Narrabri Gas

I am making a submission on the Narrabri gas Project. I object to it and I request that the project be rejected

I have visited the Pilliga Forest many times have always been struck by it's vast, wild, beauty that extends to the horizon. A unique and special place that is worthy of lasting protection.

If this project was approved if would be devastating for not only the Pilliga Forest but for the directly surrounding rural communities. The Pilliga forest is also crucially important to the spiritual, cultural and social life of Gamilaraay people of great and this project has the highly likely potential to cause more trauma to the regional Aboriginal community.

For the 35 billion litres of salty groundwater extracted, 500,000 tonnes of salt waste will be produced - for which Santos has provided no safe disposal plan. When extracting the gas, Santos plan to drill through a recharge aquifer of the Great Artesian Basin, Australia's largest and oldest underground water system of which countless communities and ecosystems across the continent depend upon. The risk of harming this water source is too great. The methane emissions of the project will be significant and will contribute to climate change, an already globally devastating process.

The project plans to clear around 1000 hectares of the Pilliga Forest. This would greatly fragment the forest, creating a huge loss of habitat and many other ecological impacts. As the largest temperate forest in New South Wales, the Pilliga is an important stronghold for the Koala. Koala numbers in NSW are rapidly falling and the species is on track to becoming endangered within a few years. Koalas cannot afford any further loss of habitat. The gasfield will clear breeding habitat for the Pilliga Mouse, a species which lives nowhere else.

In summary, this risks of this project far exceed any benefits (of which I can see none), therefore, I request the project be rejected.

These Wilderness Society points cover everything I wish to say.
1. The Narrabri Gas Project risks precious water sources, including the Great Australian Basin--Australia's largest groundwater aquifer
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
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.

The Narrabi forest is too important to despoil in this way.

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

Dear Sir/Madam,

Objection to the Narrabri Coal Seam Gas Project (SSD 6456)

The Pilliga Forest is a significant natural area as it is the largest temperate woodland remaining in Australia. It comprises woodlands of Narrow-leaf Ironbark, Broad-leaf Ironbark, Pilliga Box and Bimble Box, as well as many other plant communities including Brigalow, Green Mallee and Broombush scrublands that have been cleared from other parts of the Central West of NSW.

The Pilliga woodlands are home to more than 900 plant species, including at least 12 rare and threatened plants. There are 14 frog species, 32 mammals (including 12 bats) about 50 reptiles and over 200 bird species. Pilliga woodlands support 22 threatened animal species (Glossy Black Cockatoo, Regent Honeyeater, Gilbert's Whistler, Painted Honeyeater, Turquoise Parrot, Barking Owl, Masked Owl, Malleefowl, Square-tailed Kite, Black-breasted Buzzard, Bush Stone Curlew, Eastern Pygmy-possum, Squirrel Glider, Koala, Black-striped Wallaby, Rufous Bettong, Pilliga Mouse, Greater Long-eared Bat, Yellow-bellied Sheathtail Bat, Little Pied Bat, Large-eared Pied Bat, Eastern Cave Bat).

Given the above information it is not a suitable place for coal seam gas (CSG) field development.

I feel that it would be disastrous to fragment and degrade the Pilliga's woodlands with CSG infrastructure and roads (as proposed by Santos). A network of intersecting roads and pipelines, water extraction, lines of wells, chemical intrusions, structures, work sites of the proposed gas field will bring destruction to the Pilliga and ruin the Pilliga woodland ecosystems.

In addition the Pilliga forest is of great importance to Australian beekeepers. They are facing difficulties on many fronts and this CSG development will be another blow.

The Great Artesian Basin (GAB) aquifers have intake areas in the Pilliga forest that must be protected. CSG development can play havoc with our underground waters.

Recharge of the Pilliga aquifer will become impossible due to the proposed quantities of water extraction required for coal seam gas (CSG) development. The GAB and the integrity of the intake bed strata must take priority over CSG production in the Pilliga. Fracking of the coal seam will compromise the GAB strata. It fracking is a contingent part of the proposed project, and Santos must be refused consent.

Damage to the GAB will have dire consequences, such as loss hydrostatic pressure in the artesian wellheads of the GAB. Water is gold for the agriculture and grazing Central West NSW and region is heavily dependent upon access to the GAB. The GAB is also essential to the survival of unique mound spring ecosystems located further west. Any disruption to the fine balance of groundwater and its replenishment has ripple effects well beyond calculation or modelling by Santos. The regional economy and ecology are dependent on the GAB and the GAB must not be jeopardised.

After considering the environmental constraints of the Pilliga forest and hazards related to CSG production and the GAB, I request that the NSW Department of Planning and Environment recommends refusal of development consent of this Santos proposal in the Pilliga.

There should be No CSG infrastructure in the Willala Wilderness Area; areas of old growth woodland must be protected, as well as all endangered ecological communities, and threatened plant and animal species habitats. Adequate protection of these and other heritage values of the Pilliga woodlands will be impossible if this CSG proposal is approved.

I also believe that the natural dark night sky will be compromised by light pollution from gas flares and CSG lighting infrastructure. Dark night skies are essential for the effective operation of the internationally renowned Siding Springs Observatory located nearby.

The CSG industry has proven itself unable to effectively rehabilitate the very extensive areas it has mined, leaving many clearings and infrastructure in forests and farmlands across NSW and Queensland. The industry has shown itself to be incapable of removing its fence lines, tanks, dams, quarries, access roads, accommodation and clearings should also be removed from the mined out areas. Santos must be refused development consent.

I hope you will give my representations serious consideration and I thank you for the opportunity to comment.

Yours sincerely,

Kim Ward

I object to the Narrabri Gas Project. The massive, permanent destruction that has already resulted from fracking should be causing all those who care for the future of Australia to be alarmed at the lack of conscience of those approving this venture.
a) The Narrabri Gas Project risks precious water sources, including the Great Australian Basin--Australia's largest groundwater aquifer
b) 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
c) 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.
d) 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
e) The Pilliga is a haven for threatened wildlife
f) Coal seam gas fuels dangerous climate change
g) The nation's premier optical astronomical observatory is at risk
h) Human health is compromised by coal seam gas
I) Thousands of tonnes of salt waste will result from the project
j) Risk of fires would increase throughout the Pilliga's tinder-box conditions
I find it unconscionable that a government can support a practice that is so terribly destructive to Australia. That politicians ignore the wishes of the majority of Australians in favour of big business and put the future welfare of Australia and Australians at risk in so many ways. If there are any honest politicians, please put a stop to this criminal activity that is stealing peoples' livelihood and their future.

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, which has now led to many states banning the process.

This project is environmental vandalism at its best.Displacing animals and ruining valuable ecosystems for the sake of mining is just blatant stupidity.I object very strongly to this project and it must be stopped.

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

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.

Our organisation strongly objects to the proposal to develop and industrial gasfield in the Pilliga forest and surrounds.
We support the submissions of Lock The Gate, the Wilderness Society and the local groups on the ground such as People for the Plains.
The community is overwhelmingly opposed to this proposal.
There is sufficient evidence that fracking will damage the stability of the aquifers and in particular the Great Artesian Basin.
This area is a recharge area for the GAB. Contamination by fracking fluids and the movement of contaminated waters between different aquifers could threaten the ability of the GAB to supply water for irrigation and communities into the future.
There is no way to permanently seal a drill site. All pipes decay sooner or later. This will be yet another environmental catastrophe that we bequeath to future generations.
The industralisation of the landscape will have a detrimental effect on the threatened fauna and flora of the region. Animals such as the Pilliga Mouse and the Koala will be less likely to persist in the landscape.
Most of the traditional owners, the Gomeroi are opposed. They are distraught at the destruction of their sacred sites and traditional lands.

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

This is a submission to the Narrabri Gas Project EIS.

I object to this project and believe it should be rejected. Australia can focus on more sustainable sources of energy,as well as less destructive ones.


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.

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

Signed,


Yours sincerely,
Conrad Loten
8 Ocean St, Merewether NSW 2291, Australia

The information around coal seam gas mining which uses an antiquated and environmentally destructive process for the extraction of gas, is unacceptable now and in the future. Renewable energy for the future now before it is too late for humanity and the future generations to come. Please be mindful.
There are other sustainable practices which are cleaner and less damaging for ecosystems. Start now.

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


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/

Why can we not get a government to to do the right thing and do the best for this continent .
Why is it that foreign companies receive more cred from the government than their fellow Australians who voted them in.
I object to all CSG mining in this state and in the entire country.
Apart from the greed that pushes CSG mining, the devastation to the country both above the surface and more particularly below the surface, there is no reason to pursue such a dangerous activity.
Rehabilitation of mining sites is a very sad joke. Mining companies are in it for the fast bucks and then vanish.
How would a mining company Rehabilitate the Great Artesian Basin?

CSG is unneccessary. We have more than sufficient resources to power the planet without wrecking our environment.
Our water supply is too precious to be risked in this foolhardy manner.
Please don't permit this ventrue to go ahead.

I have family in Narrabri who rely on the land for their livelihood. They have grown cotton and other agricultural products in the local area for decades and are heavily involved members of the local community.

I am concerned that CSG in the region will compromise the environmental health of the land from which so many people in the area rely on. This also affects everyone in Australia and abroad who consume the food produced in this region.

Submission objecting to the Santos Narrabri Gas Project
INTRODUCTION: I strongly object to the Santos Narrabri Gas Project because of its likely severe impacts on the biodiversity of the Pilliga, one of the Biodiversity Hotspots of Australia, as well as because of the potentially irreversible impacts of drilling and extracting coal seam gas through the rock strata and aquifers overlying the coal seams of the Gunnedah Basin beneath the Pilliga, a major recharge area of the Great Artesian Basin. I believe these impacts justify rejection of the project.
The EIS for the Santos Narrabri Gas Project is emphatically NOT JUSTIFIED in concluding that the project will have negligible impacts on biodiversity, on threatened flora and fauna species, on the integrity of threatened ecosystems, and on the integrity of underground and surface water systems, with or without proposed avoidance and mitigation measures. The proposed future rehabilitation and Biodiversity Offset Management Plans are unlikely to be able to effectively offset or mitigate either direct or residual impacts of clearing and consequent fragmentation of the forested project area on the threatened species and ecological communities of the Pilliga because there is probably no like-for-like habitat available to be set aside in the largely cleared agricultural regions around the forests of the Pilliga (less than 2% area remaining for some threatened ecosystems).

Background: I am a member of the Commonwealth Recovery Team for Regent Honeyeaters, and as a long-term member of BirdLife Australia Northern NSW have been voluntarily monitoring, studying and mapping occurrences of Regent Honeyeaters (now Critically Endangered) in the local Bundarra-Barraba-Kingstown districts for many years. I have an honours science degree majoring in Botany from University of Sydney, and have since been involved in teaching practical and field studies to undergraduates in the Botany Department at University of New England for some 30 + years. This has developed my understanding of practical botany and ecology in the New England and North-west regions of NSW including the Pilliga, and it has underpinned a lifetime of voluntary conservation advocacy as a member of the National Parks Association of NSW Armidale Branch.
The likely significant adverse impacts of the Santos Narrabri Coal Seam Gas Project on the biodiversity and ecology of the Pilliga forests cannot be ignored. They are serious enough to justify refusal of the project. They are discussed in detail below:
1. Fragmentation of project area by clearing
Basically, the EIS outlines the Santos project follows:
*430 well pads @ 1 ha each of cleared area, connected by
*446 km of cleared infrastructure corridors (430 km of gas & water pipelines and connecting tracks, plus 16 km of road for Bibblewindi and Leewood)
*Plus an unknown number of seismic lines
*Plus an unknown number of hazard reduction firebreaks, given the high bushfire risk and shelving of responsibility back to the Forestry Authority and Rural Fire Service.

Clearing for the installation of up to 850 wells and 446 km of associated roads and infrastructure over 25 years will seriously and irreversibly fragment the Pilliga forests, an effect that cannot be mitigated or offset. Categorising this fragmentation as having negligible potential impact because the area of clearing (1,701.51 ha of native vegetation and derived grassland) is only about 1.79 percent of the study area appears to be Orwellian double-speak - "war is peace". Appendix J1 says "Up to 10,143 hollow-bearing trees would be removed during construction of the project... The loss of hollow-bearing trees in the project area would result in a loss of roosting and nesting habitat for birds and arboreal mammals such as possums and bats". A very significant impact INDEED! And hollow-bearing trees cannot be replaced by rehabilitation or replanting efforts, as most trees take 100 plus years to mature and develop hollows.

The EIS appears to aim for plausible deniability of any adverse environmental impacts, with key details hidden away in a plethora of appendices scattered throughout a 7000 page document. Is the complexity of the EIS construction intended to discourage submissions from concerned members of the public? This appears to be an example of the long-established practice of mining proponents and their consultants downplaying impacts while talking up the alleged benefits of the project. There is strong evidence to the contrary presented below:
The EIS ignores the fact that other recognised significant impacts such as increased fire risk and salt contamination of water sources are superimposed on the risks of forest fragmentation caused by clearing of 446 km of linear tracks, roads and pipelines linking 430 well pads and infrastructure.
Fragmentation is a recognised key threatening process (KTP) under the TSC and EPBC Acts which the Santos EIS was directed to address. It has conspicuously and irresponsibly failed to do so. The proposed installation of up to 850 wells on 430 well pads plus 446km infrastructure corridors in the Pilliga forest study area will inevitably effectively fragment and destroy the self-sustaining integrity of part of the last remaining large and relatively intact forest/woodland west of the Great Dividing Range - the Million Wild Acres of author Eric Rolls (Rolls, Eric 1981 A Million Wild Acres Thomas Nelson Australia ISBN 00000 17 005302 4). It will further endanger the listed threatened species
The Pilliga has been identified in 2009 as an Important Bird Area, now Key Biodiversity Area (KBA). In 2009, BirdLife Australia (then Birds Australia) released a report on Australia's 314 Important Bird Areas (IBAs), which are areas recognized as globally significant sites for bird conservation. To qualify as an IBA each site must meet the criteria developed by BirdLife International. The Pilliga is one of only a few such areas listed in NSW, which would be seriously fragmented and degraded by proposed coal seam gas mining.
The environmental importance of the Pilliga is highlighted by its listing in "Biodiversity hotspots of Australia" by the Federal Environment Department. See SEWPAC 2009, http://www.environment.gov.au/biodiversity/hotspots/national-hotspots.html
This Commonwealth report specifies the Brigalow Belt North and South as a biodiversity hotspot, one of 15 in Australia and only 2 in NSW. The biodiversity hotspot concept identifies "exceptional concentrations of endemic species that are undergoing exceptional loss of habitat". The Santos project overlies a major part of the Pilliga in the Brigalow Belt South Bioregion in NSW and will seriously threaten the exceptional concentration of many endemic species, especially those listed as critically endangered like the Regent Honeyeater. The Pilliga forest was also found to be of "National Significance" according to the report of a study carried out by independent ecology experts in October 2011. (David Milledge et al: A report prepared for the Northern Inland Council for the Environment and the Coonabarabran and Upper Castlereagh Catchment and Landcare Group) This report focussed on the area specifically targeted by the Santos proposal and was publicly released in about October 2012. It identified a number of important species not noted previously, and the risks from coal seam gas mining. It was available to Santos and should have been referred to.
The overall landscape importance of the Pilliga described above is acknowledged in EIS Appendix J2:
"The native vegetation in the development site currently constitutes 80,398 ha of highly connected large patches of continuous vegetation. The development Footprint would fragment the existing patches into smaller patches but would not decrease the overall score for percentage of native vegetation cover" This contradicts the idea that linear clearing of about 1 percent of the study area will have an insignificant impact on the landscape and its biodiversity, as will be shown below.

This Santos Narrabri Gas Project will fragment i.e. cut up the Pilliga Forests into a series of islands of vegetation bordered by 446 km of linear tracks, roads and pipeline corridors between gas well pads, the details as yet unspecified, but undoubtedly likely to cause extensive fragmentation with serious cumulative impacts, especially on avian biodiversity, and on the viability of remaining koala and other threatened fauna populations. [EIS Appendix C Field development protocol]

"Intactness analysis" as discussed in EIS 15.1.7 indicates that the number of separate patches (islands) of habitat in the Pilliga project area would increase from 387 to 721, almost doubling the number of existing patches and reducing the intactness index.

This powerfully reinforces the argument that the fragmentation of forest caused by the project is likely to have serious impacts way out of proportion to the physical area of clearing. These impacts cannot be regarded as minimal or negligible, and cannot be mitigated within the timeframe of the project. The long-term adverse impacts of any disturbance of island ecology are well known (vide Christmas Island, Lord Howe Island, Galapagos Islands...)

Such fragmentation will result in the degradation and loss of foraging and breeding habitat for all threatened woodland birds and animals, including vulnerable koalas. ["koala numbers are falling fast in areas such as the Pilliga, where they have dropped 80 percent since the 1990s" (p12 Peter Hannam article, SMH May 19, 2017)]
Fragmentation is likely to lead to unbalanced increase in numbers for some native bird species such as Noisy Miners, which invade the edges of disturbed forest and dominate patches by disturbing and excluding other birds; and such as Currawongs and Butcherbirds which reduce breeding success of other birds by predation of nestlings. The Noisy Miner is now listed as a Key Threatening Process (KTP), as acknowledged in the EIS: P.54 Table 15-21: Key threatening processes - Aggressive exclusion of birds from potential woodland and forest habitat by over-abundant noisy miners (EBPC Act) - but the EIS pays no further attention to the likely impacts of fragmentation caused by the proposed Narrabri Gas Project, which is a most serious omission.
Fragmentation by linear clearing in relatively intact forest for the Santos project has the potential effectively to turn the whole Santos lease into Noisy Miner habitat, and thus exacerbate the impact of the Noisy Miner Key Threatening Process on four EPBC Act endangered species (Superb Parrot, Swift Parrot, Regent Honeyeater, Painted Honeyeater) as well as the many TSC Act threatened birds (the previous four plus several other small parrots and many songbirds of Noisy Miner size or smaller, many listed as vulnerable). (Pers. com. Stephen Debus) The relevant documentation on the impact of Noisy Miners, and the threatened and declining species they affect, is in the OEH Final Determination for the KTP in NSW and should have been used in the EIS for proper evaluation of the likely impacts of the proposal on threatened birds and other animals
Given that Noisy Miners are known to penetrate and dominate (i.e. exclude other birds) up to 300 m into woodland from edges, the notional well-pad and track layout alone suggests that many well pads will be within 600 m or so of each other and connected by tracks. Therefore, the many edges and 300-m penetration zones so created give the potential for Noisy Miners to colonise, and aggressively exclude threatened birds from, almost the entire Santos project area, way out of proportion to the actual area cleared (or even admitted in the EIS for a calculated 10-m or 25-m indirect impact zone around infrastructure clearing). Noisy Miners also farm lerps, (though less effectively than Bell Miners do), so could potentially affect tree health over the area they eventually occupy. Thus Noisy Miners could also degrade the habitat of much of the lease far more than the EIS admits. A classic, parallel example is a state forest near Chinchilla in Qld (Barakula SF, I think - Pers. com. Stephen Debus) - a Narrow-leaved Ironbark forest thoroughly dissected by roads, and now completely dominated by Noisy Miners, as described in one of Martine Maron's papers: Maron M (2009) Nesting, foraging and aggression of Noisy Miners relative to road edges in an extensive Queensland forest. Emu 109, 75-81.

The EIS seriously underestimates and understates the potential extent of impact from fragmentation and consequent increase in Noisy Miner populations. It also ignores the fact that the impacts of fragmentation are superimposed on and are very likely to be exacerbated by other threatened impacts such as increased incidence and severity of fire plus excessively high summer maximum temperatures, and the likelihood of salt-laden produced water affecting aquifers and therefore groundwater-dependent ecosystems such as those in the Pilliga.
Fragmentation caused by clearing vegetation for the Narrabri Gas Project is an unacceptable risk to the avian and other biodiversity of the Pilliga. It gives cause to reject the project.
2. Fire
The Santos project EIS fails to consider the increased risk of bushfires, compounded and exacerbated by other recognised impacts of the project, all of which are likely to have greatly increased and cumulative adverse impacts on the biodiversity of the whole Pilliga region. Instead the EIS just says there is remote likelihood of the project causing a bushfire - overall risk associated with a bushfire is considered medium. [i.e. medium risk to the project infrastructure and workforce, not risk to the environment or biodiversity of the area].
It is undeniable that the presence of safety flares, fugitive emissions and possible leaks of highly flammable methane gas during gas extraction operations may greatly increase the risk of ignition in the whole of the historically fire-prone Pilliga project area. Bushfires in the Pilliga area are already observed to be increasing in frequency and severity due to severe storms, drought and heatwaves induced by accelerating climate change. (reports of the 2014 Warrumbungles fire and its extension to the Coonabarabran area including Sidings Springs Observatory)
The Santos CSG project is very likely to greatly increase the risks of severe bushfires in the surroundings of operations in the project area because of leaks and fugitive emissions of methane gas. These risks cannot be dismissed as low or medium, and are unlikely to be mitigated by a Bushfire Management Plan. In fact the likely requirement for increased hazard reduction burning will significantly increase the adverse impacts of clearing and consequent fragmentation for the project area.
3. Fugitive emissions, leaks of methane gas from the project equipmen , safety flares
* Fugitive emissions of methane gas are bound to happen during operations to extract coal seam gas due to leaks from well casings or by direct escape from the accessed coal seams. Such emissions have been widely studied and observed in Queensland coal seam gas operations, with methane bubbling up in nearby streams and concentrations of methane gas detected in the local atmosphere (ref). There is a high risk that drilling and depressurisation of coal seams to liberate the gas in the Pilliga project area (with or without fracking) will cause minute cracks and fissures to open up in the overlying rock strata, allowing the gas to percolate to the surface where it may cause health problems for the workforce, increased risk of fire ignition, or be ignited during severe storm conditions to cause a catastrophic bushfire.
* Leaks of gas from well-heads and equipment have already been reported for the Santos 50 well pilot project. How many more can be expected from 850 wells? Well casings and other steel and metal equipment do not last forever, and are very liable to increased risk of failure because of corrosion caused by the highly saline produced water they will carry - an unacceptable risk.
* Safety flares used at operation sites cannot be turned off in severe bushfire weather, so must pose a risk of igniting surrounding bush if storm winds or tornadoes happen to traverse the clearing at the flare site - especially if there are other leaks and fugitive emissions of gas from the surrounding operations. What compensation will be provided by Santos if a bushfire is proved to have been started from a flare or gas leak on the coal seam gas operation sites?
If the Narrabri Gas Project gets the go-ahead, the proponent should be required to install special new meters to detect traces of methane gas in the atmosphere as described in an article by Annie Sneed in April 5, 2017 Scientific American: A Tiny Detection Chip Could Find Methane Leaks Autonomously: IBM will soon field-test technology that sees methane leaking from oil and gas well pads

4. Produced Water and Salt.

Water: Volumes of water extracted during depressurisation of the target coal seams to access the gas will cause a drop of about 0.5 metres in overlying water tables, according to the EIS. This is an unacceptable impact because any lowering of the water table will affect both agricultural use of the land as well as forest growth. All dependent plant life including the plant communities of the Pilliga forests will be affected when the water table drops below the depth required to support root growth. This is likely to severely jeopardise the nationally significant `food bowl' in Santos's proposed project area and the viability of the Pilliga forests. It is the reason why 95% of surveyed rural landholders in northwest NSW strongly opposed any coal seam gas development in the Gunnedah Basin.

The extraction of gas by depressurisation of the target coal seam will result in production of about 4 megalitres per day of `produced water' containing salt (sodium chloride plus other substances from coal seams) at about one third the concentration of seawater (Chapter 6)

The EIS says produced water and brine will be stored in ponds at Leewood prior to further treatment, which it says will be constructed to required standards, double-lined and unlikely to leak. But leaks of salty water have occurred in holding ponds during past operations, causing death of surrounding areas of forest. No pond liners are indefinitely leak proof. All pond liners are prone to failure over a number of years, especially when associated with corrosive materials like salt. And what if there is an unprecedented storm rainfall which may cause overtopping or breaching of the pond walls and consequent saline contamination of soil, local aquifers and the tributaries of the Namoi River? The impacts of such an event would be very severe and unacceptable.

Salt: The proposed treatment of this produced water will lead to the production of up to 115 tonnes per day of crystalline salt during peak gas production, 1430 tonnes average per month and 43,500 tonnes over the life of the project (Chapters 12, 13 and 28, Table 28.6) How will this quantity of salt (contaminated with Uranium, Cadmium and other heavy metal salts and substances from the coal seams) be safely stored pending disposal? How will it be disposed of? How many truckloads will be required to transfer it to a licensed landfill? Where is there a licensed landfill which can safely take this amount of salt? Narrabri Shire Council says its landfill does not have the capacity to accept this amount of salt - about 4 times the average annual amount of domestic waste capacity (ABC NW Regional Radio interview 18/5/2017).

The EIS is unacceptably silent on most of these matters, with no plan for safe disposal of salt waste other than transfer to a licensed landfill site somewhere, or finding a commercial beneficial reuse.

Conclusion:
I strongly oppose the Santos Narrabri Gas Project for all the reasons discussed above, and recommend that the project should be refused on the grounds of its multiple unacceptable impacts.

If consent is granted, the following conditions should be imposed:

* The proponent must supply substantial $ amounts to the Recovery Teams for the Regent Honeyeater and Swift Parrot, to support proposed recovery actions to improve breeding success and help recovery of critically endangered species. This should be a mandatory part of the biodiversity offset plans to mitigate potential impacts on two Critically Endangered Species. This would be similar to a condition imposed on the Whitehaven Maules Creek coal mine development 50km or so to the east of the Pilliga Project area.
* The proponent should be required to install special meters to detect traces of methane gas in the atmosphere as described in the article by Annie Sneed in Scientific American April 5, 2017: A Tiny Detection Chip Could Find Methane Leaks Autonomously: IBM will soon field-test technology that sees methane leaking from oil and gas well pads ...

I ask that Planning officers fully consider this submission and recommend that the Planning Assessment Commission refuse consent for the Narrabri Gas Project.
References:
Maron M (2007) Threshold effect of eucalypt density on an aggressive avian competitor. Biological Conservation 136, 100-107
Maron M (2009) Nesting, foraging and aggression of Noisy Miners relative to road edges in an extensive Queensland forest. Emu 109, 75-81.
Maron, M., Main, A., Bowen, M., Howes, A., Kath, J., Pillette, C. & McAlpine, C.A. (2011) Relative influences of habitat modification and interspecific competition on woodland bird assemblages in eastern Australia. Emu - Austral Ornithology, 111, 40-51.
David Milledge et al. (2012) A report prepared for the Northern Inland Council for the Environment and the Coonabarabran and Upper Castlereagh Catchment and Landcare Group)
Annie Sneed in April 5, 2017 Scientific American: A Tiny Detection Chip Could Find Methane Leaks Autonomously: IBM will soon field-test technology that sees methane leaking from oil and gas well pads ...

Beth Williams 25 The Avenue, Armidale NSW 2350 22/5/2017

Dear Sir/Madam,

Objection to the Narrabri Coal Seam Gas Project (SSD 6456).
It's inappropriate to fragment and degrade the Pilliga's woodlands with CSG infrastructure and roads as proposed by Santos. A network of intersecting roads and pipelines, water extraction, lines of wells, chemical intrusions, structures, work sites of the proposed gas field will bring ruin the Pilliga woodland ecosystems.

The Great Artesian Basin (GAB) aquifers have intake areas in the Pilliga forest that must be protected.
There should be No CSG infrastructure in the Willala Wilderness Area; areas of old growth woodland must be protected, as well as all endangered ecological communities, and threatened plant and animal species habitats. Adequate protection of these and other heritage values of the Pilliga woodlands will be impossible if this CSG proposal is approved.
The CSG industry has proven itself unable to effectively rehabilitate the very extensive areas it has mined, leaving many clearings and infrastructure in forests and farmlands across NSW and Queensland. The industry has shown itself to be incapable of removing its fence lines, tanks, dams, quarries, access roads, accommodation and clearings should also be removed from the mined out areas. Santos must be refused development consent.

I hope you will give my representations serious consideration and I thank you for the opportunity to comment.

Yours sincerely,
Kerith Power

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

Dear Sir/Madam,

Objection to the Narrabri Coal Seam Gas Project (SSD 6456)

The Pilliga Forest is the largest temperate woodland remaining in Australia. It comprises woodlands of Narrow-leaf Ironbark, Broad-leaf Ironbark, Pilliga Box and Bimble Box, as well as many other plant communities including Brigalow, Green Mallee and Broombush scrublands that have been cleared from other parts of the Central West of NSW.

The Pilliga woodlands are home to more than 900 plant species, including at least 12 rare and threatened plants. There are 14 frog species, 32 mammals (including 12 bats) about 50 reptiles and over 200 bird species. Pilliga woodlands support 22 threatened animal species (Glossy Black Cockatoo, Regent Honeyeater, Gilbert's Whistler, Painted Honeyeater, Turquoise Parrot, Barking Owl, Masked Owl, Malleefowl, Square-tailed Kite, Black-breasted Buzzard, Bush Stone Curlew, Eastern Pygmy-possum, Squirrel Glider, Koala, Black-striped Wallaby, Rufous Bettong, Pilliga Mouse, Greater Long-eared Bat, Yellow-bellied Sheathtail Bat, Little Pied Bat, Large-eared Pied Bat, Eastern Cave Bat). It's not a suitable place for coal seam gas (CSG) field development.

It's inappropriate to fragment and degrade the Pilliga's woodlands with CSG infrastructure and roads as proposed by Santos. A network of intersecting roads and pipelines, water extraction, lines of wells, chemical intrusions, structures, work sites of the proposed gas field will bring ruin the Pilliga woodland ecosystems.

The Great Artesian Basin (GAB) aquifers have intake areas in the Pilliga forest that must be protected.

Recharge of the Pilliga aquifer will become impossible due to the proposed quantities of water extraction required for coal seam gas (CSG) development. The GAB and the integrity of the intake bed strata must take priority over CSG production in the Pilliga. Fracking of the coal seam will compromise the GAB strata. It fracking is a contingent part of the proposed project, and Santos must be refused consent.

Damage to the GAB will have dire consequences, such as loss hydrostatic pressure in the artesian wellheads of the GAB. Water is gold for the agriculture and grazing Central West NSW and region is heavily dependent upon access to the GAB. The GAB is also essential to the survival of unique mound spring ecosystems located further west. Any disruption to the fine balance of groundwater and its replenishment has ripple effects well beyond calculation or modelling by Santos. The regional economy and ecology are dependent on the GAB and the GAB must not be jeopardised.

After considering the environmental constraints of the Pilliga forest and hazards related to CSG production and the GAB, I request that the NSW Department of Planning and Environment recommends refusal of development consent of this Santos proposal in the Pilliga.

There should be No CSG infrastructure in the Willala Wilderness Area; areas of old growth woodland must be protected, as well as all endangered ecological communities, and threatened plant and animal species habitats. Adequate protection of these and other heritage values of the Pilliga woodlands will be impossible if this CSG proposal is approved.

I also believe that the natural dark night sky will be compromised by light pollution from gas flares and CSG lighting infrastructure. Dark night skies are essential for the effective operation of the internationally renowned Siding Springs Observatory located nearby.

The CSG industry has proven itself unable to effectively rehabilitate the very extensive areas it has mined, leaving many clearings and infrastructure in forests and farmlands across NSW and Queensland. The industry has shown itself to be incapable of removing its fence lines, tanks, dams, quarries, access roads, accommodation and clearings should also be removed from the mined out areas. Santos must be refused development consent.

I hope you will give my representations serious consideration and I thank you for the opportunity to comment.

Yours sincerely,

Christopher Grogan

To Whom It Concerns,
I would like to make a request that the NSW Government does not give approval for Santos to do Coal Seam Gas mining (fracking) in the Narrabri "Project'.
The ongoing cost of maintaining pipes over the next thousand years has not been taken into economic account, nor the cost of the damage by poison to The Great Artesian Basin, Gunnedah Basin, surface waterways and affected soil.
If specific people in the government really want this fracking and want to be responsible for the millennia of pipe maintenance, can they hold their descendants personally responsible in a meaningful way, otherwise it is simply too easy for vested interests to be able to sell the future viability of life in this region, for no reason other than short-term greed.

Executive Director
Resource Assessments
Department of Planning and Environment
GPO Box 39
Sydney NSW 2001
Dear Sir/Madam,
Objection to the Narrabri Coal Seam Gas Project (SSD 6456)
The Pilliga Forest is the largest temperate woodland remaining in Australia. It comprises woodlands of Narrow-leaf Ironbark, Broad-leaf Ironbark, Pilliga Box and Bimble Box, as well as many other plant communities including Brigalow, Green Mallee and Broombush scrublands that have been cleared from other parts of the Central West of NSW.
The Pilliga woodlands are home to more than 900 plant species, including at least 12 rare and threatened plants. There are 14 frog species, 32 mammals (including 12 bats) about 50 reptiles and over 200 bird species. Pilliga woodlands support 22 threatened animal species (Glossy Black Cockatoo, Regent Honeyeater, Gilbert's Whistler, Painted Honeyeater, Turquoise Parrot, Barking Owl, Masked Owl, Malleefowl, Square-tailed Kite, Black-breasted Buzzard, Bush Stone Curlew, Eastern Pygmy-possum, Squirrel Glider, Koala, Black-striped Wallaby, Rufous Bettong, Pilliga Mouse, Greater Long-eared Bat, Yellow-bellied Sheathtail Bat, Little Pied Bat, Large-eared Pied Bat, Eastern Cave Bat). It's not a suitable place for coal seam gas (CSG) field development.
It's inappropriate to fragment and degrade the Pilliga's woodlands with CSG infrastructure and roads as proposed by Santos. A network of intersecting roads and pipelines, water extraction, lines of wells, chemical intrusions, structures, work sites of the proposed gas field will bring ruin the Pilliga woodland ecosystems.
The Great Artesian Basin (GAB) aquifers have intake areas in the Pilliga forest that must be protected.
Recharge of the Pilliga aquifer will become impossible due to the proposed quantities of water extraction required for coal seam gas (CSG) development. The GAB and the integrity of the intake bed strata must take priority over CSG production in the Pilliga. Fracking of the coal seam will compromise the GAB strata. It fracking is a contingent part of the proposed project, and Santos must be refused consent.
Damage to the GAB will have dire consequences, such as loss hydrostatic pressure in the artesian wellheads of the GAB. Water is gold for the agriculture and grazing Central West NSW and region is heavily dependent upon access to the GAB. The GAB is also essential to the survival of unique mound spring ecosystems located further west. Any disruption to the fine balance of groundwater and its replenishment has ripple effects well beyond calculation or modelling by Santos. The regional economy and ecology are dependent on the GAB and the GAB must not be jeopardised.
After considering the environmental constraints of the Pilliga forest and hazards related to CSG production and the GAB, I request that the NSW Department of Planning and Environment recommends refusal of development consent of this Santos proposal in the Pilliga.
There should be No CSG infrastructure in the Willala Wilderness Area; areas of old growth woodland must be protected, as well as all endangered ecological communities, and threatened plant and animal species habitats. Adequate protection of these and other heritage values of the Pilliga woodlands will be impossible if this CSG proposal is approved.
I also believe that the natural dark night sky will be compromised by light pollution from gas flares and CSG lighting infrastructure. Dark night skies are essential for the effective operation of the internationally renowned Siding Springs Observatory located nearby.
The CSG industry has proven itself unable to effectively rehabilitate the very extensive areas it has mined, leaving many clearings and infrastructure in forests and farmlands across NSW and Queensland. The industry has shown itself to be incapable of removing its fence lines, tanks, dams, quarries, access roads, accommodation and clearings should also be removed from the mined out areas. Santos must be refused development consent.
I hope you will give my representations serious consideration and I thank you for the opportunity to comment.
Yours sincerely,
________________________________________