia by operating on a 4 degree warming business plan.
The Australian people stand to lose to much more than we could gain from such a reckless project which is set to harm the health of local residents, famers, animals and our natural environment.
Thank you for your consideration of this submission, kind regards,
Yodit Ackerman

I wish to object to the Santos Gas Fracking proposed wells of any number in the Narrabri Project. Water, is free, it is not for sale for corporations to steal from our entire countries' Water Supply.

All inhabitants of this land, be they human, animal, plants, own this Water Resource, this is not for sale to purchase.

It is toxic, destructive mining, that destroys our EARTH forever!

You have no right to do this in any sense of logic, reason or justice.

I object outrightly to any kind of mining whatsoever, electricity plants, or associated infrastructure to support mining.

Yours Sincerely
Liz Masterson

As a local resident, I object to the Narrabri Coal Seam Gas Project for a number of reasons.
First, because of its effect on the local groundwater and the Great Artesian Basin. The coal seam needs to be dewatered to release the gas, which will affect the recharge to the Great Artesian Basin - the life blood of the agricultural industry and the local communities. There is also the likelihood of surface water contamination (which we have already experienced) and the real threat of ground water contamination through faulty wells. For example, there have been more than 20 spills and leaks so far, including the leak at Bibblewindi, for which Santos was fined. Santos could face a major corporate risk through the likely contamination of bodies of water and water ways (such as the Bohena Creek) in this region.
Second, there is no need for this project: Santos and the other large gas companies have caused the gas shortage in Australia by overselling Queensland gas. Producing gas from the Narrabri field is particularly expensive and not necessary if gas was more closely managed by the Australian government so that it benefited Australian industry and Australians.
Fossil fuel needs to stay in the ground if we are to have any chance to stop catastrophic climate change, which would be a major economic burden for us all. The government would be better off investing in more renewable energy.
It will fragment and damage the Pilliga Forest, the largest temperate woodland in eastern Australia, home to 900 plant species, over 230 species of birds, at least 15 species of frogs and 40 species of native mammals (including 6 species of bats). Many of these plants and animals are threatened or endangered.
I request that the Government reject this project and support the Great Artesian Basin and local communities and livelihoods.

I vehemently object to this project as it is unsustainable environmentally, socially, culturally and economically, and is completely unethical, for the following reasons:

* It risks essential water sources needed for farming and providing food for current and future generations, including the Great Australian Basin, Australia's largest groundwater aquifer.
* 96% of farmers oppose CSG due to air and land pollution, as well as loss of crucial water - healthy farmland is essential for the Australian economy.
* The traditional langowners, the Gamillaraay, are strongly opposed as this would destroy sacred sites.
* Dangerous materials released released into the environment by CSG have an adverse effect on human health such as eye, nose and airway irritation, headache, nausea, dizziness and loss of coordination.
* Santos has a history of spills and leaks, including uranium levels 20 times high than acceptable in drinking water, barium, arsenic and aluminium. Santos has shown itself to be unable to meet acceptable environmental standards.
* There is no proposed method of dealing with the thousands of tonnes of salt waste, leaving a toxic legacy for future generations in NSW.
* Methane flare stacks up to 50m high would be running constantly, even on total fire ban days, leading to severe increased risk of bush fires.
* It would damage vital habitats of endangered species such as the koala, seriously damaging biodiversity.
* This would seriously contribute to dangerous climate change - CSG fields contribute to climate change through the leakage of methane during the production, transport, processing and use of coal seam gas.
* The Sliding Springs Observatory, the nation's premier optical astronomical observatory is at riski due to light and dust pollution.

This project is therefore morally reprehensible, and must not go ahead, for the sake of the environment, Indigenous landowners, people's health, and the economy.

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

22nd of May, 2017


To whom it may concern,

Thank you for the opportunity to comment on the proposed Narrabri Gas Project.

I object to the Gas project and these are my personal reasons why:
* I would like to acknowledge and support the views of the traditional custodians of the land the Gamilaraay people in their stand to look after the Pilliga forest.
* The concerns of the community in regards to changing land use and water and soil protection are outlined in the 2016 NSW Department of Primary Industries and University of Newcastle Research Paper -`Local Attitudes to Changing Land Use- Narrabri Shire'.
* The growth and development of the Narrabri Shire's is strongly tied to the success of its agricultural industries which rely heavily both on surface water from the Namoi River and ground water from the Artesian Basin. Agriculture from the Narrabri Shire contributes $185.5 to the national economy annually. The #saveweewaa campaign has been wonderful in highlighting just how important water is for our shire, livelihoods and existence.
* The proposed SANTOS Gas Project involves drilling 850 wells through the recharge area of the Great Artesian Basin, extracting water and gas from below. Not only the Narrabri Shire, but 22 % of Australia relies on this water source.
* Isolated stresses put on the Artesian Basin outlined in the EOI do not consider other pressures being implemented elsewhere in Australia and the combined load and effect this will result in.
* The gas extraction process involves drilling 1 km or longer vertical wells into the coal seams (approximately the length from the post office to the RSL along the main street of Narrabri) which are then steered horizontally along the coal seams. Although we have skilled people in the community proposing the job, it is best accepted in the CSG industry that any geological model will contain errors and need to have contingencies to deal with variances when they appear.
* This project has already caused over 20 toxic spills and leaks, of which many SANTOS tried to keep hidden from the community. There is also no waste disposal plans being offered for the thousands of tonnes of salt waste generated during the project. Peak salt production will be 115 tonnes (two and a half B-double truckloads) per day.
* When a CSG project ends, the wells are plugged with concrete and steel and must last forever. Long term monitoring and efforts that need to go into protecting our sources from any sorts of spills are time consuming, expensive and long term impacts are generally unclear and glazed over. It is proposed that 50 % fail before being shut down. Personally, it would not matter if this figure was a 1 % risk. Yes- it IS impressive technology. However what happens if there ARE failures? This is a risk that the community is not willing to pay and do not believe that the appropriate mitigation processes have been actioned.
* Yes, the <200 ongoing job boost could be great for the town. However, a lot could be said about supporting existing businesses within the community. Internet users living in remote locations of Australia have a high incidence of online shopping ~ 70 % making retail in our town very hard. In Australia, the renewable energy industry is creating more jobs than coal, however this is an option our shire has yet to explore. Moree solar farm (150 jobs) is another good example of a new industry being explored. The creation of this current industry also threatens to hinder the livlihoods of farmers in the region as well as those that work at the renowned Australian Telescope. The light pollution from flares, compressor stations and the water treatment plant will limit the visibility of the night sky. If jobs are the cry, there are a lot of other ways we can support our community jobs without risking others.
* SANTOS does not have a reputation as an environmentally reliable company with issues on Port Curtis Island with flares and contamination resulting in amendments to the EIS needing to be made. This seems consistent with the current EIS where the detail provided of where the gas wells and pipes will go is not mentioned.
* Vegetation plays an important role in filtering the water before it enters the water table. Removing vegetation and creating more impermeable surfaces is extremely important for water quality however, although remediation efforts will take place, the short and long term impacts of affecting over 95 000 hectares in this project and the impacts on water quality have not been significantly explored.
* The likely substantial escape of methane emissions (the most potent greenhouse gas) are also not explored in the EIS. The NSW Government has committed to moving towards strong climate resilience and protecting the Australian public and wanting to be a leader in climate change. The Victorian Government has banned the production of CSG in the state and we suggest that NSW does the same. Granting industry that is polluting, not reducing the amount of greenhouse gases is not sustainable.
* Water is our livelihood. Our Life. We cannot drink gas.
* I request that the Government insists that SANTOS conducts a proper long term economic and health impact assessment for the Narrabri Shire including modelling exposure pathways. In Narrabri, there are concerns that the project will have a negative long term impact on air quality, cost-of-living, the labour and housing markets. The EIS only provides very narrow approximate impacts, not accurately stating the exact implications of the project.

Thank you for your consideration of my submission.

Yours sincerely,

Julia


Julia Barnes
Environmental Scientist
Educator
[email protected]

Fracking has been proven to be incredibly detrimental both to people and environment. Time to move to renewables!

This is a submission to the Narrabri Gas EIS.
I object to this project and believe it should be rejected.
* 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.
* The high possibility of pollution caused by chemical use in the wells and pumped into holding ponds can affect our groundwater, waterways and wildlife. If the waterways are polluted by pond leakage and flooding from heavy rainfall this would cause irreparable damage, not only to the immediate areas but further downstream. This leakage and pollution has already been an issue with this project. Wildlife are also at risk if they drink from these ponds.
* It will clear close to 1000 hectares of the Pilliga Forest, fragmenting the largest temperate woodland in New South Wales, home to unique wildlife.
* 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.
* It will lead to large deliberate and fugitive emissions of methane, adding to climate change.
* It is not justified: Santos' own CSG 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 allowing Santos to inflict more environmental, social and economic harm.
* 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.
* Flaring, which is already occurring and will continue to occur, is extremely dangerous in bushfire prone areas. We have very strong laws on fire restrictions and have experienced massive fire events in bushland and farmland yet this practice is still happening, risking the lives and livelihoods of many people.
* Coal Seam Gas is harmful to health. Neither the NSW Government nor Santos have investigated or dealt with the serious health effects of CSG now appearing in peer-reviewed research in the United States. The health of the community should be the Governments main priority.
* The concerns of the majority should become the concerns of the Government - in a democracy.
On a more personal note, groundwater is our sole source of water - for drinking, washing, stock and garden. If this water is depleted or poisoned, either through activities further afield at Narrabri or from further gasfield approvals in our area, our health and livelihood will be affected. Has the government or Santos offered guarantees that drawdown and contamination will not happen? On the contrary, it has been admitted drawdown is basically certain and contamination has happened both here and overseas.
I urge the Government to reject this project and make the Great Artesian Basin recharge off-limits to gas mining.

This is a submission to the Narrabri Gas EIS.
I object to this project and believe it should be rejected.
* 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.
* The high possibility of pollution caused by chemical use in the wells and pumped into holding ponds can affect our groundwater, waterways and wildlife. If the waterways are polluted by pond leakage and flooding from heavy rainfall this would cause irreparable damage, not only to the immediate areas but further downstream. This leakage and pollution has already been an issue with this project. Wildlife are also at risk if they drink from these ponds.
* It will clear close to 1000 hectares of the Pilliga Forest, fragmenting the largest temperate woodland in New South Wales, home to unique wildlife.
* 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.
* It will lead to large deliberate and fugitive emissions of methane, adding to climate change.
* It is not justified: Santos' own CSG 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 allowing Santos to inflict more environmental, social and economic harm.
* 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.
* Flaring, which is already occurring and will continue to occur, is extremely dangerous in bushfire prone areas. We have very strong laws on fire restrictions and have experienced massive fire events in bushland and farmland yet this practice is still happening, risking the lives and livelihoods of many people.
* Coal Seam Gas is harmful to health. Neither the NSW Government nor Santos have investigated or dealt with the serious health effects of CSG now appearing in peer-reviewed research in the United States. The health of the community should be the Governments main priority.
* The concerns of the majority should become the concerns of the Government - in a democracy.
On a more personal note, groundwater is our sole source of water - for drinking, washing, stock and garden. If this water is depleted or poisoned, either through activities further afield at Narrabri or from further gasfield approvals in our area, our health and livelihood will be affected. Has the government or Santos offered guarantees that drawdown and contamination will not happen? On the contrary, it has been admitted drawdown is basically certain and contamination has happened both here and overseas.
I urge the Government to reject this project and make the Great Artesian Basin recharge off-limits to gas mining.

Overall, the environmental risks associated with this project seem to outweigh the potential economic benefits.

- the impact on ground water
- the impact on rivers that feed the Murray Darling Basin
- fragmentation of the Pilliga Forest as a result of the sheer number of wells being proposed (and its impact on wildlife corridors).

Thanks you
Sam.

The EIS for the Narrabri Gas Project is misleading due to its superficial consideration of bushfire risk. Chapter 25 of the EIS (Hazard and Risk) considers bushfire but suffers two major flaws: i) it does not recognise the increased likelihood of bushfire igniting as a result of the operations and ii) it does not consider the impact of the Asset Protection Zones and fuel reduced zones.
Likelihood of Ignition
The new 430 km road network and the people travelling along them will bring increased risk of bushfire ignition through various means including tail pipe sparks, discarded cigarettes and deliberate ignition (arson). The relationship between roads and bushfire ignition is well recognised both in Australia (Penman et al 2013) and everywhere else where spatial patterns of ignition have been studied (Romano-Calcarreda et al 2008; Narayanaraj and Wimberley 2012). 41% of bushfire ignitions in NSW are deliberately lit (Collins et al 2016) and even measures taken by the proponents to reduce accidental ignition will not address this issue. Predicting changes to bushfire patterns is a difficult and imprecise task, but given the huge increase in the road network, it is conservative to assume that both the number of bushfires and the area burnt is likely to double in the project area as a result of the proposal. It could be far worse than that.
Despite this obvious increase in risk, and with no argument presented as to why, the EIS states "the likelihood of bushfire ignition from a project related activity was remote" (Chapter 25, P1). This is completely misleading.

Fuel reduced areas
The EIS states (Chapter 25, P8) that they will develop a Bushfire Management Plan which will include "asset production zones and fuel reduced zones" (notice spelling mistake which should read "asset protection zones"). Asset protection zones, as recommended by the Rural Fire Service are usually 50 m from the edge of an asset (in this case infrastructure and roads) where shrubs and most low lying fuels are removed. Given that the road network will be 430 km long, this means destroying plants in 2100 ha of forest. I presume fuel reduced areas refers to a Strategic Fire Advantage Zone, which by RFS guidelines is usually 500 m deep and involves regular prescribed burning treatments but not the mechanical removal of any plants. Also given the length of the road network, this equates to 43,000 ha or 45% of the project area being treated on a prescribed burning rotation that is probably too frequent to sustain many of the native plants that live there. This includes the main tree species in the Pilliga that show mortality rates of ~20% for the larger trees in response to a single prescribed burn (Parnaby et al 2010).
Clearly the impact of fuel treatments to reduce the likelihood of bushfire could be huge, and the EIS glosses over this issue in one bland sentence that does not even recognise the problem. This is totally inadequate.

References
Collins, KM, Price, OF, Penman, TD (2016) Spatial and temporal patterns of fire ignitions in southeastern Australia. International Journal of Wildland Fire 24, 1098-1108.
Narayanaraj, G, Wimberly, MC (2012) Influences of forest roads on the spatial patterns of human- and lightning-caused wildfire ignitions. Applied Geography 32, 878-888.
Parnaby, H, Lunney, D, Shannon, I, Fleming, M (2010) Collapse rates of hollow-bearing trees following low intensity prescription burns in the Pilliga forests, New South Wales. Pacific Conservation Biology 16, 209-220.
Penman, TD, Price, OF, Bradstock, R (2013) Modelling the determinants of ignition in the Sydney Basin, Australia: implications for future management. International Journal of Wildland Fire 22, 469-478.
Romero-Calcerrada, R, Novillo, CJ, Millington, JDA, Gomez-Jimenez, I (2008) GIS analysis of spatial patterns of human-caused wildfire ignition risk in the SW of Madrid (Central Spain). Landscape Ecology 23, 341-354.

The drilling of 850 wells will cause vast damage to the wilderness of the Pilliga, from the access road and the gas pipelines and other associated infrastructure.
The waste generated from the CSG operation will be huge and toxic. It is not clear where it will be treated or how it will be disposed of.
The fugitive emissions from CSG are huge, far greater than conventional gas drilling, or even fracking. This is not a sensible way to obtain gas.
Extracting vast quantities of groundwater will greatly impact upon groundwater-fed ecosystems and other less intensive groundwater users.
Yours sincerely,
James Barrett

I am opposed to the proposed gas field on a number of counts. One being the harm that will be caused to the great artesian basin from the extraction of the gas, the amount of contaminants that would leak and affect surrounding land and waterways. The second reason is that we dont need to extract gas but instead should be already transitioning to a clean energy future without the use of fossil fuels, that are so destructive to the earths atmosphere. Please dont subject humanity to a horrible 'mad max' style future.

The Narrabri Gas Project should not proceed due to the likely irreversible damage to the Artesian water that so much of our country relies on. Any damage to the aquifers or contamination of the water will result in the closing up of grazing country in the western division which relies on this water for stock and domestic survival. Australia has an irregular rainfall pattern and bores are a reliable way of maintaining constancy of supply.

It is of great concern that the Narrabri Gas Project Environmental Impact Statement makes no reference to the risk of damage to the artesian water supply. The Groundwater and geology (Chapter 11); Hydrology and Geomorphology (Chapter 13) and Cumulative Impacts (Chapter 29) chapters discuss the extraction and groundwater activities, the risk of contamination of water and runoff events, yet fail to consider at all the risk that the method of gas exploration and extraction poses to the long term security of the artesian water. In Australia, with relation to alternate water sources, there is no Plan B - rainfall events are not enough to maintain the health and sustainability of environmental and food production requirements.

I strongly object on environmental and water impact grounds to the approval of this project. The risks are far greater than the economic returns estimated.

I object to the development of coal seam Gas fields. This production is of short term gain for long term pain. Not unlike asbestos mining, the extraction of water from this depth can only be monitored and results proven many years after the process has been found to be advisable or not. Results of independent chemical sampling in atmosphere and water tanks has proven there is increased influence of lead and other heavy metals in the Dalby / Tara area which are unacceptable where we are producing food and fibre for the world. Science can be used as guidance only as it is only able to produce results of the questions asked and all theory's are flawed. Our water is our life and any change will mean the end of agriculture as we know it,

'The Pilliga' is a precious natural resource, not only for it's flora and fauna, but for the future of our environment and people.
Any exploration is a backward step.
Please keep it intact.
Jan Kay

Get it out of the Pilliga - it affects not just this forest the size of Sydney but surrounding farmland, water supplies and the dark sky necessary to our national observatory Siding Spring.

please do not allow or approve fracking in the piliga scrub or anywhere in nsw

Long term gas well integrity due to ground movement causing cracked concrete allowing concrete cancer is a major concern.
This has the potential to contaminate groundwater decades into the future.
The economics of natural gas as a transition fuel between coal and renewables has also been disproven. Wind or Solar with storage is now cheaper than gas for electricity generation.
If the world is to remain within 1.5 degree warming as agreed at the Paris climate summit, it has been stated that no new fossil fuel projects should proceed.
The NSW governments management of compliance of resource projects within this region has been less than satisfactory and I do not believe this standard will improve with the approval of the Santos project.
The Maules Creek Coal Project EIS grossly underestimated the noise, dust and light pollution that now exists within the Maules Creek valley and the local residents are now suffering as a consequence.
I do not believe that the NSW government nor Santos are capable of best management practices that estimate and mitigate the numerous potential negative consequences of this project and therefore I strongly object to it's approval.