Narrabri Gas

Please see attached PDF file uploaded with this submission. I OBJECT!

Please see submission attached.
I object to this project.

Please see attached file.
I object to this proposal.

Our submission is attached as a PDF

My submission is attached.

Sunday 21 May 2017
Please accept my submission to the Narrabri Gas Project
I am working in agricultural research with a keen interest in ecological agricultural systems.
I have been living in Victoria since 1996 actively participating in many different community
groups in particular those caring for the environment. I am privileged to have traveled Australia
extensively and having witnessed firsthand the detrimental impact of the rapidly expanding
mining industry on communities and the landscapes over nearly two decades, the prospect of
allowing the Unconventional Gas (UCG) industry establishing in any States or Territories,
principally anywhere in the world, is politically, economically and environmentally irresponsible
to the extreme.
Based on the experience in other parts of the world where the UCG industry is more advanced,
including in Queensland. I do not believe that this industry can co-exist safely with other land
uses like farming, conservation, and tourism.
I urge you to diligently read the comprehensive Final Supplemental Generic Environmental
Impact Statement (SGEIS) issued by the New York Department of Environmental Conservation.
The report, comprising of over 2000 pages, notes that considerable uncertainty over the
adverse environmental and public health consequences of fracking has "grown worse over
time."
Considering that it took the New York Department of Environmental Conservation seven-years
of research and over 260,000 public comments to produce the Final Supplemental Generic
Environmental Impact Statement (SGEIS) highlights the complexity and uncertainty surrounding
Unconventional gas mining.
I would like to make it clear that since this report was published new and extensive scientific
evidence continue to proof the very extensive safety uncertainties including a wide range of
health, environmental, climate and economic concerns.
It would be irresponsible to suggest anything else than to reject the Narrabri Gas Project and
instead I believe there is a compelling case to place a permanent ban on all unconventional gas
mining across New South Wales and indeed Australia.
.
Please NOTE:
I have include the following documents as part of my submission, due to the large file size of the
SGEIS report (Volume 1 and Volume 2), the documents can be accessed via the following web
link: http://www.dec.ny.gov/energy/75370.html
The second document is the `'Compendium of scientific, medical and media findings
demonstrating risks and harms of fracking (Unconventional gas and oil extraction)''. The full
report can be accessed via following web link: http://concernedhealthny.org/compendium/
Local communities and Farmers reject the Narrabri Gas Project;
Gas drilling will industrialise the landscape, impact on rural communities and people in
adjacent areas and it is highly likely to have significant public health impacts. UCG is a
fossil fuel which will further entrench our current reliance on coal and gas as energy
sources. It is water and energy intensive to produce, and will emit significant greenhouse
gas emissions.
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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 UCG, and have told Santos they do not want their country
sacrificed for a coal seam gas field.
The benefits associated with any royalties that are likely to be delivered as a result of
drilling are negligent compared with the enormous tax payer subsidies given to the mining
industry. In addition, the high risk of likely costs to tax payers to deal with the many
negative impacts on the environment, health and economy, long after the industry has left;
far outweigh any short term benefits.
Why would New South Wales even consider putting some of our best farmland, vibrant
communities and significant natural landscapes at risk by allowing this short term industry
to proceed for only minimal royalty returns to the state?
In particular when this industry does not have a social license to operate, as shown by
extensive community surveys that shown an average of 96% opposition to UCG. 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.
The Narrabri Gas Project poses unacceptable environmental, productivity, public health,
mitigations and residual risks;
Responsible decision making where risk is involved and science is still gathering
momentum requires the application of the precautionary principle. It is clear that many
problems with the industry may take years, and potentially decades, to be fully understood.
To gain a better understand of the full implications of UCG industry please read the
comprehensive Final Supplemental Generic Environmental Impact Statement (SGEIS) and
Compendium of scientific, medical and media findings demonstrating risks and harms of
fracking (Unconventional gas and oil extraction).
It would be reckless to unleash this industry on New South Wales with all the evidence that
is emerging about contamination events associated with UCG mining and "grown worse
over time" as stated in the SGEIS report.
Major environmental impacts associated with UCG are highlighted in Chapter 6.4
Ecosystems and Wildlife of the SGEIS report. Despite having its origin in America the
principals are directly relevant to the Narrabri Gas Project and in general the world.
The report describes in great detail the significant negative impact from fragmentation on all
terrestrial and aquatic habitat types, including forests, grasslands, shrub lands, rivers and
wetlands. Of particular concern is habitat fragmentation, transfer of invasive species and
potential impacts on endangered and threatened species.
Fragmentation is an alteration of habitats resulting in changes in area, configuration, or
spatial patterns from a previous state of greater continuity, and usually includes the
following:
 Reduction in the total area of the habitat;
 Decrease of the interior to edge ratio;
 Isolation of one habitat fragment from other areas of habitat;
 Breaking up of one patch of habitat into several smaller patches; and
 Decrease in the average size of each patch of habitat.
Habitat fragmentation from human infrastructure has been identified as one of the greatest
threats to biological diversity.
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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 Area. The
Narrabri Gas Project 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.
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.
Unacceptable public health risks;
Major health impacts associated with UCG are highlighted in Volume 2, Appendix A
Public Health Review of Shale Gas Development of the SGEIS report, they are:
 Air impacts that could affect respiratory health due to increased levels of
particulate matter, diesel exhaust, or volatile organic chemicals.
 Climate change impacts due to methane and other volatile organic chemical
releases to the atmosphere.
 Drinking water impacts from underground migration of methane and/or fracking
chemicals associated with faulty well construction.
 Surface spills potentially resulting in soil, groundwater and surface water
contamination and surface water contamination resulting from inadequate
wastewater treatment.
 Community impacts associated with boom-town economic effects such as
increased vehicle traffic, traffic accidents, road damage, noise, odor complaints,
increased demand for housing and medical care, and stress.
Furthermore, the `Compendium of scientific, medical and media findings demonstrating
risks and harms of fracking (Unconventional gas and oil extraction) adopted for use in many
areas of the world including Australia, highlight many significant issues. The full report has
been supplied with this submission.
1. Growing evidence shows that regulations are simply not capable of preventing
harm. That is both because the number of wells and their attendant infrastructure
keeps increasing and, more importantly, because some of fracking's many
component parts, which include the subterranean geological landscape itself, are
simply not controllable.
2. Drinking water is at risk from drilling and fracking activities and associated waste
disposal practices. As documented by the Pennsylvania Department of
Environmental Protection in a review of its records, 234 private drinking water wells
in Pennsylvania have been contaminated by drilling and fracking operations during
the past seven years. These do not include drinking water wells contaminated by
spills of fracking waste water or wells that went dry as a result of nearby drilling and
fracking activities. In California, the injection of liquid fracking waste directly into
groundwater aquifers threatens contamination of large numbers of public drinking
water supplies.
3. Drilling and fracking emissions often contain strikingly high levels of benzene. A
potent human carcinogen, benzene has been detected in the urine of well pad
workers (at levels known to raise risks for leukemia), in private drinking water wells
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contaminated by fracking operations, and in ambient air at nearby residences. In
some cases, concentrations have far exceeded federal safety standards. Such
exposures represent significant public health risks.
4. Public health problems associated with drilling and fracking are becoming
increasingly apparent. Documented indicators variously include increased rates of
hospitalization, ambulance calls, emergency room visits, self-reported respiratory
and skin problems, motor vehicle fatalities, trauma, drug abuse, infant mortality,
congenital heart defects, and low birth weight.
5. Natural gas is a bigger threat to the climate than previously supposed. Methane is
not only a more potent greenhouse gas than formerly appreciated, real-world
leakage rates are higher than predicted. Within the last five months, multiple teams
of independent scientists have published data on fugitive emissions that, all
together, call into question earlier presumed climate benefits from replacing coal
with natural gas. Further, evidence increasingly suggests that the natural gas
abundance brought by fracking is slowing the transition to renewable energy and is
thus exacerbating, rather than mitigating, the climate change crisis.
These findings are reflected in rapidly increasing research conducted within Australia, for
example, the study "Impact of the mining industry on the mental health of landholders and
rural communities in southwest Queensland" by the Royal Australian and New Zealand
College of Psychiatrists 2013 in the Australasian Psychiatry 21(1) 32-37. States that: "The
scale, and speed of growth, of mining and coal seam gas has introduced numerous new
social issues for regional and local economic development, including employment and skills
shortages, a shortage of affordable housing, social inequities and lack of appropriate
infrastructure and services. All the issues related to mining and coal seam gas industry
were seen as having created tremendous mental health problems for the landholders and
associated rural communities in the region."
Doctors for the Environment point out that a range of other hazardous chemicals are
reported to be used in Australian fracking operations for CSG including 2-butoxyethanol
and ethylene glycol. Research compiled by Doctors for the Environment found that 2-
butoxyethanol is easily absorbed and rapidly distributed in the human body and is
particularly toxic to red blood cells, carrying the risk of haemolysis, and damage to spleen,
liver and bone marrow. Ethylene glycol is used to make anti-freeze and when ethylene
glycol breaks down in the body it can affect kidney function as well as the nervous system,
lungs and heart.
Again, the Final Supplemental Generic Environmental Impact Statement (SGEIS) and the
Compendium report supplied with this submission addresses many more of the impacts of
UCG such as risk mitigations and residual risks of unconventional gas activities.
Based on the conclusions above alone; suggesting anything else than to ban all
unconventional gas mining permanently would be irresponsible.
There are a range of reasons why UCG cannot co-exist peacefully with the environment
and the community;
UCG activity fundamentally industrialises landscapes. Gas mining operations have a large
footprint and require access roads, drill pads and processing equipment, waste ponds and
water treatment sites, flaring pits, and pipelines. It will profoundly change the rural nature of
the areas where it is allowed to become established.
There will be visual and noise pollution, plus increased heavy traffic use of local roads. It is
likely there will be local short term distortion of the rental and property markets. There is no
guarantee that any employment generated will significantly benefit local communities given
it will rely on specialist skills.
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There can be no doubt that these communities will, in general, object to industrialisation of
rural landscapes that will happen as a result of gas mining. Given all these obvious impacts
it is difficult to imagine that an UCG industry will not impact negatively on rural property
value.
Based on the experience of farmers in Queensland where the coal seam gas (CSG)
industry has already become entrenched and its problems are starting to be documented, I
do not accept the premise put forward by the industry that UCG operations can peacefully
co-exist with farming.
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 pollution. The area has
been internationally recognised as a `dark sky park' and the 50m high gas flares proposed
by Santos threaten the viability of the facility.
Competition with farmers over water;
Groundwater plays a vital role in sustaining agriculture, and hence our economy and
lifestyle. Mining coal and gas (and especially UCG) is a very water intensive process. With
the prospect of an expanding mining sector, fossil fuels and agriculture can be expected to
be in increasing conflict over limited water supplies in coming years.
It can be argued that when recharge rates are considered, many aquifers are already over
committed. Additionally, there are already substantial concerns about subsidence and over
use of aquifers across Australia.
The question of how much water will be needed by industry will depend, of course, on how
many drill operations are ultimately approved. A difficulty in assessing the likely impact of
any approvals of UCG mining is that there is a wide variety of opinions on just how much
water is used.
Additionally, there is the matter of how much water will be extracted from coal or other gas
seams in the fracking process, and how this will affect the water table.
Other forms of UCG also use substantial quantities of water in the drilling process. Shale
and Tight Gas, which exist at deeper levels will need to be fracked, as confirmed by Lakes
Oil in community consultations held in Victoria in early 2015.
This means substantial volumes of water, even if fewer chemicals are used in the frack mix
compared with CSG. The company said that wells may be in use for up to 20 years,
although main flow of gas is expected in the first few years of operation.
The Australian gas industry provides a figure of 11 million litres per shale or tight gas frack,
however, many other sources suggest higher levels of water use. One estimate of water
use in shale gas frack operations was '20 ML per frack', with 'flow back rates of 10 to 70%'
There could be several wells per pad, based on multiple horizontal drill lines, increasing the
water consumption substantially.
Like the water that is pumped into the ground as part of the frack to carry the sand and
chemicals, this water will be contaminated with salts, whatever chemicals are used in the
frack, and potentially any chemicals found in the rock formation itself. In the case of tight
and shale gas, other potential contaminants from the frack mix could include biocides,
corrosion inhibitors and friction reducers.
Again many examples are listed in the Final Supplemental Generic Environmental Impact
Statement supplied with this submission.
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The potential for contamination of groundwater;
Apart from the question of industry accessing large volumes of water, there is also the
matter of quality of ground water. Based on the experience in Queensland, concerns about
contamination of aquifers or surface water from mining operations can be expected to
become significant once operations become established.
Industry proponents have been active in attempting to convince the community and local
governments that tight and shale gas is fundamentally different to CSG and that fewer
chemicals are used in the frack process and there is no risk of contamination.
Where industry admits to contamination incidents, they are generally referred to 'legacy'
problems, and the result of poorer management regimes in other countries or older and
poorer drilling technology. The take home message from industry is that 'new' technology
has made the process safe and that Australia has excellent regulatory regimes to safely
manage the industry.
However, globally, there is rapidly growing evidence of contamination incidents associated
with shale and tight gas drilling. Many examples are listed in the Final Supplemental
Generic Environmental Impact Statement (SGEIS) supplied with this submission.
There is also concern of geo contamination - dangerous materials being brought to the
surface in recovered water as a result of shale and gas fracking. These contaminants
include heavy metals, naturally occurring radioactive materials (NORMs - including Radium,
Thorium and Uranium), volatile and semi volatile organic compounds (VOC's) and high
concentrations of salts.
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.
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 Narrabri Gas Project.
Well failure through blowouts, annular leakage (along the well) or radial leakage
(perpendicular to well) is the primary cause of groundwater contamination from
unconventional gas production. Research consistently has shown that on average there is
an immediate bore failure rate of 6% which then increases to 50% within 30 years and
continues to increase. The risks are too great and cannot be mitigated.
Again many examples are listed in the Final Supplemental Generic Environmental Impact
Statement supplied with this submission.
Climate change;
Climate change impacts due to methane and other volatile organic chemical released into
the atmosphere during unconventional gas extraction and use is no better than burning
coal. To have even a 75% chance of meeting the 2…C warming limit, at least 77% of the
world's known fossil fuel reserves (coal, oil and gas) cannot be burned. 2…C of overall
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warming is generally seen as being the absolute upper limit that is allowable if we are to
avoid 'catastrophic' climate change.
Any discussion about energy policy needs to consider the implications of climate change. In
the case of UCG, which requires access to land in a way that is adversely impact on local
farming activity and the environment, there is an additional consideration when it comes to
climate change. UCG can be seen as one more land use, like urban sprawl, that results in
changes to farming activity and clearing of native vegetation.
Yet climate science tells us that south eastern Australia will be affected by climate change
in a way that will reduce food production. This makes our farmland even more important
and in need of protection from invasive activities like coal and gas mining.
Potential changes in climate may reduce productivity and output of NSW's agricultural
industries in the medium to long term. It is essential that we do not put food producing
areas at risk from UCG drilling without fully understanding the possible long term impacts
on groundwater and agricultural land.
A responsible energy policy for New South Wales would rule out any further coal, gas, or oil
development. In terms of our future energy supply mix, we must remember that UCG is a
fossil fuel. The widespread burning of fossil fuels are the main single cause of human
induced global warming. The only way to stop, or at least minimise, the impacts of climate
change is to stop burning fossil fuels, not dig up and burn more.
Despite high energy and resource needs involved in extracting UCG, indirect emissions of
carbon dioxide from fossil fuels used during extraction and direct emissions of carbon
dioxide from endues consumption are relatively small compared to the fugitive emissions of
methane from leaks in the UCG production. Methane is a far more powerful greenhouse
gas than carbon dioxide.
Again many examples are listed in the Final Supplemental Generic Environmental Impact
Statement supplied with this submission.
Implications for local and regional development, investment and jobs;
In terms of regional centres near to gasfields, there will be a mixed impact. The experience
in places like Queensland is that a small number of businesses will do well, but long term
residents will be impacted by a boom and bust cycle in both the property and rental
markets. For towns with significant numbers of lower income families, there is a real risk
that people will be displaced from the rental market.
Furthermore, increased pressure on infrastructure by the influx of mining activity will drive
up council rates, service based businesses such as farms, farm supply, auto mechanics,
hospitality, tourism etc, will find it increasingly difficult to be able to employ staff at
affordable wages leading to high general living costs for residents and visitors, essentially
driving away vital workforce needed by the agricultural and service sectors, residents and
tourism.
The Compendium report highlights that the economic and job prospects claimed by industry
are greatly exaggerated, abstracts of two examples from pages 85 and 87 of the report
state that:
"May 27, 2014 - A Bloomberg News analysis of 61 shale drilling companies found that the
economic picture of shale oil and gas is unstable. Shale debt has almost doubled over the
last four years while revenue has gained just 5.6 percent. For the 61 companies in their
analysis, Bloomberg News reported: "In a measure of the shale industry's financial burden,
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debt hit $163.6 billion in the first quarter." Further, Bloomberg News noted that drillers are
caught in a bind because they must keep borrowing to pay for exploration needed to "offset
steep production declines typical of shale wells .... For companies that can't afford to keep
drilling, less oil coming out means less money coming in, accelerating the financial tailspin."
"November 21, 2013 - The Multi-State Shale Research Collaborative released a six-state
collaborative report demonstrating that the oil and gas industry has greatly exaggerated the
number of jobs created by drilling and fracking in shale formations. The report found that far
from the industry's claims of 31 direct jobs created per well, only four jobs are created for
each well. It also demonstrated that almost all of the hundreds of thousands of `ancillary'
jobs that the drilling industry claims are related to shale drilling existed before such drilling
occurred. As Frank Mauro, executive director of the Fiscal Policy Institute put it, "Industry
supporters have exaggerated the jobs impact in order to minimize or avoid altogether
taxation, regulation, and even careful examination of shale drilling."
Again many examples are listed in the Final Supplemental Generic Environmental Impact
Statement and the Compendium report supplied with this submission.
The comprehensive `Compendium of scientific, medical and media findings demonstrating
risks and harms of fracking (Unconventional gas and oil extraction) report concludes that:
Growing evidence shows that regulations are simply not capable of preventing harm. That
is both because the number of wells and their attendant infrastructure keeps increasing
and, more importantly, because some of fracking's many component parts, which include
the subterranean geological landscape itself, are simply not controllable.''
Again many examples are listed in the Final Supplemental Generic Environmental Impact
Statement supplied with this submission.
The risks and impacts posed by UCG cannot be managed;
Even in Australia, history has shown that regulation of industry does not work, there are
countless examples where loop holes are exploited by industry to flaw any regulations put
in place.
The Narrabri Gas Project has a long history of spills and leaks of toxic UCG 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
barium. In addition, there have been over 20 reported spills and leaks of toxic UCG water
from storage ponds, pipes and well heads. Santos cannot be trusted.
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.
Based on mounting evidence of the negative impacts of UCG mining in Australia and
elsewhere around the world, I believe the best and simplest policy response to regulate this
industry is to ban it. Many other jurisdictions around the world including Victoria in Australia
have chosen to place an outright ban on UCG and/or the process of fracking.
I urge you to reject the Narrabri Gas Project and instead ban all unconventional gas mining
permanently.
Dated, Sunday 21 May 2017

Happy to have submission made public, uploaded at the link below.

uploaded

Submission is uploaded as file attachment 1.

uploaded

I object to this proposal on many grounds as specified in my attached submission.

I have provided details of my concern about the inadequacy of the greenhouse gas emission assessment methodology and factors used in that assessment.

Objection to Narrabri CSG project as detailed in attached PDF file

NSW Department of Planning and Environment
G.P.O. Box 39
SYDNEY NSW 2001
20th May 2017

Re: Submission Regarding the EIS for the Proposed Narrabri Gas Project (SSD 14_6456)

Dear Sir / Madam,
I am president of the Artesian Bore Water Users Association Inc., and I thank you for this opportunity to present our submission to the Santos Narrabri Gas Project EIS.
Artesian Bore Water Users Association of NSW Inc. (ABWUA) objects to this Narrabri Gas Project (NGP) on many grounds. This EIS is a proponent-driven exercise in spin and misrepresentation. Santos had so many years to get their paid proponents to write this report, and we are given a couple of months to digest it and respond. There are so many flaws in this document that it is hard to know where to begin, or to have time and space to list them all.
Firstly we must point out that Santos starts the EIS with a blatant untruth in their introduction. Santos, in the introduction, state that "In addition, the project is not located within a major recharge zone of the Great Artesian Basin." All the CSIRO maps, Geoscience, all GAB mapping, show clearly and irrefutably, that this statement is untrue. I was told by an expert from the Dept., that the entire EIS is therefore invalid, and should be thrown out and have to be re-written, for making such a misleading (and completely untrue) statement at the beginning.

In 2015 ABWUA commissioned a report by SoilFutures Consulting Pty Ltd into the recharge systems and petroleum and gas licenses. (GAB Recharge Systems 2015 - attached). This peer-reviewed report clearly states that:

* In NSW, the main occurrence of recharge > 30mm is in the east Pilliga between Coonabarabran and Narrabri.
Other proof of the location of the GAB recharge in relation to the Narrabri Gas Project (NGP) is various and comprises CSIRO maps used by both Queensland and NSW State Governments and the Australian Federal Government. Other resources are listed in the reference section of the report which is attached. (Doc. enclosed).

Other findings in the report include:

* Only 0.2% of the GAB has effective recharge of 30 - 79mm/yr.

* Both the Pilliga and the northern Surat gas fields or licence areas occur in the very limited critical recharge (>30mm) areas of the GAB.

* Excessive draw-down of pressure heads in the recharge zone of the GAB associated with gas extraction, has the potential to reduced pressure heads on artesian waters across much of the GAB, and potentially stopping the free flow of waters to the surface at springs and bores.

* "Drawdown of many hundreds of metres is reported in Ransley and Smerdon (2012) for the northern Surat basin coal seam gas fields where coal seams are being dewatered to release gas." Whereas Santos claim a mere "0.5m drawdown".

So the drilling through the southern recharge of the GAB, will destroy the pressure, which allows the groundwater to be brought to the surface. There is much evidence of this in the Queensland gasfields already, where so many bores have failed already.
See report below:
Great Artesian Basin Coordinating Committee - Key Issue 1, Declining Artesian Pressure.

Pressure is a key attribute of any artesian groundwater resource providing a relatively low-cost supply in remote areas. Excessive extraction of water through uncontrolled discharge from artesian bores, both above and below ground level, has resulted in a continuing decline in artesian pressures in parts of the Basin, causing a loss of access to artesian water by an increasing number of water users. Reduced natural discharge in response to declining artesian pressure is also causing detrimental impacts on groundwater-dependent ecosystems (such as mound springs and wetlands) and associated biodiversity and cultural heritage values. http://www.gabcc.org.au/public/content/ViewCategory.aspx?id=13

Other queries arising from statements in the Introduction to the EIS:
"Due to the geology of the deep coal seams, hydraulic fracturing will not be needed to extract the gas and Santos is not seeking approval to use this technology." Why did Eastern Star Gas (of which Santos was a major partner at the time) need to frack, when they owned the licence - if it was not necessary? Does the fact `Santos is not seeking approval to use this technology' mean they will guarantee in writing, to never frack, no matter what the circumstances? Will it be written into any sale contract that the purchaser can't frack? I have been told by expert hydrogeologists and groundwater engineers, that every gas well is fracked ultimately. Some don't need to be fracked immediately, as the gas flows freely at first, but some need to be fracked straight away. But eventually every single well is fracked, to get the best value from the cost of setting up the wells and infrastructure. As one hydrogeologist (and gas well driller) explained to me, "it is like wringing out a sponge - you have to get every last drop out of the seam. It is necessary to make it cost-effective."
Santos also use weasel words such as "we don't INTEND to frack..." which leaves them open to later do fracking. Their next statement (after the project gets the "tick the box" that our Member Kevin Humphries assures us it will), would be "Oh, we didn't INTEND to frack, but now circumstances have changed and we found that we had to frack to get the gas out."

And this (following) is probably the worst inaccuracy in the EIS:
"The EIS found the project will have minimal risk of impact on agricultural and domestic water sources". Sadly, the Queensland CSG experience has shown this is certainly not the case. So many bores have lost pressure, are burping and bubbling with gas, can be set on fire, or have simply failed altogether. When a bore now fails in Queensland, they simply plug and abandon it, and sink a new bore to a deeper level - which effectively masks the fact that they are depleting and destroying the Basin there.
There is no data base in Qld. of the failed bores, and no publicly available record of how many bores have failed so far. They are hiding all the data and trying to hide the facts, as they don't want people to know.
But the evidence from Queensland shows that even where fracking hasn't occurred, there is clear evidence that there have already been massive impacts on water bores and industries. And now we also have a wealth of evidence from the U.S. that unconventional gas extraction (with or without fracking) damages the other users' water. We now have proof that in relation to the predictions of damage to our groundwater made in previous reports, the impacts are coming much sooner (and worse) than was predicted. https://www.dnrm.qld.gov.au/ogia/surat-underground-water-impact-report


The `Triple-Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31, poses an even greater danger to the Great Artesian Basin and other aquifers than from ordinary wells, as it is very difficult, if not impossible, to seal the junction between the casing and the lateral. When questioned about sealing these junctions, Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is unfortunately very clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers. All gas wells leak in time, industry figures are that 7% leak immediately, and within 20 years, 30% leak. As Santos will be long gone by then, who will bear the future cost of rehabilitating the corroding and crumbling wells, that have lost their integrity?

Santos have stated publicly that this Narrabri Gas Project is just the beginning. They have stated to their shareholders and on their website, that their plan to drill 850 wells across the pristine Pilliga Forest, the largest inland forest left in NSW, and the recharge zone for the Great Artesian Basin, is just the start. (See doc below). They intend to spread out across our most productive farmland, with clear plans for a massive gasfield - tens of thousands of wells - right across the area shown in their map below. And that is just for starters.




ABWUA has been instrumental in the continuation of GABSI, which is the single greatest thing that has happened to the GAB. For many years, ABWUA assisted with this capping and piping scheme, to save the groundwater that was being wasted through free-flowing bores, and to restore the pressure to the GAB (which was failing). GABSI was a proven scheme that was working, pressure was returning to the system, and bores which had not flowed for many years, suddenly started flowing again. Through continued lobbying for funding, GABSI has recently been renewed; it was announced last week that the federal government has renewed GABSI for phase 5.
Information on GABSI is available at http://www.water.nsw.gov.au/water-management/water-recovery/cap-and-pipe-bores
"Great Artesian Basin Sustainability Initiative
The Cap and Pipe the Bores program is part of the Great Artesian Basin Sustainability Initiative (GABSI), jointly funded by the Australian and NSW governments. GABSI phase 1 was implemented between 1999 and 2004 with $25 million funding. Phase 2 built on this with $32 million funding from July 2004 until June 2009. DPI Water has targeted remaining free flowing bores through the Cap and Pipe the Bores program under GABSI phase 3, which finished in June 2014.

Some of the savings made under GABSI include:
Achievements
In the past, up to 95 per cent of artesian water was being wasted through evaporation and seepage. Today, the Cap and Pipe the Bores program has improved water supply through the following achievements:
* saving 78,500 ML of water every year
* supplied approximately 4.2 million ha with permanent, reliable, efficient and strategically located watering points
* controlled 398 free flowing bores
* removed over 10,000 km of bore drains
* installed 18,000 km of piping
* improved water use efficiency and reduced water wastage
* improved water quality for stock and domestic use
* increasing artesian pressure, increasing access to water
* reducing salt discharge by 62,800 tonnes every year
* reducing greenhouse gas emissions by 41,600 tonnes every year
* assisted land managers to achieve more sustainable property and stock management.
Increases in artesian bore pressure are being observed in many areas as a result of capping and piping. The program is achieving many other landscape benefits such as improving biodiversity conservation and feral animal control."
Will the government then please explain why, when all these savings are applauded as benefits to the environment, can Santos now threaten to undo all the good work that has been achieved? Well over half a billion dollars of both the State and Federal governments and the individual landholders, stands to be wasted, as CSG mining does the exact opposite of what GABSI is doing. GABSI restores the pressure, and saves the wastage of finite artesian water; CSG mining has to DE-PRESSURISE and drain the water from the coal seams (and lower the water table).
It has become evident from the Queensland experience that Santos WILL cause a lowering of the water table. This is incontestable as they dewater the aquifers to get the gas - and they have admitted that. As has the National Water Commission.

They have no answer to what they propose to do with the salt they will bring to the surface. Something GABSI was designed to do, was to reduce the salt brought to the surface. All Santos has said is that they will bury it in some as yet unknown landfill. (See attached paper on problems with salt, by geochemist John Polglase).

Current status of GABSI:
Barnaby Joyce announces an extra $8m in federal funding for GABSI 5. http://minister.agriculture.gov.au/joyce/Pages/Media-Releases/$8-million-top-up-to-support-water-management-in-the-Great-Artesian-Basin.aspx

The Office of Water has stated that bores that impact on springs will be focussed on.
20 - 30 of these bores will be done in the next 3 years.
The government can't afford to cap the less than 250 bores which are still uncapped in NSW alone. Who will ever be able to cap thousands of bores when Santos has long gone and they all need rehabilitating? 7% of bores fail initially, 30% within 20 years and 100% within 100 years. Bores do not last `forever' as stated by Santos. Concrete and metal do not have a perpetual lifespan.
This damage is permanent. Over time it will be like a pincushion with rusting pins. Who is liable for capping them? Will it be the landowner, and taxpayer - as with GABSI?

Australia is the driest inhabited continent on earth. How can we allow an industry that states `that to get to the gas it dewaters the aquifer'.

The GAB lies under 22% of Australia. Is it worth the risk?
Water and air are the most valuable things on this planet. How can we risk them?

The GAB is not alone. In fact, worldwide, for most groundwater aquifer systems employed for agriculture:

a. recharge fluxes were over-estimated;
b. reservoir volumes were over-estimated; and
c. extraction volumes were under-estimated.
In other words, over 3-4 decades, most aquifer management (if any) resulted in unsustainable outcomes. The classic example is the High Plains Aquifer in the USA. Equally, with exponential world population growth and exponential domestic reliance upon groundwater, it does not bode well for the health of the remaining 'fossil' systems. Sadly, the enduring and increasing number of 'water conflicts' is an indicator of where we are all headed.

Thank you for the opportunity to present this submission. I have so many other points I would like to raise, so much evidence of so many things wrong with this NGP - but I hope you will give us the opportunity to provide further information later. We are waiting on some vital reports, which are not yet completed, and which will form part of our submission. As I requested in writing to your Department earlier, I would appreciate presenting this information and these reports to you, at a later date.

Yours sincerely,
Anne Kennedy
President ABWUA


Some links:
http://player.vimeo.com/video/102105908
Interview with Professor Ingraffea on well integrity failure
http://psehealthyenergy.org/site/view/1233
Comprehensive list of peer-reviewed papers on unconventional gas development.

http://endocrinedisruption.org/chemicals-in-natural-gas-operations/introduction
TEDX info on endocrine disruption

https://www.youtube.com/watch?v=gz2mq5GYnR0
Dr Mariann Lloyd-Smith's address at Lismore on risks of CSG (and exposes the myths)
(Documents showed they use 18,500 kilograms of chemicals per well)

https://www.youtube.com/watch?v=Kvfzz7_nbqs&feature=youtu.be
Dr Geralyn McCarron on health impacts
http://www.couriermail.com.au/news/opinion/the-environment-deserves-more-than-this-drop-in-a-bucket/story-fnihsr9v-1227027256382?nk=3f4a84942d7e4ccf4baff87e2585f053
Tom Crothers, an independent hydrology consultant and a former general manager of Water Planning and Allocation for Queensland - tells of the enormous destruction to the GAB from mining.
http://csgscienceforum.com/event-videos/
CSG Science Forum (and link to Professor Ingraffea's video)
http://www.propublica.org/article/new-study-predicts-frack-fluids-can-migrate-to-aquifers-within-years
Study on migration of fracking fluids to aquifers

https://www.youtube.com/watch?v=W8qs5HQ6jgs
Professor Ingraffea dispelling myths re fracking

http://www.globalpossibilities.org/usgs-finally-admits-that-fracking-causes-earthquakes/

Please find my submission attached

Please find PDF file attached.

I object to the Narrabri Gas Project.

1. Flawed process
I am an ordinary Australian citizen.
I do not have teams of lawyers or paid environmentalists to write or read 7,000 pages of EIS documents. I work from the kitchen table at night after tea.
As an ordinary tax payer I cannot make political donations to the major parties to buy the outcomes I want.
I cannot offer politicians post-parliamentary positions on the board of my company so they can use their influence in the corridors of power to advance my company's interests over those of ordinary Australian citizens. I have no such company.
I hope that you will, nevertheless, take note of my submission in this David & Goliath contest which sees ordinary Australians dig in against their own govt. and Santos over the Narrabri Gas Project.

I fear that submissions opposing the project will not be heeded and worry that the call for public submissions is window dressing.
Why?
Shortly after Santos released their EIS I heard an interview with the member for Barwon, Kevin Humphries, on ABC radio. He said of the Narrabri Gas Project: "There might be a little bit of grandstanding but at the end of the day the project will go ahead and I'm highly supportive of it." http://www.abc.net.au/news/2017-02-23/narrabri-coal-seam-gas-proposal-will-go-ahead-says-nationals-mp/8296794
He pre-empted the outcome of the Planning and Environment process - "The project will go ahead". Very concerning to me, it means it is already a done deal.

2. Time taken to produce the EIS is not relevant.
Kevin Humphries also said ""The environmental impact statement that Santos have worked up has taken several years" as if this automatically makes it good. I wish to point out that time taken to produce the document is not an indicator of anything except the time taken to produce it.

3. Length of EIS is not relevant
The 7,000 pages is not doubt meant to be impressive but I urge you to resist being subconsciously impressed by size. I suspect that the excessive length of the document is more a weapon against opposition than an attempt at really covering the environmental bases. Santos know their opposition is ordinary people trying to grapple with this around the kitchen table after tea then doing the farm BAS before midnight and the next day's work.

4. Size of gas field
This is the thin end of the wedge. If the Narrabri Gas Project is approved Santos will then use it as leverage to extend their operations to the rest of their licences in that area. This is the domino effect of CSG which we have seen in numerous other cases (like Qld). If you allow this project to go ahead you are de facto approving CSG across the whole area. It's some of the best farming country in Australia.

5. Farming vs CSG
Q. How can you run a centre pivot over a gas well?
A. You can't.
Q. How can you farm your country when the water flow has changed because roads to gas wells now criss cross your land and act like levees?
A. You can't.
Q. What happens when the CSG that comes up under its own pressure is exhausted and all that infrastructure is just sitting there unproductive?
A. Santos will want to start fracking to get gas up.
Q. What happens to the Great Artesian Basin when fracking chemicals get into the water?
A. It's buggered. For good and all. No amount of remorse will bring it back.
We hear a lot of cant and stock phrases like "mining and agriculture can co-exist" but just saying something doesn't make it true. Not even if you're a politician.

6. World's Best Practice
We keep hearing about World's Best Practice but if World's Best Practice is slipshod and inadequate then a company, such as Santos, promising to deliver World's Best Practice is promising not much.
World's Best Practice includes not having any plan for the salt from "produced water" from the Narrabri Gas Project. That salt will be trucked to landfill and dumped to become someone else's problem. It could be coming to your town. Or mine. When asked about this in an ABC radio interview Peter Mitchley, Santos' General Manager NSW, would not say where it would go. Whether they haven't thought about it or whether they just don't want people to know? That's World's Best Practce.
If you accept (as I do) that allowing CSG will lead ultimately to fracking this is relevant: http://www.ecowatch.com/confirmed-oklahoma-earthquakes-caused-by-fracking-1882034344.html The US Geological Survey has linked fracking to the huge increase in earthquakes in America.

7. Divine Right
There is the perception by Santos and govt. that just because Santos have already spent millions this gives them an automatic right to have their project approved. I hope the Planning and Environment process does not share this view. What about the millions that farmers have invested in their industry? Why don't they have the automatic right to continue farming? Why is CSG more privileged than agriculture and allowed to destroy it? Agriculture is a proven industry already operating successfully in the region Santos threatens. In my opinion it is a far nobler and more beneficial industry than CSG. People continue to need food and fibre and the area that Santos have licences over is some of the best agricultural land in Australia.

8. Social License
No matter how much money Santos put into the football team or girl guide halls, etc they don't have social license. You can't buy that. It's like trust - the only way to get it is to earn it and Santos have not earnt it. (They are not trusted either, by the way.) This is patently clear in the division in the town that has come with Santos' unwelcome project. More advanced cases can be seen all through the gas belt in Qld where communities have been destroyed by the gas industry, people have committed suicide over the effects that CSG has had on them, their families and their farms.

9. Ruination of the Countryside and Loss of Amenity
I live in rural Australia. If I wanted to live in an industrial wasteland I would move to one. If the Santos project is approved I will have an industrial wasteland forced upon me.

10. Stakeholders
Kevin Humphreys & Peter Mitchley have both inferred or said outright that people who don't live in "the area" have no right to a say on this.
Wrong.
In Australia we have freedom of speech, of course we have the right to have a say on this.
Stakeholders have been narrowly defined - no doubt in an attempt to discredit opponents. One could even suggest that The Pilliga has been chosen as Santos' first project in this basin precisely because it is sparsley populated. But there are plenty of precedents where people living elsewhere have fought against bad policies concerning a particular place, for example Lake Pedder in Tasmania. As Australians we have the right to do this whether we live there or not.

11. Political Donations
On the internet someone asked why Santos has donated money to political parties, they asked "what are they buying". It makes you think, because public companies don't spend money on philanthropy - they want something for their money, and Santos have paid a lot.
https://newmatilda.com/2012/02/06/gas-drillers-bring-heavy-hitters/
https://www.getup.org.au/campaigns/coal-seam-gas/the-santos-law/no-special-laws-for-santos
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;db=CHAMBER;id=chamber%2Fhansards%2Faf5e9bce-9bd9-45dc-bd87-c1d5218a5d66%2F0186;query=Id%3A%22chamber%2Fhansards%2Faf5e9bce-9bd9-45dc-bd87-c1d5218a5d66%2F0000%22
http://www.abc.net.au/news/2016-02-01/political-donations-parties-data-search/7129064
http://www.theland.com.au/story/3991134/santos-under-the-microscope-over-undisclosed-political-donations/?cs=4951#!

12. Health
CSG is like smoking - it's not illegal but it's bad for your health. Plenty of anecdotal evidence for this and increasing amount of scientific evidence.
We don't want it.
NIMBY - Not In My Backyard.
I don't wish it on anyone else, either.

13. Methane
We've all seen the footage of Jeremy Buckingham lighting up the fugitive methane in the Condamine River in Qld. That methane comes from the CSG industry there. Methane leaks out and when you put down what is essentially a bore to bring it up to the surface it's hardly surprising. Why allow this in the first place? It's such a dirty industry and we'd be far better off without it.
From the article at
http://www.independent.co.uk/environment/gas-power-plants-methane-emissions-120-times-more-study-purdue-edf-greenhouse-global-warming-climate-a7641471.html
"Gas power plants can emit up to 120 times the levels of methane reported by companies to regulators in the United States, according to new research"
No doubt that's World's Best Practice - what Santos will aim for (see above).
"But if natural gas is going to deliver on its promise, methane emissions due to leaks, venting, and flaring need to be kept to a minimum."
"mass-for-mass, methane still has 28 to 34 times the greenhouse effect of carbon dioxide over 100 years."
https://www.commondreams.org/news/2016/08/16/nasa-study-nails-fracking-source-massive-methane-hot-spot

14. Siding Springs
The dark sky park that has been declared and the observatory that depends on that are being sacrificed to this project. Gas flares will be going 24 hours a day so the night time will not be dark any more. Why does Santos' have a more priveleged place than the world class Siding Spring Observatory? Why is Santos allowed to have its project and Siding Springs has to pay the price?

15. Those who can't make submissions
Animals and plants have value. It might not be a dollar value but it's a real value nonetheless. Of course they can't enter the debate about the Narrabri Gas Project which will kill many of them. What was the point of the govt. spending
$40 million on the rewilding the Pilliga project if Santos is allowed to proceed? http://www.thecourier.net.au/news/world-first-for-pilliga/

16. Dishonest behaviour and sharp practice?
On the internet I saw this:
"Residents stuck living near the Chinchilla gas field have been posting for a
week now ... "why has the gas flaring stopped?"
"Now we know ... the NSW Dept of Planning visited to view 'first hand" what
the problems are. What an absolute scam by the CSG industry!"
NSW Government agencies visit Queensland gas fields
Date: 12.05.2017 Departmental Media Release

Is this true? Did you go for a first hand look and they turned off the flares so you'd get a better impression of their industry and operations?
If that did happen it speaks volumes and is pretty much the CSG industry themselves admitting that World's Best Practice might not pass muster with the NSW Dept. of Planning.

17. My Recommendation
My Recommendation is that you refuse approval for the Narrabri Gas Project. It is wrong on so many levels. There is huge opposition to it and if approved there will be a backlash like the one in Lismore that frightened the govt. into buying back the licence there. I suggest the govt. buy back Santos' licence - like they did near Lismore - and that the whole area feeling the menace of Santos' current and future gas projects be liberated from that threat by the govt. guaranteeing that they will not now, or ever, allow CSG or fracking there.

I have uploaded my submission objecting against the Narrabri Gas Project

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.

I challenge the declaration of David Chubb stating that The information contained in the Santos Narrabri Gas Project Environmental Impact Statement is neither false nor misleading. This EIS is misleading. I raise the following points in regard to this which concurrently support my objections to the Narrabri Gas Project.

The Environmental Impact Statement forward States,

"The ability for natural gas development to co-exist with agriculture and other industries is demonstrated by Santos' Queensland natural gas operations, where it has in excess of 850 agreements in place with more than 300 landholders."

A majority of those agreements were made when the side effects of natural gas operations were not known. As a result of this invasion on land holders properties and the discovery of negative side effects, there have been many community meetings in protest of the mining processes and the Lock the Gate community has been formed to educate on the dangers of, and to assist the public to keep the natural gas industry away. This form of mining is mostly unwanted by Australians. Santos has a poor record of respecting the public interests or dealing with issues raised from their mining methods. They also have a track record of denying any problems exist and claim that their mining methods are wonderful and perfectly safe when the community knows first hand that it is having negative impacts on their water quality, water availability, air quality and health.

As a result of this poor history, I do not trust the environmental impact statement claims that there is not expected to be any significant environmental problems caused by the Narrabri Gas Project.
I would expect at least acknowledgment of where there have been problems in past gas projects and why this project is different. Also because of the over positive conclusions, there are insufficient action plans created for any negative environmental impacts that may arise.
Reports from the local community claim their only source of water is the from the Pilliga sandstone layer. There is no tolerance for any degradation of that water supply. Given the history of coal seam gas mining, there is no guarantee of zero contamination. So therefore this project is too risky.
It is claimed there are financial benefits to the community, but if the ground water is poisoned, within the 20 year mining period, there will no longer be a community remaining.

The Environmental Impact Statement forward also states,

"Santos has gained a strong level of support within the broader Narrabri community through its demonstrated commitment to operating safely and its extensive local engagement since acquiring the operations in late 2011."

Contrary to this statement, a recent poll by the local community of the broader Narrabri community found that the greatest support for the Narrabri Gas Project was a maximum of only 7% of people. This can hardly be called "a strong level of support" The Narrabri gas project is not wanted by 93% of people.

The Executive Summary states,

"Without developing gas of its own, NSW has no ability to manage its own energy supply security in a changing energy market"

However the current gas supply security crisis and changing market has been deliberately created by Santos itself by purposefully diverting gas that was previously supplied to NSW, toward supplying the export market. Santos does not care about energy supply security in NSW.
There is no reason why Santos could not divert the gas from the Narrabri gas project to the export market if it were to be more profitable. The fact is, there is no security working with Santos.
Santos has manufactured this crisis and are now creating pressure on the NSW Government to approve the Narrabri Gas Project that the NSW community does not want. Santos is not working with the Australian community in mind, it is working for the export market and its own profitability. Any Government office Supporting Santos over the NSW community will be committing treason, supporting a foreign interest over the wishes of the people of Australia.

Another statement from the executive summary,

"Should the project not proceed, and if a feasible alternative to current gas supply is not found in the short term, there is a risk that jobs may be lost, large industrial gas users may close and there may be gas shortages."

Once again Santos is fully aware of this potential problem and has uncaringly diverted gas away from NSW to the export market, supporting international industry over Australian industry. They have over committed to their export contracts and now expect the Narrabri community to pay for their mismanagement and greed.

With the environmental impact statement being overly positive, and with the fast construction of the initial wells over the first 3 to 4 years. I am concerned that by the time the negative environmental impacts are recorded, it will be too late to discontinue or reverse the environmental damage.

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

Sincerely,


Paul Branko.

NSW Department of Planning and Environment
G.P.O. Box 39
SYDNEY NSW 2001
20th May 2017

Re: Submission Regarding the EIS for the Proposed Narrabri Gas Project (SSD 14_6456)

Dear Sir / Madam,
I am president of the Great Artesian Basin Protection Group, and I thank you for this opportunity to present our submission to the Santos Narrabri Gas Project EIS.

The Great Artesian Basin Protection Group Inc. (GABPG) strongly objects to this Narrabri Gas Project (NGP) on so many grounds. This EIS is a proponent-driven exercise in spin and outright misrepresentation. Santos has had so many years to get their paid proponents to write this report, and yet we are given a couple of months to work through it and respond. There are so many flaws in this EIS document that it is hard to know where to begin, or to have time and space to list them all. So I will simply focus on the Great Artesian Basin (GAB), and the known impacts to it.

Our organisation (GABPG) has enormous concerns about the devastating impact that Coal Seam Gas mining is already having on the Great Artesian Basin (GAB), and the impact that the loss of the GAB will have on rural Australia, and on all our communities - and indeed, on all of Australia. And also the impact that CSG mining will have on our immediate and on our long term physical, social, environmental and economic wellbeing.

But the immediate threat for us here, is from Santos' Narrabri Gas Project (NGP) which has already had 26 known and documented spills, leaks and incidents - that we know of. And all of these were reported by private citizens - they would have never been discovered had it been left to the "self -monitoring" of Eastern Star Gas and Santos.

Santos are drilling through the aquifers of the southern recharge of the GAB, and we believe they are causing irreversible damage, right now.

Australia is the driest inhabited continent on earth - but we have one incredible resource, our Great Artesian Basin. It lies under 22% of Australia, and is the largest and deepest artesian basin in the world. The GAB water is plutonic water, millions of years old - and it is finite.

Many decades ago, govt. hydrogeologists realised that the extraction and wasting of waters from the Basin was unsustainable - and after almost a century of waste and mismanagement, GABSI (capping and piping the free-flowing bores) was introduced. GABSI was a proven success, it was saving massive amounts of water, and the pressure was being restored. But not long after the govt. and landholders started capping, piping and conserving the water, the CSG industry arrived. CSG extraction does the exact opposite of GABSI, and is undoing all the good work that 15 years of GABSI has achieved in restoring pressure to the GAB. GABSI conserves the pressure and the water, while CSG mining must remove the pressure and the water. Hydrogeologists now recognise that the GAB must be treated as finite water, as the recharge is so minimal. And yet we are losing the equivalent of Sydney Harbour (500,000 megalitres) every year. Future Australians - when they have no groundwater left - are going to ask how we could have wasted and plundered this vital resource, the way we are doing at present.

More than half a billion dollars has been spent so far (by govt. and private bore owners) in the GABSI scheme - capping and piping and trying to restore the falling pressure, over the last 15 years. And then came the coal seam gas industry - where they have to de-water and de-pressurise the coal seams, to extract the gas. Which is the exact opposite of what GABSI has been doing. CSG mining will not only drain the GAB, but is destroying the pressure, and of course the groundwater can't be brought to the surface without pressure.

The volume of water to be removed from the aquifers by the CSG industry, is staggering, and quite literally unsustainable - up to 12 million megalitres for the 20-year life of a single gas project. John Hillier's report (which had to be privately commissioned and paid for, as the govt. would not commission any such report!) - proved what everyone already knew (but that CSG companies kept denying), namely that the coal seams and the GAB are hydraulically connected.

National Water Commissioner Chloe Munro said: "We recognise that if not adequately managed and regulated, the CSG industry risks significant, long-term and adverse impacts on surface and groundwater systems."

Information obtained from environmental clean-up sites shows that known toxins are routinely being used, including hydrochloric acid, benzene, toluene, and xylene, as well as formaldehyde, polyacrylamides, and chromates. These chemicals include known carcinogens and other hazardous substances.

Typical releases from gas wells include BTEX (benzene, toluene, ethyl benzene and xylene), volatile organic compounds (VOCs), poly-aromatic hydrocarbons (PAHs), heavy metals and other compounds naturally present in coal seams. All these substances affect the respiratory system. 25% are carcinogenic; 37% affect the endocrine system; 52% affect the nervous system and 40% affect the immune system. They can and do contaminate air, surface water and underground water systems.

But it's not just the chemicals used in fracking. Even if they don't frack, toxic chemicals are used in the drilling fluids, and are also naturally occurring in the coal seams anyway. The very act of CSG extraction brings poisons and carcinogens to the surface, and into the food chain.

Firstly, even without hydraulic-fracturing, there are naturally occurring heavy metals and toxins in the coal seams - elements that should never be brought to the surface, and should be left deep in the seams underground, but the coal seam gas extraction brings them to the surface.

There are dozens of toxic and carcinogenic elements in the coal seams, but the main ones are arsenic, cadmium, lead, mercury, chromium, thorium, uranium. Old uranium is 'series soluble' - and its not only what they add (in drilling fluids) when extracting the gas, but also what is mobilised from the coal and is brought to the surface; the chlorium isotopes and other radioactive elements in the uranium decay series.
Of the 12 elements, the final element is lead, and only the tiniest bit of lead will kill you. But the big concentrations are salt - potassium chloride in the drilling process, and also in the coal seams. Potassium chloride is the No. 3 choice of killer, in many U.S. states, as a lethal injection - and yet it is used in huge quantities in CSG drilling, as it breaks down the silica.

The drilling oils and surfectants are proprietary, and no-one knows what's in them. Man makes 77,000 organic chemicals, and we have virtually no toxicity information for any of them. BTEX chemicals (benzene, toluene, etc.) that everyone is worried about in fracking fluids, are freely used in drilling aides anyway, and are also naturally occurring in coal seams.

A hydrogeologist/geochemist told me that he has asked many mining companies whether they will allow him to test the water at the bottom of the wells, when they have completed a well. But he said none of them will ever let him test. Because they know that the deeper they go, the more toxic it gets.

When last measured some time ago, over 300 gas wells in the GAB were leaking - they are fractured below the ground (from hydraulic fracturing) and are continually venting raw methane into the environment, and into the artesian water. Research in the US has shown that fugitive natural gas emissions may contain many contaminants, some of which are known human hormone system disrupters and others have non-cancer and cancer end points.

The `Triple-Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31, poses an even greater danger to the Great Artesian Basin and other aquifers than from ordinary wells, as it is very difficult, if not impossible, to seal the junction between the casing and the lateral. When questioned about sealing these junctions, the Chief Scientist Professor Mary O'Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drilling fluids or gas escapes and the down draining of aquifers.

All gas wells leak in time, 6% leak immediately, and within 20 years, 30% leak. As Santos will be long gone by then, who will bear the future cost of rehabilitating the corroding and crumbling wells, that have lost their integrity?

Of enormous concern is the 'cement deterioration' issue. Cement has been shown to lose integrity quite quickly, depending on the aquifer and environment it is in - not even taking into account the corrosion caused to the casing by the saline water in the aquifers. I would like the govt. to tell us which department they have allocated to supervise the rehabilitation, maintainance and ongoing inspections and repairs to these gas wells, for the next thousands of years - when Santos (or the other gas companies) will have long gone? And which govt. economist has costed out what this will cost taxpayers in the future, trying to inspect, maintain and rehabilitate all these corroding wells, under the ground, forever?

It is well documented, that removing the masses of water and gas from the coal seams, creates voids, and then subsidence as the earth pressures readjust; which (combined with the natural faulting and movement in the stratas), causes increased seismicity. Just the act of CSG extraction causes seismicity and earthquakes, but when you add fracking - and then re-injection - it is unavoidable that there will be earthquakes in the future. In the US they are getting multiple earthquakes weekly, which have been proven to be directly linked to fracking and re-injection. In England some years ago, a County had their first recorded earthquake in their long history, and (what a surprise!) there was a gas drilling rig 100m away. Is it a co-incidence, but suddenly our State Governments have stopped their seismic monitoring at any earthquake-prone sites?

Riverbeds and waterways are cracked and damaged allowing methane to escape. The Condamine River bubbles with gas - as filmed recently and widely viewed, it can be set on fire. Seismic activity is caused by the rock fracturing, done to release the coal seam gas. Exploration involves seismic surveys, followed by deep drilling of many wells, and by the time the Development Permit is applied for, most of the environmentally damaging work has already occurred - without any environmental impact statement having been done.

If we get toxicity or a problem in the water, cattle from this area could be banned - as in the Kingaroy area when toxins were found in the bore water. Australian export meat has an enviable clean record - we must not spoil that. And it has been stated that it is a highly likely outcome that in the future, meat buyers will not want stock from a known CSG area, as there must be a perception of safety with the product.
A Queensland stock & station agent has said that already they (the buyers) won't buy cattle at sales for slaughter (for export), if they come from "certain areas" of the Darling Downs. He said that they "test much more stringently" for export meat, than for the domestic market, and so the agents won't buy export slaughter cattle from certain areas - only for the domestic market. So apparently we are eating the contaminated meat!

Such strict regulations and care must be taken when handling chemicals for farming - yet there are no such regulations with these CSG drilling chemicals. At the start of the Qld. floods a couple of years ago, 54 totally toxic storage dams burst / overflowed / totally flushed out initially during the floods, and discharged 30 years of accumulated toxins and carcinogens into the rivers and waterways. The CSG companies applied to the govt. for another 1186 other dams to all flush out too - they wanted to empty out all their poisons while the rivers were so high, for the "dilution" factor. A geochemist in Dalby said they work on 'dilution by volume' (i.e. that a thimbleful of arsenic in a river is "acceptable"). And can claim Force Majeure during floods. The north west area where Santos intend to spread out to form their massive gas field, is a flood plain - do we want these chemicals and toxins in our rivers, and washing over our land?

Of huge concern is the salt pollution left behind, 6-8 tonnes of salt produced for every megalitre extracted. It is estimated that millions of tonnes of salt per year will be brought to the surface onto prime farming land, rendering it useless. Other estimates for this contaminated salt have reached 50 million tonnes. This contaminates the farming land - and Santos still has no idea what to do with this salt, from the contaminated `waste water'. The best Santos could come up with was that "it will go in landfill somewhere."

Between 30,000 to 60,000 litres of drilling fluids are used to drill each well, and approximately 35% (and up to 100%) stay down in the wells and are never brought back to the surface. Once these fluids have gone into a permeable rock, then its gone into an aquifer or water body, and has contaminated it. Once the aquifers have been polluted, they can never be cleaned up; once they've been fractured, they can never be repaired. John Hillier's report (which had to be privately commissioned and paid for, as the govt. would not commission any such report!) - proved what everyone already knew (but that CSG companies kept denying), namely that the coal seams and the GAB are hydraulically connected.

And the evidence is unfortunately already appearing. The gas companies are now suggesting alternatives for farmers who have already lost their bores and access to stock and domestic water. In Queensland, many gas companies are already carting water for landowners who have lost their bores - how long will this continue, after the gas companies have gone? And how will it continue, when there is no water left in the GAB? The notion of "making good" is an insult to anyone's intelligence. How do you `make good' for the loss of an aquifer, and how do you replace it? How do you `make good' for the permanent loss of our water? "Make good" is a transparent abrogation of responsibility by the govt. - they should demand that the companies prove beyond any doubt that there is no risk to the water tables, before proceeding.
And it must be noted the incredible amount of water used - the mining industry is allowed "unlimited take" from this finite groundwater. This is simply not sustainable.

A report was recently commissioned by the Australian Government and Great Artesian Basin Jurisdictions titled "Economic output of groundwater dependent sectors in the Great Artesian Basin" by Frontier Economics (Frontier, 2016) (attached). In table 1, it states that the combined value of industries dependent on GAB water resources in NSW is as follows: livestock, irrigated agriculture and urban water totals $1132.3m, mining and CSG $576m, annually. Livestock, agriculture and the provision of water to towns is sustainable into the unending future. Mining and CSG have a limited lifespan and will leave irreparable damage and costs forever. Is a short term benefit worth the long term, permanent pain? And the ABARE data this year showed a record return from agriculture - why risk a viable, productive, sustainable industry (agriculture), for a short-term destructive industry (CSG) with no economic return to the Australian people?

And our govt. representatives shriek with joy "Jobs, jobs, jobs", whenever a mine or CSG project is mentioned. But with regard to employment, we have to be clear about who this sector employs. If you're thinking about Australian society as a whole, the mining sector only employs 1.3% - about 135,000 people directly. And agriculture employs about half a million people directly. So if we're concerned about the impact of the mining boom on society in general, then clearly if it's going to have a negative effect on agriculture, then we have to be concerned about the welfare of that half a million people, as against the 135,000 people, that are employed directly in the mining industry.

This Santos NGP is so wrong on all counts - it has nothing to recommend it on any level. The American experience chronicled so disturbingly in Gasland, is now being rolled out all over Australia - and especially above our Great Artesian Basin. The consequences will be disastrous - a long-term legacy of destruction left behind, for a short-term financial and political gain. How can they justify this? How can they possibly sacrifice our prime farming land, and Australia's single greatest resource, the Great Artesian Basin, one of the wonders of the world, for such a short-term monetary gain, and one that comes at such an enormous future cost? This water is needed for towns and communities, for people, for food production - not for foreign and multinational gas companies.

The Great Artesian Basin is of such vital importance to rural Australia. The towns, communities, farms and industries rely totally on GAB water. Our greatest resources aren't coal, gold, uranium, or gas - the single greatest resource Australia has is our GAB. It is inconceivable that governments could put at risk this priceless water.

Our country is a signatory to the Rio Convention, which says we must adopt the Precautionary Principal - "In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation". (From the Rio Declaration on Environment and Development, a key international agreement currently in force to which Australia is a party).
Our govt's have been spouting that they support the "precautionary principal" - but still, nothing happens.

As I am writing this, right now, the GAB is being fractured, de-pressurised, drained and poisoned - each day the destruction goes on, and each day it grows more critical, as governments do nothing to legislate or protect our priceless and irreplaceable water. Our finite water. And I honestly believe that if we don't take a stand and stop this industry soon, it will be too late.

Water is the one non-negotiable essential for life. And the Coal seam gas industry will destroy it. And Santos' Narrabri Gas Project is the first nail in the coffin.

Thank you for this opportunity to present our concerns. I have a lot of further evidence I would like to present, if the occasion arises.

Yours sincerely,

Anne Kennedy

President,
Great Artesian Basin Protection Group
0429 023007
[email protected]

See attached.