Narrabri Gas

I am not in favour of this project.
The process of fracking has been shown in the USA to introduce contaminants into the groundwater, causing local inhabitants to have significant poor health. There is also evidence of noxious gases filtering up through peoples' taps.
Assurances were given by mining companies that this would not happen, and denials by those same companies that it did happen. And yet the residents involved were not so affected before the mining started.
Is the NSW government strong enough to honestly investigate such claims here should they arise? I think not.
Therefore I contend that there are too many risks associated with this sort of project, and that the precautionary principle should apply.

I oppose this project for a number of reasons, including:
- We cannot extract more fossil fuels if we are to address climate change, so approving this project would be a grave injustice against future generations.
- Drilling 850 coal seam gas wells through the Great Artesian Basin is a high risk activity that will bring to the surface huge amounts of salt and chemically laden water and threatens farmland and water resources. There is no serious plan in the EIS to deal with the vast quantities of salt that will be generated by this project and I ask that you refuse to approve it unless Santos can demonstrate a genuine beneficial reuse of this salt and not simply dump it in landfill.

I also note that Santos have publically stated that they do not intend to use fracking at this project, but have not ruled it out. If the project is approved (which it should not be) I request that you include a condition of approval which holds Santos to their word by explicitly stating that hydraulic fracturing cannot occur.

Please don't let Santos frack the Pilliga. Our water is precious. Our forests are precious.

Coal seam gas had been proven again and again to be a threat to long term agricultural production. The short term financial gain is not worth the risk to drinking water and the disastrous effect that csg mining can have on the environment. There is nothing more important than water security and cag mining threatens this. The livelihood and wellbeing of thousands of farmers is put at risk when an area is mined in this way. Please don't allow it to go ahead

I strongly object to this proposal. If approved, it would cause serious environmental impacts contributing to climate change and harming the local environment, including the Pilliga and aquifers that are vital to the health of the Great Artesian Basin.

The approval of a large coal seam gas project such as this one isn't justified on environmental, economic or social grounds. Santos's environmental and social impact assessments are inadequate and approving the project would create significant environmental risks, cause social upheaval and create risks to community and public health, all for a project that isn't justified in terms of its contribution to the economy or to meeting domestic energy needs.

In particular, I object to this proposal because:

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 strongly urge you to reject the Narrabri Gas Project.

The damage the project will very probably have on the Great Artesian and the Murray-Darling Basins. These water sources are beyond value to the entire country and should not ever be put at risk by a for-profit company. The native custodians are also opposed - why is it OK to override the wishes of the peoples whose traditional lands it is? Even the local farmers are in massive opposition to this preposterous project.

In addition, Santos has a disastrous and crap record with pollution and should not be allowed to do this work, EVER. Not to mention what effect these works have in contributing towards climate change. And Santos also has no plans in place for what they will do with all the salt produced by their project, minimum 170000 TONS! and possibly up to 42000 tons. Crazy!

There are numerous threatened species within the Pilliga so it's again madness this is even being considered. Why is the almighty dollar worth more than our planet's health and the creatures on it? You can't take the cashola with you, you know. Once the planet it dead you won't be able to spend the stupid money. It makes no sense.

I strongly object to this appalling proposal which makes no sense whatsoever on a full cost environmental accounting risk benefit analysis. The world is rapidly moving to 100% renewable energy which is essential if we are to restrict global warming damage to the temperature rise currently locked in. Gas is not a 'transition fuel', in fact it is a major contributor to global warming at every level, from production to distribution and usage. The CSG industry in particular has a horrific environmental record all over the world and should be banned everywhere.

I am specifically concerned about the risks to the Great Artesian Basin and the Murray-Darling Basin, human health and climate change impacts. I am also concerned that the Gamilaraay Traditional Custodians are opposed to the project, as well as farmers and other local community.

The previous spills and leaks of toxic material bring into question whether or not Santos can be trusted to manage the project safely. The Pilliga is a haven for threatened wildlife and simply cannot be put at risk of damage, given it's significance.

The fact that much of the mineral and gas extraction from mining our precious forests is actually exported speaks to the heart of this issue- are we prepared to destroy our precious forests and native habitats just for the sake of corporate wealth-making, leaving environmental destruction in its path?
This fertile region of the Pilliga needs protection from the destruction of mineral and petroleum extraction, and the historically appalling environmental damage and lack of repair caused by those engaged in such activity.
Once such activities are approved these precious lands will never be the same again.

I object to this project and believe it should be rejected.

The project is not justified: Santos' own coal seam gas export activities in Queensland have caused gas prices to rise and supply to become unpredictable.

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.


This project, if approved, would:
1. Extract 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.
2. Clear close to 1,000 hectares of the Pilliga Forest, fragmenting the largest temperate woodland in New South Wales, home to unique wildlife.
3. 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.
4. Lead to large deliberate and emissions of methane from venting and leakage, adding to climate change.

The project will also 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.

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.

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.

I urge the Government to reject this project and make the Great Artesian Basin recharge off-limits to gas mining.

Signed,

Matthew Joe Sparks

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.
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.
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 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.
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.
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.
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 am opposed to the Narrabri Gas Project for the following Reasons:

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

The Great Artesian Basin and The Murray/Darling Basin are 2 of our most precious water resources. These are our safety net in face of climate change and rapidly reducing water sources all over the planet.
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.
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.
WATER IS LIFE and must be protected.

2. Both The Gamilaraay Traditional Custodians are opposed as are the Farmers and Local Communities.

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.
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.

3. 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 coordination. These impacts have been documented in human populations nearby to existing gasfields in Queensland, Sydney and in America

4. 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. A legacy which will harm humans, flora and fauna.

Allowing CSG in the Pilliga is wrong.

I live in Narrabri.
I work in the gas industry, and so am very familiar to the steps Santos takes in ensuring it meets its obligations. I am also familiar with the rigour employed in the development of the EIS.
This project will have an extremely positive impact on Narrabri, and have benefits for he broader NSW community. A major positive for Narrabri will be the employment opportunities for the school leavers - many of them will be able to get employment with Santos in Narrabri without having to leave town. For those who choose to leave for further studies, there will employment opportunities for them at the conclusion of their studies - either directly or indirectly.
A diversified industry base is essential for small communities like Narrabri to grow and thrive. Lately, there have been many shops in the town close their doors. This project offers the opportunity to reverse that trend.
I ask that any conditions of approval that are placed on Santos be based on risk - any not unrealistic simply because it is the gas industry. By all means condition the development to ensure environmental protection, but do not place conditions based on perception. Particular reference should be paid to ensuring conditions are realistic, measurable, clear, certain and do not lead to a conditional approval. Do not ask Santos to do anything beyond what anyone else in the community would be required to do.

I say no to the narrabri gas project.
The region is a recharge zone for the largest aquifer in thd world. The narrabri gas project has to many unknowns and risk contaminating the aquifer. I also say no due to the area being koala habitat and the other endangered/threatened species of the area will be put at risk.

I object to this project and believe it should be rejected.

This project, if approved, would:
1. 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. clear close to 1,000 hectares of the Pilliga Forest, fragmenting the largest temperate woodland in New South Wales, home to unique wildlife.
3. 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.
4. 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.

RESPONSE TO NARRABRI GAS PROJECT - ENVIRONMENTAL IMPACT STATEMENT

I submit this comment on the basis of twenty years' experience as a researcher, consultant and business owner in the fields of audience research, community consultation and evaluation. Much of this has specifically related to government programs and agencies.
The following comments are specifically focused on the Community and stakeholder consultation.
The method for approaching this report of community and stakeholder consultation is to answer three questions;
* What systematic methods have been used, to attend to and recording specific concerns and views of a range of community members?
* What language is used to describe this process?
* What evidence is there of two-way communications over time that address community issues in their own words and use communication appropriate to them?
* What have the proponents learned about community concerns?
* What evidence is there that proponents now respond effectively with communities and will continue these practices when concerns arise, in order to solve issues for the communities' benefit.
1. Systematic methods and recording of specific concerns.
The aim of this project is stated as, `to better understand and address issues in the early stages of the project so that community interests can be considered during the planning process' p9-6).
This report uses a definition of `stakeholder' and classifies three levels of stakeholder impact (Table 9-1) that provides a systematic beginning. The report in its content ignores both of these initial, definitional approaches. The three levels may have pointed to priority groups and issues that were most important but instead the list of seven stakeholder groups (Table 9-2) are prioritised by conventional, corporate concerns external to the Pilliger project. There's a similar organisational concern to `integrate' integration with environmental assessment(Fig9-1) and this overtakes the community focus from the beginning. The outcome is a list of issues and the organisations `responses' that are clearly directed to government, not community (Table 9-6).
There is no mention of the recording of information through the process or the way it was compared and analysed to describe community concerns.
2. Language Used
The terminology and defensive references to trails of other documents demonstrate the bureaucratic purpose of this whole consultation. Some links were audited. They ended in an undertaking to complete a requirement in the future or at a long list that was not directly relevant and that required searching (for example the `answers' at https://narrabrigasproject.com.au). Engineering terms are used where description of the questions people asked, and what possible options might be considered alongside them, would have greater authenticity. The Consultation Plan was created for the `delivery of consultation activities' (p 9-5). This mechanistic, technical, regulatory language is a feature of most pages and content of the report. It does not use language that speaks to or about communities. The latter would be evidence for actually engaging with them.

3. Evidence of two-way communications that address community issues in their own words

There is a half-page of the report that does use appropriate communication terminology and stands out as an example of what could have been achieved in this EIS. On page 9-10 the opportunity for the community to learn and the proponent to capture and respond to issues is described. This is the only actual example of two-way process in the report. The three examples are listed, in quotations that imply someone asked this question. The real responses to these issues are then given in plain language. The issues are very specifically grounded in the Pilliger. Someone knew what they should be doing here and how to do it.

4. What have the proponents learned about community concerns?
Most of the report is taken up with a list of media, stakeholders and technical/regulatory references. Reading the report has the effect of silencing or denying the kinds of concerns that no doubt were raised consistently across groups. Indeed, the expression of concerns by protest groups is explicitly ignored in this report. The concerns of major groups such as Lock the Gate, and local farmer groups are consistent public expressions of concerns and one of the best sources of information. They have run alongside the work of santos for many years. A refusal to listen to these groups, who overlap with the ither defined stakeholder groups, is a great weakness of this report. They have excised communities expressing themselves in the public domain.
5. What evidence is there that proponents now respond effectively with communities to solve issues for the communities' benefit.
Curiously, one half-page speaks of real issues, actual people and very good responses by Santos. This is the only part of the report that gives any confidence that Santos will be able to work alongside the communities in future. The report gives no confidence that Santos sees local people as the most valuable source of knowledge and collaboration they could possibly have. This is shown most clearly in the lack of specifics about the concerns of indigenous people. They don't even name the particular groups with whom they have talked. Nor does this EIS note that indigenous people are opposed to their proposal.
This is no basis for confidence by government that Santos will not entirely disrupt the social relations of a community, without seeing their impact and without being able to foster any of the community relationships that this major new industry must have to succeed over time.
Dr Patricia Gillard
Coppice Research
22 May 2017

I believe the project is potentially damaging to underground aquifers and do not have faith that decommissioned wells will be permanently structurally sound.

Also have doubts the gas is needed and believe renewable energy projects would be a better alternative.

I hereby object to the The Narrabri Gas Project and declre my opinion that it must not be granted permission to proceed. The Narrabri Gas Project severely risks precious water sources, including the Great Australian Basin--Australia's largest groundwater aquifer. Moreover, The Narrabri Gasfield poses a real risk to our two most precious water resources: the Great Artesian Basin and the Murray-Darling Basin. 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.

2. The Gamilaraay Traditional Custodians are opposed to this project because 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.

3. 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.

4. 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.

5. The Pilliga is a haven for threatened wildlife
The Pilliga is one of 15 nationally listed `biodiversity hotspots' and is vital to the survival of threatened species like the Koala, Spotted-tailed Quoll, Black-striped Wallaby, Eastern Pygmy-possum, Pilliga Mouse and South-eastern Long-eared Bat. The forest is home to over 200 bird species and is internationally recognised as an Important Bird Area². The Santos gasfield would fragment 95,000 hectares of the Pilliga with well pads, roads, and water and gas pipelines--damaging vital habitat and threatening the survival of endangered species.

6. 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.

7. 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.

8. 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.

9. 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.

10. 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.
- See more at: https://www.wilderness.org.au/articles/final-push-pilliga#sthash.s4AlXziG.dpuf

I am extremely worried about the risk to our groundwater. The compounded impacts of mining for coal and gas in the Great Artesian basin are high risk activities. The risks to groundwater are too high given the nature of Australia as a dry continent.

At a time when we should be working towards reconciliation with Australian Indigenous people, it seems unbelievable that this project would go ahead without the support of the Gamilaraay people.

The fact that farmers and local community are against this project and such community opposition should be listened to.

I am also greatly concerned about the environmental risks associated with spills and toxic water leaks. Santos has a poor track record and i see no need to risk environmental and human health.

I object to the proposed Narrabri Gas Project. I object with a passion. It is totally outrageous to risk the integrity of the Great Artesian Basin in this driest continent on earth. The sandstone recharge area underneath the Pilliga forest is vital, it has the highest recharge rate. Reduction in groundwater pressure with the removal of water on the scale proposed by the gas field could have disastrous effect across the entire Basin. It is crazy to risk it. It is also totally inappropriate to risk polluting the Murray Darling Catchment with contamination from drilling fluid spills and the salty water from the bores. The creeks of the Pilliga forest flow into the Namoi River
Based on the existing Pilot Project with over 20 reported spills and leaks of contaminated water from the CSG production it is clear that Santos is not competent to manage an industrial scale gasfield, particularly in such an irreplaceable area with such precious assets.
Futhermore, the state of NSW would be presented with a drastically undesirable problem, piles of salt.There is no solution proposed for the disposal of the hundreds of thousands of tonnes of salt that would be produced if this project went ahead. It is not a solution to have an accumulation. That makes it a toxic problem.
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 Area. The Santos gasfield would fragment 95,000 hectares of the Pilliga with well pads, roads, and water and gas pipelines--damaging vital habitat and threatening the survival of endangered species.
The Pilliga forest is of far greater value as habitat for the 25 nationally listed and 48 state-listed threatened species of the largest intact woodland in eastern Australia than as an industrial gasfield. There is no place for projects like this in a future of a safe climate.
Global warming can only be kept below two degrees if at least 80% of our fossil fuels remain in the ground. 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. CSG is not a growth industry. It is now very clear that it's not a transition fuel. We must transit straight to a renewable energy based low carbon future, a gas industry only adds to our problems. It does not help solve them.
The opposition to the industrialisation of the Pilliga forest is overwhelming. The Gamilaraay Traditional Custodians are opposed to the destruction of this country which is rich in their culture. They are supported in their opposition by the broad community, including farmers and the wider public who appreciate the importance of the Pilliga forest to continental ecosystems functions. Much protest action has already occurred. It would undoubtedly continue. This project does not have a social licence.
The environmental impact statement evidences that the potential impact on water is of major concern. The potential impact on fire risk is also a grave concern. A plan to flare off methane, even on total fire ban days, in the fire prone cypress pine and ironbark woodlands of the Pilliga is simply crazy. Given all the risks in our uncertain future of global warming the proposed project is simply crazy.
The proposed Narrabri Gas Project should be rejected.