Narrabri Gas

To Whom It May Concerned,

I am opposed to the Narrabri Gas Project. I grew up in rural NSW, then went off an obtained a PhD in Electrical Engineering and worked around the world.

I have returned from working in the USA and have seen and heard the devastation that these practices have on the land, majorly the water table, and water pollution. There are many and varied effects on health. I have attached 3 supporting documents that detail the widespread illness.

A thought experiment for the decision makers. Imagine I asked you to put one drop of petrol, in your breakfast cereal every day. Would you do it? This is a way to explain, just because you cannot see things doesn't mean they are not there. Now imagine after 3 weeks of putting this one drop in everyday, you start to get nosebleeds, more and more nosebleeds. Do you stop putting the drop of petrol in your cereal? What if I tell you its in the kids cereal too? This is the reality of water table pollution due to gas extraction.

In an engineering sense, there is not containment, the water table constantly moves under us. As the gas comes up some is lost, if fracking practices are used then your pumping chemicals directly into the water table. The point is it is rare that any scientist will support gas extraction due to the fact that some gas - long chain hydrocarbon - same as petrol - will leach into the water, and the locals will drink it. Cost to the NSW medical system to treat these people will be high, cost to the community will be massive.

Please understand that in Victoria we build more and more solar farms everyday for around 6-10c/kWh. People are paying 20+c/kWh for this gas based electricity. Thus it is cheaper to invest in solar energy. We see this change with a large investment occurring in solar PV energy right now in Australia.

The Australian population has stood up time, and time again, against CSG and fracking. I ask that you start to listen. No CSG, no fracking in Australia. Take a trip to the USA and see the destruction, you won't want to support it.

Sincerely,
Dr. Christopher Rowe
Bach EE, PhD EE.

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Please find attached my submission

I absolutely do not agree with Coal Seam Gas mining in the Pillaga (or anywhere else) for many reasons, but my primary reason is one of health concerns for all Australians.
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1. Health Concerns. The health of all people who continue to live and work in the immediate vicintiy of CSG mining is at direct risk as many studies are now showing. The risks that CSG mining poses to our water and food security will also impact on the health of all Australians. These combined health risks are far greater than the purported benefits CSG is supposed to contribute. See attached article with reference list of relevant articles.

2. It is neither necessary, nor smart, to be investing in CSG energy when the renewable energy technologies are more reliable, enviromentally sustainable and ultimately cheaper than energy created from CSG. The invention, development and manufacturing associated with these new technologies should be the economic future of Australia.

3. Environemental degradation. About 1000 hectares of the Pilliga temperate woodlands will have to be cleared causing initial environmental damage, loss of habitat & wildlife, and erosion.

4. Water security for NSW. Australia is a dry continent with land west of the great dividing range relying on the groundwater that the Great Artesian Basin makes availble to western NSW farmers. CSG mining will not only pollute this underground water resource, it will seriously deplete the amount of water that is availabel in the future.

5. The waste water that CSG mining creates will also poison the surface water and soil with its toxic salts. No acceptable treatment for this waste water has been put forward yet.

6. Air pollution. The large, deliberate and fugitive burning of methane will pollute our atmosphere adding to climate change.

7. Food security. The polluted ground and surface water will place our agricultural industries at serious risk and will ultimately jeopardise the food supply and security of NSW.

8. The First People's cost. The spiritual and cultural heritage, along with the current society of the Gamilaraay people will be disregarded and damaged beyond repair. Enough!

Public sentiment has turned against this type of development and it would not be politically clever for any government to pursueCSG mining. The people of NSW have a perception that NSW politicians and decision makers are making short term decisions to feather their own nests instead of actions that will provide long term benefits to the people of NSW. Pursuing CSG mining in the Pilliga will strengthen this perception and ultimately hurt politicians who support it.

I seriiously hope that these submissions are read in full and the strength of feeling that is required for the Australian public to participate in this process are fully appreciated.

Please do not continue with this project, for the benefit of all Australians, now and in the future.

Regards,
Carol

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Please find attached a submission from Walgett's Dharriwaa Elders Group.

This submission objecting to the proposed SANTOS gas field at Narrabri is by Mark Anning, a MBA-qualified journalist of more than forty years experience. I've spent 12 years with the wire services, AAP, Reuters & The Associated Press and have worked for both sides of the House as a journalist (Freelanced for Mike Egan ALP in the 80s, and Michael Lavarach, the ALP federal Attorney-General in the mid-90s, then staff journalist for Peter Slipper LNP for a short time in 1994).

I am a former manager for the Sunshine Coast Regional Economic Development Board (successfully managing sustainable economic growth in a high value environmental region for three local councils) and have sat on various committees for the three tiers of government, including state authorities (Queensland Fisheries Management Authority ZAC). I was accredited to the 1991 G7 Economic Summit, 2002 CHOGM and commentated on the 2007 APEC meetings whilst living within the security precinct.

Contrary to allegations made online by the gas industry, I am not paid, employed or funded by anyone to present these concerns about fracking and the gas industry in general. I have never made any political donations.

As a farmer directly affected by a coal seam gas exploration license at Gloucester NSW, I began looking into the issue and found serious and genuine concerns about the health, environment and economic effects of the inappropriate and unsustainable gas industry.

Who can we trust?

Firstly, the disclosure of the true nature of the effects that gas extraction has had on Queensland has been grossly hampered by the industry's insistence on farmers signing Confidentiality Clauses and their buying up the worst affected land. This has silenced dissent & complaints and has prevented many cases of contamination being made public.

We note that a landmark court action Nothdruft Vs QGC (Royal Dutch Shell) & Others, begins hearing on Monday, 22nd May 2017 - coincidentally, the same date that submission closed for this EIS. We can expect more court actions to follow in Queensland, and more if this approval is given for SANTOS to operate in NSW. (1) (2)

(1) Initially happy with the CSG arrangement, the Nothdurft family were eventually surrounded by 30 wells within 2.5km of their house and which they claim is causing ill health.
https://www.youtube.com/watch?v=BA0c-C99CQI
(2) A WESTERN Downs family is taking Queensland Gas Company (QGC) to Land Court in what is being described as a "landmark" case.
Nood and Narelle Nothdurft signed a compensation agreement with QGC in in 2006 for seven gas wells on their property.
Citing noise emissions breaches and health issues - namely headaches and nosebleeds - the Nothdurft's representative, George Houen of Landholder Services Pty Ltd, said the family would be arguing that there had been a material change in circumstances since the agreement was signed. https://www.chinchillanews.com.au/news/chinchilla-family-in-landmark-court-case/2979855/

The gas industry has bought some of the worst affected land. As of 30 June 2015, QGC own 0.04% of Queensland's land area (3). They have since purchased more, so too have other gas companies. We note that many of the landholders speaking out in favour of gas wells on their properties do not also host the associated infrastructure and vents, and many do not live on the affected properties.

(3) 73,758ha across the Surat Basin. 0.04% of Queensland's land area
http://www.bg-group.com/files/pdf/qgc/qgcataglance_aug15.pdf

The fact that SANTOS will be self-monitoring and self-reporting is of concern. (4) We note that the NSW EPA is under-funded to carry out independent monitoring.

(4) Pollution monitoring data that is required to be collected by a licence condition must be published by the licensee in accordance with section 66(6) of the POEO Act and with the written requirements issued by the Environment Protection Authority (EPA).
http://www.epa.nsw.gov.au/licensing/pubmonitdata.htm

We have already seen the gas industry, and SANTOS in particular, failing to report breaches, see elsewhere in this submission.

Second point, the NSW Chief Scientist reported that gas extraction is "safe if properly regulated". (5) I meet Mary O'Kane during her Inquiry and appreciate the difficult task that she was given.

(5) The long-awaited independent review of coal seam gas (CSG) in New South Wales, released last week by the NSW Chief Scientist, highlighted many risks and uncertainties around human health from exposure to toxic CSG chemicals.
Despite this, the report concludes the risks can be managed through unprecedented regulation and monitoring.
But major health concerns remain unresolved. These include regulatory inadequacies, cumulative chemical and mental health risks, safety breaches, and climate change.
Hence, the report leaves many health concerns regarding human health effects from CSG activities in NSW unanswered. https://theconversation.com/chief-scientist-csg-report-leaves-health-concerns-unanswered-32422

It should be noted that the "Independent Review of Coal Seam Gas (CSG) Activities in NSW" inquiry's Terms of Reference asked, in effect, "How can this industry proceed?" - she was not asking "Should this industry proceed?" I have no doubt that she would have come to a different conclusion if she was tasked with asking the right questions.

O'Kane, to her credit warned "The risk to human health and the environment posed by coal seam gas can be managed but "unintended consequences" due to accidents, human error and natural disasters are inevitable, the state's top scientist says. (48)

(48) Coal seam gas will have 'unintended consequences', says chief scientist
http://www.smh.com.au/environment/coal-seam-gas-will-have-unintended-consequences-says-chief-scientist-20140930-10oblo.html

Mary O'Kane claimed, during our meeting, that "fracking had been done safely in Australia for decades". She became speechless when I pointed out that the modern fracking process was invented in 1998 by George Mitchell, known as the Father Of Fracking.

Mr Mitchell combined three processes: fracking (aka hydraulic stimulation), slickwater (the injection of chemicals, especially guam - which is now experiencing a worldwide shortage), and horizontal drilling.

Before Mr Mitchell's invention, the use of fracking was rarely done because it was uneconomical. It was Mitchell's invention that created the current boom in gas exploration in 1998 - not even two decades ago. (6)

(6) He did not discover shale gas and oil: geological surveys had revealed them decades before he started. He did not even invent fracking: it had been in use since the 1940s. But few great entrepreneurs invent something entirely new.
He spent decades perfecting techniques for unlocking them: injecting high-pressure fluids into the ground to fracture the rock and create pathways for the trapped oil and gas (fracking) and drilling down and then sideways to increase each well's yield (horizontal drilling).
"In 1998, with Mr Mitchell approaching his 80s, his team hit on the idea of substituting water for gunky drilling fluids. This drastically cut the cost of drilling and turned the Barnett Shale into a gold mine".
George Mitchell fused two technologies - hydraulic fracturing and horizontal drilling and added a cocktail of chemicals to the fracking process which made the process economical. http://www.coal-seam-gas.com/usa/history.htm

Both the process and the scale of modern fracking compared to 'decades' ago is like comparing apples to oranges. The industry's claim that "fracking had been done safely for decades" is at best 'spin' or a cynical marketing claim, and at worst, a blatant lie.

Before leaving George Mitchell's contribution, note that he became very concerned by the impacts of his invention.

George Mitchell: "As a concerned businessman and philanthropist, I have come to understand that the natural gas industry can no longer simply focus on the benefits of shale gas while failing to address its challenges.
"We know that there are significant impacts on air quality, water consumption, water contamination, and local communities." (7)

(7) The Economist http://www.economist.com/blogs/schumpeter/2013/08/interview-george-mitchell

Thirdly, the CSIRO chief Larry Marshall explains the new funding regime within CSIRO and GISERA:

Larry: (Chuckles) so chasing the dollar is not a strategic move. But, we absolutely are constrained by our funding envelope. So we try to secure funding to do things that we believe will build strategic value in the company. Sometimes that customer is the Federal Government, State Governments, industry, the public, but this funding, this revenue is not an entitlement, we have to earn that. When we get funded, whoever, the funder is, they're funding us to do something and they expect a deliverable, a result, so if we don't earn that, if we don't deliver that result they will cease funding us, and CSIRO has experienced that many times in the past. We also have to respond to shifts in global markets, as priorities shift, we have to recognise that and always be in a position where we're able to deliver the most value we can to our nation in response to those shifts. (8)

(8) CSIRO website https://www.csiro.au/Vimeo/Larry-Interview-CSIRO-changes/video-transcript

Unfortunately since the new CSIRO fund raising policy, we have seen instances of CSIRO-GISERA making claims that are not entirely accurate, certainly not scientifically accurate, and not in the best interest of the general population.

For example, their study of fugitive methane emissions was attempting to establish 'baseline' data in 2014. (9) It wasn't until I made the point that baseline data could not be established years after the gas industry had been operating in the area, that they corrected their publication.

(9) "Taking a measured approach to CSG - CSIRO through the Gas Industry Social and Environmental Research Alliance (GISERA) is undertaking a comprehensive study of methane seeps in the Surat basin."

Mark Anning says
20th October 2014 at 11:27 pm
It's stunning to see the coal seam gas industry funded Gisera redefine the word "baseline".
Baseline used to mean "a minimum or starting point used for comparisons" but now GISERA is establishing the baseline after the industry is in "full swing".
I genuinely appreciate that the CSIRO has had funding cuts and now must rely on the coal seam gas industry for dollars ... but PLEASE be aware that farmers, rural residents and indeed all Australians need truly independent baseline data if there are legal actions resulting from spills or contamination.
There are hundreds of such legal actions in the USA, so expect them here too!
What you've done here is akin to establishing the `baseline' data for a smoker or asbestos worker after they've been exposed for years.
C'mon CSIRO ... don't be part of the gas industry spin and change the "facts". Australian people are relying on you to get this right!

Nicholas Kachel says
21st October 2014 at 11:37 am
Hi Mark
Thanks for your comment. You are entirely correct: `baseline' was the wrong word to use in this instance, and the blog has been amended accordingly.
Cheers
Nick
https://blog.csiro.au/taking-a-measured-approach-to-csg/comment-page-1/#comments

Australia laments the loss of it's independent, employed scientists. Unfortunately the new arrangements which "expect a deliverable, a result" for the benefactor cast doubt on the 'independence' of their work. That may be unpalatable for many, but it is true.

We have all got better things to do than monitor these so-called 'independent' monitors. However, NSW Planning has to appreciate that we live here. We WILL be monitoring and reporting on every breach and going to court if necessary, if this project is approved.

Fourthly, we note that Anthony Roberts is now NSW Planning Minister. It was very disappointing to see him label the farmers trying to protect their water, air and land from the effects of coal seam gas as "extremist protesters" and then go on to publish three 'untruths' to support his claim, for his political reasons.

Alan Jones read this webpage on my website on his radio program (10). It is ironic to be labelled an 'extremist' by someone supporting an industry that endangers the health of citizens, risks the environment and damages our sustainable economy.

(10) http://coal-seam-gas.com/australia/bentley05.htm
Finally, before leaving this segment on "who can we trust?" - I ask "can we trust the gas industry?" We note that social media from those stuck living in the gas fields near Kenya Plant in Queensland were wondering why the gas flaring had stopped during the first week of May 2017. The answer came in a press release from NSW Planning, dated 12th May 2017 (11).

NSW Government agencies visit Queensland gas fields
Date: 12.05.2017
The Department of Planning and Environment and other NSW Government agencies visited Queensland last week to meet with government representatives and inspect coal seam gas projects near Chinchilla as the Narrabri Gas Project public exhibition draws to a close.
The contingent of NSW Government planning, environment and water experts visited Queensland to gain a better understanding of the issues faced by communities and government regulators associated with the development of the coal seam gas industry in that state.
Mike Young, Director of Resource Assessments at the Department of Planning and Environment, said the visit was very informative and important for the NSW Government.
"While the Queensland gas fields are much larger than what is being proposed in NSW, our trip last week helped us gain an appreciation of the kind of issues that will need to be considered in the assessment of Narrabri Gas Project," Mr Young said.

(11) NSW Government agencies visit Queensland gas fields
http://www.planning.nsw.gov.au/News/2017/NSW-Government-agencies-visit-Queensland-gas-fields

We have to surmise that NSW Planning did not get a fair and accurate examination of the normal operations of the Queensland gas fields during their visit - instead they got the "PR" tour organised by the gas industry.

With such sheenigans going on, it is my conclusion that NSW Planning must reject this EIS as they are not being given truly independent information to assess, and they're decision making is deliberately being hampered by the gas industry.

The Environmental Impacts.

I concur with the environmental concerns, particularly:

* The fragmentation of the state forest due to the clearing of 988 ha of native vegetation, including 700 ha of State Forest (12) which directly affects the 'vulnerable' koala population (13) and other native species which deserve to be protected for the future.

(12) Clearing of 988 ha of native vegetation, Page 28 https://majorprojects.accelo.com/public/84a9c618542ac22cbf04c4d5552a72d5/Appendix%20U1%20Economic%20assessment%20_cost%20benefit%20analysis_.pdf

(13) Koala listed as vulnerable http://www.environment.gov.au/biodiversity/threatened/species/koala

* The effects of gas extraction on the Great Artesian Basin and other groundwater aquifers. We are all aware of the 'perfectly safe' claims made by the gas industry, however the facts prove a different story.

In 2011 the NSW Government banned the use of BTEX chemicals in CSG fracking fluids (14) however naturally occurring BTEX can and has been 'mobilised' during gas extraction at Gloucester (15). Whether the BTEX is mobilised 'naturally occurring' or injected, the effects on our finite water supply will be devasting. (16) (17) (and many other reputable peer-reviewed scientific papers).

AGL, Santos and others in the gas industry use the same drilling companies, so comparisons between their operations are legitimate.

(14) http://www.water.nsw.gov.au/water-management/groundwater/water-and-coal-seam-gas

(15) "AGL informed the EPA that it was aware of these elevated levels of BTEX chemicals on 15 January, but it did not make these results known to the EPA or the public until today," Mark Gifford, EPA Chief Environmental Regulator, said in a statement released late on Tuesday.
"The EPA is very concerned at AGL's lack of timeliness and transparency in informing us of these results and we will be conducting a full investigation," Mr Gifford said.

http://www.smh.com.au/environment/water-issues/agl-suspends-csg-drilling-near-gloucester-after-chemical-find-20150127-12zc80.html

(16) Their presence in water can create a hazard to public health and the environment. http://scialert.net/fulltext/?doi=rjes.2011.394.398

(17) Volatiles such as BTEX compounds can pose a drinking water hazard when they accumulate in ground water. https://www.nature.nps.gov/hazardssafety/toxic/btexcmpd.pdf


In 2011 the NSW Government banned the use of evaporation ponds for the disposal of CSG produced water. ( See Ref.3 above). The fact is SANTOS have just dug a little deeper and renamed their evaporation ponds "holding ponds". My view is such skirting of the ban is literally cynical, that is, lacking sincerity or integrity. We note these ponds were approved and constructed "without an accompanying plan for the treatment of the waste water." (18) These ponds have already leaked (19). The same rationale for banning 'evaporation' ponds must be applied to the SANTOS holding ponds.

(18) Vice Chair of Namoi Water Matt Norrie said the holding ponds, expected to have a total capacity of 600 megalitres, will be used to store waste water being transferred from one of the company's holdings in the Pilliga State Forest.
"Say we get a couple of large rainfall events, and these ponds are already full, because there is no clearly defined plan of what they're going to do with this water, there is a potential risk that if these dams are sitting there full, that these damns could get too full," he said.
"Untreated coal seam gas water, it pretty much sterilises the environment."

http://www.abc.net.au/news/2013-04-02/santos-given-approval-for-holding-ponds/4604944

(19) Santos said on Tuesday that the leak was found when the pond was about one-third full, and the waste water was then drained to allow the repairs to take place. The amount leaked was in the order of 2000 litres a day.
"Why the heck didn't they get back to me with the answer?" Mr Pickard said. "They all tell you they want to get to the information out there ... but you've got to put them in a corner to get it."
http://www.smh.com.au/environment/water-issues/santos-coal-seam-gas-wastewater-pond-leaked-briefly-during-commissioning-20160112-gm44n7.html

* Methane Emissions. It is safe to say that the scientific data for fugitive methane emissions of the methane extraction industry is still coming in. It doesn't take a scientist to work out the high point vents, leaking gas wells and other methane (aka 'natural gas') infrastructure will add to this, no matter what the regulations are.

In popular discussions around climate change and global warming, the effects of methane are largely ignored. But methane is a significant contributor to climate change and half of the methane added to the atmosphere is derived from human activities. There are vast reserves of methane trapped in ice that may escape into the atmosphere as the climate warms. If this were to happen on the same scale as the Permian Extinction, we can expect to see the massive loss of most species of animals and plants on Earth, including ourselves.

The methane concentration in Earth's atmosphere has increased by about 150% since 1750. The current atmospheric methane concentration has never been as high during the past 420,000 years. A surge in methane levels has been detected over the past decade with a further acceleration during 2014-15. Concentrations of methane in the atmosphere during 2014-15 rose by more than 20 parts per billion (ppb), bringing the total to 1,830 ppb compared to ~750 ppb in 1750. (20)

(20) https://www.australiascience.tv/science-update-methane-climate-change-and-extinction/

With Australian fugitive methane emission testing still in progress, it is important to view the comparative results from the coal bed methane gas (aka coal seam gas) fields in North America.

NASA Satellite Data Shows U.S. Methane `Hot Spot' Bigger than Expected
The study's lead author, Eric Kort of the University of Michigan, Ann Arbor, noted the study period predates the widespread use of hydraulic fracturing, known as fracking, near the hot spot. This indicates the methane emissions should not be attributed to fracking but instead to leaks in natural gas production and processing equipment in New Mexico's San Juan Basin, which is the most active coalbed methane production area in the country.
Natural gas is 95-98 percent methane. Methane is colorless and odorless, making leaks hard to detect without scientific instruments.
"The results are indicative that emissions from established fossil fuel harvesting techniques are greater than inventoried," Kort said. "There's been so much attention on high-volume hydraulic fracturing, but we need to consider the industry as a whole."
Coalbed methane is gas that lines pores and cracks within coal. In underground coal mines, it is a deadly hazard that causes fatal explosions almost every year as it seeps out of the rock. After the U.S. energy crisis of the 1970s, techniques were invented to extract the methane from the coal and use it for fuel. By 2012, coalbed methane supplied about 8 percent of all natural gas in the United States. (21)

(21) https://www.nasa.gov/press/2014/october/satellite-data-shows-us-methane-hot-spot-bigger-than-expected/

A report published by the NASA researchers in the journal Geophysical Research Letters (22) concludes that "the source is likely from established gas, coal, and coalbed methane mining and processing." Indeed, the hot spot happens to be above New Mexico's San Juan Basin, the most productive coalbed methane basin in North America (23).

Methane is 20-times more potent as a greenhouse gas than CO2, and has been the focus of an increasing amount of attention, especially in regards to methane leaks from fracking (24) for oil and natural gas. Pockets of natural gas, which is 95-98% methane, are often found along with oil and simply burned off in a very visible process called "flaring." But scientists are starting to realize that far more methane is being released by the fracking boom than previously thought.

Earlier this year, Cornell environmental engineering professor Anthony Ingraffea released the results of a study of 41,000 oil and gas wells that were drilled in Pennsylvania between 2000 and 2012 (25), and found newer wells using fracking and horizontal drilling methods were far more likely to be responsible for fugitive emissions of methane.

According to the NASA researchers, the region of the American Southwest over which the 2,500-square-mile methane cloud is floating emitted 590,000 metric tons of methane every year between 2002 and 2012--almost 3.5 times the widely used estimates in the European Union's Emissions Database for Global Atmospheric Research (26) --and none of it was from fracking.

That should prompt a hard look at the entire fossil fuel sector, not just fracking, according to University of Michigan Professor Eric Kort, the lead researcher on the study:

"While fracking has become a focal point in conversations about methane emissions, it certainly appears from this and other studies that in the US, fossil fuel extraction activities across the board likely emit higher than inventory estimates." (27)

(22) NASA researchers in the journal Geophysical Research Letters http://onlinelibrary.wiley.com/doi/10.1002/2014GL061503/full

(23) New Mexico's San Juan Basin http://www.csmonitor.com/USA/USA-Update/2014/1010/How-scientists-overlooked-a-2-500-square-mile-cloud-of-methane-over-the-Southwest-video

(24) Yale http://e360.yale.edu/features/on_fracking_front_a_push_to_reduce_leaks_of_methane

(25) http://www.pnas.org/content/111/30/10955

(26) European Union's Emissions Database for Global Atmospheric Research http://edgar.jrc.ec.europa.eu/

(27) https://www.desmogblog.com/2014/10/17/nasa-confirms-2500-square-mile-cloud-methane-floating-over-american-southwest

Globally, over 60 percent of total CH4 emissions come from human activities. Pound for pound, the comparative impact (on Climate Change) of CH4 is more than 25 times greater than CO2 over a 100-year period. (28)

(28) US EPA https://www.epa.gov/ghgemissions/overview-greenhouse-gases#methane

Whether we believe human's impact on climate change or not, the fact is the climate is changing. Methane is a large enough component of that to warrant mankind's immediate attention to reducing the amount of methane emissions, not increasing them as this project will do.

We are seeing huge amounts of new methane seeps appearing as the earth thaws. (29) (30)

(29) Scientists say a 'fountain of gas' poured from jelly-like trembling earth in tundra on Belyy Island in northern Siberia. http://siberiantimes.com/ecology/casestudy/news/n0681-now-the-proof-permafrost-bubbles-are-leaking-methane-200-times-above-the-norm/

(30) More Than 150,000 Methane Seeps Appear as Arctic Ice Retreats
Scientists continue to discover more and more of the powerful greenhouse gas escaping from the thawing Arctic https://www.scientificamerican.com/article/more-than-150000-methane-seeps-appear-as-arctic-ice-retreats/

This is alarming:
The result obtained for the Australian CSG wells is also lower than the production average emission factor for pneumatic devices provided in the API Compendium (API, 2009) of 345 ± 49.5 scf d -1 (4.6 ± 0.66 g min-1).
It is not clear why these emission rates are lower than the U.S. estimates; however, it should be borne in mind that the results of our study represent only a very small sample. The Allen et al. (2013) study examined 305 devices compared to only seven in our study. Another reason for the difference may be due to the intermittent operation of the devices. Most of the CH4 emission apparently occurs when the devices operate and hence the frequency of operation has a strong influence on the emission rate so a longer period of sampling may have yielded different results.
Vents installed at various points on some well pad equipment were frequently found to be sources of CH4 emissions. Of the 43 well sites examined, ten had vents, all from Company B, that were emitting CH4 at the time measurements were made. The rate of emissions varied substantially from less than 10-4 g min-1 up to 44 g min-1, which was the highest rate of emissions measured from any source measured during this project. The mean vent emission rate was 6.1 g min-1 with a standard deviation of 13.4 g min-1, reflecting the large range of values.
The third main source of well pad CH4 emissions was from equipment leaks. Most of the wells examined were found to have some degree of leakage from equipment on the pad. The two largest equipment leaks detected were due to leaking seals at Wells C3 and E4. At the time of the site visit, Well C3 was shut-in for maintenance and as a result the pressure on the seal was almost 2 MPa, which was much higher than normal operating pressure and this is likely to have contributed to the high leak rate from the well. This is consistent with a study of leaking wells in Queensland made in 2010 where high CH4 concentrations (up to 6 % CH4) due to leaks were often found on shut-in wells that were under high pressure (DEEDI, 2010).
Despite this, it has been suggested that 6 to 7 % of well completions in the United States are subject to integrity failure that could lead to CH4 leakage (Ingraffea, 2013). Given that we surveyed less than 1 % of Australian CSG wells, it is possible that the small sample size is not sufficiently representative to assess the true extent of well leakage. Further work would be required to conclusively determine the extent of casing leaks. (31)

(31) https://www.environment.gov.au/system/files/resources/57e4a9fd-56ea-428b-b995-f27c25822643/files/csg-fugitive-emissions-2014.pdf

The US average seems to be that 5% of gas wells soon, and the percentage increases over time. About 5% of wells fail soon, more fail with age, most fail by maturity. (32) All gas wells will fail eventually, given the fact that steel and concrete does not last forever, and the ground shifts over time.

(32) US EPA https://www.epa.gov/sites/production/files/documents/ingraffea.pdf

It is notoriously difficult to get industry figures from this industry. (33) Even Minister Roberts complained in the media about not getting data from the industry.

(33) How Much Natural Gas Leaks? Lost gas proves a slippery figure for scientists, industry and government
https://www.scientificamerican.com/article/how-much-natural-gas-leaks/


We can't escape the fact that fugitive methane emissions resulted in Earth's greatest mass extinction event. (34)

(34) Methane Hydrate: Killer cause of Earth's greatest mass extinction
http://www.sciencedirect.com/science/article/pii/S1871174X16300488

I ask you to consider if, in approving this EIS, you are approving a time bomb for future methane emissions. We will certainly be hearing much more on this topic in the years to come, and asking who is culpable.

* Bush fires. The increase in methane seeps caused by gas drilling, the re-allocation of scarce water and the exemption for SANTOS to flare gas in bush fire season all adds up to a disaster waiting to happen.

* Salt - or as it's known in the gas industry "beneficial waste". After all these years, SANTOS still have not given an adequate proposal for the mountains of salt created.

Queensland still has solved the problem, other than dumping it in creeks. (35)

(35) Group will take salt dump fight to Queensland Ombudsman
19th May 2017 https://www.chinchillanews.com.au/news/group-will-take-salt-dump-fight-to-queensland-ombu/3179896/

In NSW "Any salt or salty water that is produced as a result of CSG activities will only be disposed of consistent with licence conditions. Approved methods for disposal of CSG produced water may include beneficial reuse (for example, for dust suppression at a coal mine), reinjection into an aquifer or treatment (for example by reverse osmosis) and reuse." (36)

(36) http://www.water.nsw.gov.au/water-management/groundwater/water-and-coal-seam-gas/frequently-asked-questions

Last week we saw a resident near a Queensland gas facility complain about the 24/7 noise, and a few days later, QGC workers from Kenya Plant dumped the coal seam gas salty 'produced' waste water all along the road in front of his farm. Again, I make the point that SANTOS uses the same personnel in Queensland as they will in NSW, so that behaviour is already entrenched. We must expect the same behaviour from the same people in NSW.

Coal seam gas produced water and reverse osmosis concentrate are highly contaminated materials. They are not suitable for general waste disposal and must be handled as hazardous controlled waste in a licensed waste facility capable of handling the toxicity of the material. Both these waste products contain toxic heavy metals, ordinary salt, other salts, radioactive solids and hydrocarbon residues.

There is no current waste disposal facility in NSW and unlikely to be none in future that can handle up to 110 tonnes per day of produced water waste.

There is currently no treatment-disposal mechanism in place in Australia for the concentrated (solid salt-waste) produced after the reverse osmosis of CSG brine.

This legacy will no doubt be left for future generations and the New South Wales taxpayer.

The SANTOS Narrabri Gas Project should not be approved based on this issue alone.


Economics

The economics of this proposed SANTOS gas field do not stack up, neither for SANTOS as a company or for the communities and businesses that they effect.

Stock market

"In the short run, the stock market is a voting machine but in the long run, it is a weighing machine." ― Benjamin Graham

Peaking at $22.00 per share in 2008 with the hype surrounding the building of the $US18.5 billion SANTOS GLNG gas export terminal, the share price of SANTOS is now $3.52 - as at 21st May 2017 (37)

(37) Twenty minute delayed share price https://www.google.com.au/?gfe_rd=cr&ei=oFEhWcu2ILLM8gf86Ii4Cg#q=santos+share+price

Even this price is being propped up with Chinese capital firms ENN Group and Hony Capital buying up this month to the limit required before triggering FIRB. SANTOS is a real risk of becoming a takeover target and will likely be bought cheaply, broken up and the parts sold off or in the case of their export terminal, closed down. Part of that risk is the unknown buyer, probably foreign given that very few Australians are likely to take on this project, then becomes the licensee.

Analysts are very aware of SANTOS problems - the falling prices, the global gas glut (the 'gas shortage' has always been a myth perpetuated by industry to gain more acreage) and their Queensland gas wells are not performing to expectations - and have sold off SANTOS shares as a result. SANTOS management spent billion of dollars building an unnecessary third LNG export terminal at Gladstone. Their 2009 EIS for the terminal stated that they need more acreage to fulfill their gas export contracts.

It is not up to the NSW Government to approve an unsustainable and unviable project for a failing business. The Narrabri Gas Field is already, in my view, a worthless 'stranded asset' and the clean up of any half-completed gas wells and infrastructure, or spills, will become a taxpayer liability.

Given the risks that any problems created by a cash-strapped company on the brink of collapse will be passed onto the taxpayer, on this issue alone the proposal should be rejected.

"World's Best Practice" The NSW Government and Department of Planning is committed to "World's Best Practice". (38) (39 (40) (41)

(38) The Minister for Planning, Housing and Special Minister of State Anthony Roberts released the Development Assessment Best Practice Guide on 21 March 2017 http://www.planning.nsw.gov.au/Assess-and-Regulate/Development-Assessment/Councils-Development-Assessment-Guide

(39) https://data.nsw.gov.au/blog/tags/best-practices

(40) https://www.procurepoint.nsw.gov.au/scm1461

(41) On 13 November 2014, the NSW Government released its Gas Plan which is designed to deliver world's best practice regulation and secure vital gas supplies for the State. https://www.gtlaw.com.au/release-nsw-gas-plan


* World's Best Practice in the Cattle Industry

Any contamination of diary or beef cattle industry will be devastating. VOCs particularly cross into humans from milk. The main element of concern is the heavy metal strontium, which can be toxic to humans, especially in growing children.

Before dismissing these international examples by saying that Queenslanders have been been raising cattle with gas wells on the farms, again I make the point that few cattle farms have the associated infrastructure associated with the problems, not many live on the farms near the gas wells, all have signed Confidentiality Clauses preventing problems from being made public, and it is still early days.

I can no longer donate blood in Australia because I happened to be in the UK during 1991-92 during the Mad Cow contamination. Whilst I am not suggesting that gas extraction causes Mad Cow disease, this example highlights the unforeseen consequences of contaminated beef products.

The total economic loss to the nation (UK) resulting from BSE in the year following the crisis is estimated to be between £740 million and £980 million, equivalent to between 0.1% and 0.2% of UK national income (GDP).
The UK domestic beef market appears to have recovered as far as it is going to. (42)

(42) http://www.veterinaria.org/revistas/vetenfinf/bse/14Atkinson.html

The unforeseen consequences of cattle contamination from fracking has prompted World's Best Practice elsewhere, favouring the Precautionary Principle (43).

(43) The precautionary principle (or precautionary approach) to risk management states that if an action or policy has a suspected risk of causing harm to the public, or to the environment, in the absence of scientific consensus (that the action or policy is not harmful), the burden of proof that it is not harmful falls on those taking that action.
The principle is used by policy makers to justify discretionary decisions in situations where there is the possibility of harm from making a certain decision (e.g. taking a particular course of action) when extensive scientific knowledge on the matter is lacking. The principle implies that there is a social responsibility to protect the public from exposure to harm, when scientific investigation has found a plausible risk. These protections can be relaxed only if further scientific findings emerge that provide sound evidence that no harm will result.
In some legal systems, the application of the precautionary principle has been made a statutory requirement in some areas of law. https://en.wikipedia.org/wiki/Precautionary_principle

Cattle from Tioga County Farm Quarantined after Coming in Contact with Natural Gas Drilling Wastewater
07/1/2010 HARRISBURG -- The Department of Agriculture announced today that it has quarantined cattle from a Tioga County farm after a number of cows came into contact with drilling wastewater from a nearby natural gas operation.
Agriculture Secretary Russell Redding said uncertainty over the quantity of wastewater the cattle may have consumed warranted the quarantine in order to protect the public from eating potentially contaminated beef.
"Cattle are drawn to the taste of salty water," said Redding. "Drilling wastewater has high salinity levels, but it also contains dangerous chemicals and metals.
We took this precaution in order to protect the public from consuming any of this potentially contaminated product should it be marketed for human consumption."
Subsequent tests of the wastewater found that it contained chloride, iron, sulfate, barium, magnesium, manganese, potassium, sodium, strontium and calcium.
Redding said the main element of concern is the heavy metal strontium, which can be toxic to humans, especially in growing children.
The metal takes a long time to pass through an animal's system because it is preferentially deposited in bone and released in the body at varying rates, dependent on age, growth status and other factors. (44)

(44) Commonwealth of Pennsylvania Dept. of Environmental Protection press release http://www.coal-seam-gas.com/usa/pennsylvania31.htm

What became of the quarantined cows in Tioga County? The following spring, eight of the 11 calves did not survive, an unusually high number for farmers Carol and Don Johnson.
Dr. Michelle Bamberger, a veterinarian, said there is little research being done about the impacts of gas drilling on food supplies.
"We have no idea what's in this [wastewater] and what contaminants could be picked up by the plants and then farmed and then fed to cattle and then fed to people or fed to people directly, so I'm very concerned," she said. (45)

(45) https://stateimpact.npr.org/pennsylvania/2013/12/04/what-became-of-the-quarantined-cows-in-tioga-county/

Communities living near hydrocarbon gas drilling operations have become
de facto laboratories for the study of environmental toxicology. For the past year, we have been documenting cases of animal and owner health problems with potential links to gas drilling. Many cases are currently in litigation. The authors compiled case studies of twenty-four farmers in six shale-gas states whose livestock experienced neurological, reproductive and acute gastrointestinal problems. Exposed either accidentally or incidentally to fracking chemicals in the water or air, scores of animals have died. (46)

(46) http://psehealthyenergy.org/data/Bamberger_Oswald_NS22_in_press.pdf

U.S. Forest Service soil scientist, Mary Beth Adams, said "There's relatively little research in general on the effects of natural gas development. I'm not familiar with much research on the effects of wildlife or even on vegetation. It simply hasn't been done. The pace of development is outpacing the research.
"But there are other constituents that are probably associated with those salts. The deer may be ingesting those as well- the heavy metals and the radionuclides. We don't know. There's been so little work done on what's in there. And then how it moves through the ecosystem. Maybe it all leaches out quickly. Probably it doesn't. But we don't know that."
"It would be nice if humans were a little less impetuous and that we would actually think about what might be the potential impacts and do some research before we run away with it, but I think it's probably human nature." (46)

(46) https://stateimpact.npr.org/pennsylvania/2013/11/26/why-deer-can-be-attracted-to-gas-drilling-sites/

In New Zealand, Fonterra stopped sourcing milk from land affected by oil and fracking waste
Fonterra has vowed to no longer accept milk from any new dairy suppliers based in areas of New Zealand where oil industry and fracking waste has been spread and covered, but has denied that pressure from the country's Green Party played any part in its decision. (47)

(47) http://www.dairyreporter.com/Manufacturers/Fonterra-vows-to-stop-sourcing-milk-from-land-affected-by-oil-and-fracking-waste

The risk to human health and the environment posed by coal seam gas can be managed but "unintended consequences" due to accidents, human error and natural disasters are inevitable, the state's top scientist says. (48)

(48) Coal seam gas will have 'unintended consequences', says chief scientist
http://www.smh.com.au/environment/coal-seam-gas-will-have-unintended-consequences-says-chief-scientist-20140930-10oblo.html

The best solution to ensure "World's Best Practice" and the NSW 'brand' as clean and contaminate-free is reject this proposal.

Economic Advice from the Experts

Visiting Canadian 'gas guru' (his words not mine) Geoffrey Cann of Deloitte stated:

"By the way, I think it's time to simply abandon NSW and VIC as gas precincts. The anti-development sentiment is too far entrenched. Those gas reserves should be sold off or turned back to the government, in favour of creative alternatives. In my view, it's better for Queensland to simply own the entire east coast gas market and produce like mad, rather than trying to finesse a terra joule of gas here and there from piddly coal measures in NSW." (49)

(49) Parting Thoughts For Australia's LNG Sector http://www.fueluplng.ca/parting-thoughts-for-australias-lng-sector/

A report by Australia's Deloitte Access Economics asserted rising gas prices in Australia (which has happened, far worse than anticipated) would diminish manufacturing output by $118 billion over the next seven years and cost 14,600 manufacturing jobs. (50)

(50) Australia Shows US How Not To Export Gas
http://www.afr.com/business/energy/gas/australia-shows-us-how-not-to-export-gas-20140729-jk6pj

Cann went on to state: ""I also think the sentimentalism over the loss of Australian heavy manufacturing is unbecoming of a staunch free market economy. Why not embrace what Australia wants to be, a tourism-agri-health country and use its gas assets for those purposes?" (49) His bold fonts.

By the way, Cann is not entirely accurate, Victoria has saved the Queensland export market by supplying it from Bass Strait. BHP's boss has stated that Bass Strait could supply the entire East Coast domestic gas needs "indefinitely". South Australia is also preparing to export gas, so there is no need for the NSW gas field for SANTOS.

Even gas execs admit that we don't need more gas drilling in NSW
Some coal seam gas types are saying NSW will face a gas shortage this winter. This is nonsense, and they know it.
In case you missed it, on his way out the door last week, AGL chief Michael Fraser casually observed that there was enough gas in Bass Strait to head off any supply shortages in New South Wales.
That is a stunning admission from one of the key instigators of a massive scare campaign designed to pressure the NSW government into fast-tracking approvals for AGL's controversial coal seam gas projects in Gloucester and Santos' Narrabri project in the Pilliga State Forest.
The scare campaign was always based on a false premise that NSW, which has always depended on gas from interstate -- whether from Victoria's Bass Strait or South Australia's Moomba or Queensland's coal seam gas fields -- suddenly needed its own gas supply. (51)

(51) Even gas execs admit that we don't need more gas drilling in NSW https://www.crikey.com.au/2015/02/16/even-gas-execs-admit-that-we-dont-need-more-gas-drilling-in-nsw/

Phoney energy crisis merely a ploy to access off-limits gas
Let's be clear: there is no gas shortage. Not in Australia, and not around the world. In fact, there's the opposite: a global glut of the stuff. BHP has already admitted there's enough gas in Bass Strait to supply the east coast "indefinitely". And globally, by the end of 2015 the gas industry was capable of producing about 25 per cent more liquefied gas than the world wanted to import. (52)

(52) Phoney energy crisis merely a ploy to access off-limits gas http://www.smh.com.au/comment/phoney-energy-crisis-merely-a-ploy-to-access-offlimits-gas-20170315-guz8pb.html

The Australian Energy Market Operator has warned that Australia is about to run out of gas but that's not actually true.
BHP Petroleum chief Mike Yeager told journalists in 2014 that there was plenty of gas available in the Bass Strait, and it could supply people in Victoria and NSW, and possibly even Queensland, "indefinitely".
Australia has plenty of gas to supply its own needs, but gas companies on the east coast have been sending this overseas ever since they were allowed to build three liquefied natural gas (LNG) plants at Gladstone in Queensland. (53)

(53) How Australia is being screwed over its gas http://www.news.com.au/finance/economy/australian-economy/how-australia-is-being-screwed-over-its-gas/news-story/4187e60617aec18e87d57453cfca0167

The main point from the above examples is that NSW Planning should not legitimately be under any pressure economically to approve this project. There is plenty of gas for NSW, and NSW has always imported gas, just as we import Telecom equipment, Passenger motor vehicles, Refined petroleum, Medicaments Computers, Pharm products (54)

(54) https://dfat.gov.au/trade/resources/Documents/nsw.pdf

This confected "gas crisis" is not a supply problem, as stated by industry, especially SANTOS - in fact we are the world's biggest exporter in a global gas glut, it is a policy failure by politicians - however, finally, the solution is being discussed by the Prime Minister (55). Not surprisingly, it is SANTOS, the only LNG exporter drawing on domestic gas to meet its export contracts, that has forced the issue and created the domestic "gas crisis". (56)

Malcolm Turnbull intervenes in gas market to tackle surging domestic prices
The Prime Minister's dramatic intervention comes after largely fruitless meetings with east coast gas companies, including Santos, Origin, ExxonMobil and Shell, in March and April, in which he asked for remedies to the domestic shortfall in supply and price spikes during peak periods.
An "Australian domestic gas security mechanism" will allow for export controls to be imposed on companies when there is a gas supply shortfall. (55)

(55) Malcolm Turnbull intervenes in gas market to tackle surging domestic prices http://www.smh.com.au/federal-politics/political-news/malcolm-turnbull-intervenes-in-gas-market-to-tackle-surging-domestic-prices-20170426-gvsuyb.html

(56) The Adelaide-based Santos has long been accused of being a major contributor to the tight gas supply situation in eastern Australia due to the reliance of its Gladstone LNG project on third-party suppliers.
The company last week revealed that some 59 per cent of the gas processed through GLNG in the March quarter had come from third parties which could have otherwise been directing that gas into domestic markets.
http://www.theaustralian.com.au/business/mining-energy/gas-export-controls-loom-santos-glng-partners-at-risk/news-story/6e077f3aa34becb9667d3fb16635b09a

I will state again, NSW Planning should not legitimately feel under any pressure from any company, industry lobby group, political party or politician, economically to approve this project. The Prime Minister's response to the "SANTOS Crisis" is a "Australian domestic gas security mechanism" - a modified gas reservation policy that every independent person, gas consumer or business owner or lay person, knows that NSW needs. It took some time, and of course SANTOS is not happy, but the federal government has the solution at hand.

You may have seen SANTOS share price dive 2.5% on the APPEA Gas Conference revelations that a LNG plant may have to close to better reflect the industry's capability to deliver on their export contracts, and that SANTOS will be especially hit by the "domestic gas security mechanism". The fact is that SANTOS will have to downsize their business to better reflect their poor business decisions, they can't legitimately blame farmers trying to protect their land & water, or the NSW Government, for their predicament.

Now, is "NSW Gas for NSW" as SANTOS claim? If left to their own devices, of course not - SANTOS are desperate for gas to meet their export contracts - they've sold more than they have. The only way that the Narrabri gas will end up in Sydney is if the NSW Government legislates their own "NSW gas reservation policy". Any codicil or condition attached by NSW Planning on an approval will be, in my view, worthless given that SANTOS chances of survival as a company in its present form will be a stroke of luck.

The AEMO website shows gas streaming from NSW, via Bass Strait, to the Gladstone export terminals. (57) The SANTOS gas pipeline connects to Gladstone. A large percentage their gas will be exported, guaranteed.

(57) Natural Gas Services Bulletin Board http://www.gasbb.com.au/

Boom Bust Towns

In 2013 gas industry funded GISERA conducted research into "How coal seam gas is changing the face of rural Queensland". They found "in studying the impacts of unconventional gas development, the one negative trend we found was that agricultural employment had decreased more than the rest of rural Queensland during the expansion of the coal seam gas industry."

"For every new job in the resources sector there has been around two new jobs created in the related sectors of construction and professional services. By contrast, for each new job in the resources sector there has been a reduction of 1.7 jobs in agriculture." (58)

(58) How coal seam gas is changing the face of rural Queensland https://theconversation.com/how-coal-seam-gas-is-changing-the-face-of-rural-queensland-21064

That kills the myth of 'co-existence' right there.

It must be pointed out that this research was during the "development" phase, with an increase in "construction" jobs. Obviously since the development and construction phases have ended, these short-term jobs have moved on to the next development.

But, have the sustainable, long term agriculture jobs returned? I would suggest that they haven't. GISERA is silent on research into the aftermath of coal seam gas in Chinchilla and places like Gladstone. The sudden fall in land prices around Chinchilla supports this view.

One of the worst hit Queensland towns affected by coal seam gas' boom/bust is Gladstone.

The biggest loser of Australia's gas shortage is the city that's sucking it all up
When local shop owner Jenelle Knight starts talking about the struggles her community is facing to keep Gladstone alive, she breaks down in tears.

"The people here are resilient, [but] I think they have really been pushed this time. We have lost a lot of people, a lot of businesses, and I think there is a lot more just holding on and that is really sad," she says.

The fabrics of society were torn when 14,500 new jobs - 25 per cent of the then population - appeared almost at once, as the unprepared city rushed to build housing estates, apartment complexes and motels.

Rents skyrocketed, with seniors no longer able to afford to live in the community they'd known all their lives. Teachers, nurses and police were either forced to move away by the high costs, or threw in their day job to join the crews constructing the plants.

Business owners, too, lost staff to jobs that were paying "obscene amounts" of money and struggled to maintain a grip on wages as house and rental prices soared through the roof.

But when construction was done, the rapid increase in rent, wages and people retracted just as quickly and hit the city hard - seven years on, about 1200 homes sit empty throughout the region, more than a dozen empty shops line the city's main strip, and Gladstone Regional Council is working hard to coax people back into the community. (59)

(59) The biggest loser of Australia's gas shortage is the city that's sucking it all up http://www.smh.com.au/queensland/the-biggest-loser-of-australias-gas-shortage-is-the-city-thats-sucking-it-all-up-20170316-guzwbf.html

The bust has not been limited to Gladstone. "As the coal seam gas construction boom winds down in south-west Queensland, businesses in towns like Roma, Miles and Chinchilla are doing it tough." (60)

(60) The end of the CSG boom in south-west Queensland http://www.abc.net.au/radionational/programs/breakfast/csg-boomtime-over-for-south-west-qld/6050560

The economic benefits to Narrabri and the surrounding district will be no different, that is, short term jobs for out-of-town workers will force up prices of rentals and housing, forcing long standing locals to leave. The social fabric will be torn apart with further mistrust and aggravation between miners and long term residents. And when the miners and construction workers leave, the long term residents - those that survived - will be left with even fewer agricultural jobs, closed businesses and depressed land values.

Land Values. Queensland residents have described the coal seam gas industry's impact on local housing prices as "a really short party with the worst and longest hangover".

They're warning Narrabri residents to be prepared for a sudden and rapid rise, followed by a sharp and steady decline in the value of their home if Santos' 850-well project is approved.

Karen Auty bought her home in Chinchilla in 2007, prior to the CSG mining boom enveloping the area, which she said sent house prices, rental rates and land valuations sky rocketing.

When the CSG industry came to town, the value of her unimproved land tripled in three years, before dropping more than $20,000 below its original value. (61)

(61) Narrabri warned of coal seam gas impact on house value by Chinchilla
http://www.northerndailyleader.com.au/story/4562970/what-does-the-csg-industry-do-to-the-price-of-nearby-houses/

Insurance & Mortgages The NSW Chief Scientist recommended "the government should also establish a standing body of experts to advise on the industry and consider a robust policy of insurance and environmental risk coverage of the industry". (62)

(62) Coal seam gas will have 'unintended consequences', says chief scientist http://www.smh.com.au/environment/coal-seam-gas-will-have-unintended-consequences-says-chief-scientist-20140930-10oblo.html

This recommendation has not adequately been achieved, with farmer's land turned into an industrial complex they are struggling to find adequate insurance.

"We were absolutely staggered to learn that our insurer can't provide a policy for coal seam gas risks," Mrs Ciesiolka said.
The Land contacted multiple insurance brokers and three major insurance providers, but none could identify a product to insure against potential CSG contamination was available. (63)

(63) CSG too risky for insurers http://www.farmonline.com.au/story/3365648/csg-too-risky-for-insurers/

Mortgages become harder to obtain. For example, a bank turns down owners' application for $500,000 bridging loan on grounds that Queensland property has four coal seam gas wells on it (64)

(64) Commonwealth Bank: coal seam gas makes property 'unacceptable' as loan security
https://www.theguardian.com/environment/2016/sep/30/commonwealth-bank-coal-seam-gas-makes-property-unacceptable-as-loan-security


Global Gas Glut. SANTOS is in trouble financially because they have over estimated their figures. Their share price has plummeted (65), they have conducted numerous capital raisings involving share dilution (66) (67) (68) (69), their construction costs are over budget (70) (71) (72), their Queensland gas wells are not producing to expectation (73) (74) (75). And their gas is not selling at the prices expected (76) (77). It is no surprise then, that SANTOS have over-stated the Cost Benefit in this EIS.

SANTOS figures assume a recovery in the global selling price of gas. That is not going to happen in the foreseeable future.

Qatar, the world's largest gas producer - with production costs approaching zero - is ramping up production. (78)

Russia, a huge exporter of gas, is building a pipeline into China - Australia's main market (79).

Trump is calling "drill, baby, drill" with his plans to export USA gas, again, to Australia's export market (80).

We are already in a Global Gas Glut and this NSW SANTOS EIS proposes to produce more, at a time that the world's biggest producers are also ramping up production.

SANTOS are a high-cost producer in a low cost world. Even if their gas is for the domestic market, which is highly doubtful, they will not be able to produce gas cheaply enough at Narrabri to compete with the glut-created excess gas (after export contracts are met) from Queensland.

SANTOS, now desperate for gas to either meet its export contracts, or at least satisfy its domestic 'price mechanism' requirements for government, has not factored in the long term depressed prices that this global gas glut has created.

(65) SANTOS historic share price, 20 minute delayed https://au.finance.yahoo.com/quote/STO.AX/history?ltr=1

(66) Santos baffles market with $1.5b equity raising
Dec 15 2016 Santos has insisted its surprise $1.5 billion equity raising was not driven by any asset problem or credit rating risk as some investors struggled to understand the need for the move that has raised early questions around management credibility under new chief executive Kevin Gallagher.

Shares in the oil and gas producer dived 10.7 per cent on Thursday, despite the successful completion overnight of the first part of the raising, a $1.04 billion placement to institutional investors. The stock fell to $3.94, 12¢ below the sale price for institutions.

"It is perplexing," one investor said. "They seemingly didn't have any liquidity issues and they were comfortable with their balance sheet the week before, but in what can only be described as a very hurried process they jammed out a capital raising."

The investor said the share sale raised concerns about a "credibility gap" given the messages put out at the strategy briefing.

http://www.afr.com/business/energy/oil/santos-baffles-market-with-15b-equity-raising-20161214-gtbgdx

(67) Santos shares slip after wrapping up $2.5b capital raising
Dec 3 2015 Santos shares fell as much as 2.7 per cent on on returning to trade after the company confirmed it had wrapped up its $2.5 billion equity raising with the retail shortfall bookbuild successfully completing late Wednesday.

The oil and gas producer found its balance sheet under severe strain by the extended weakness in crude oil prices, which has coincided with an increase in debt levels to fund construction of its $US18.5 billion GLNG gas export project in Queensland.

Potential divestments include some of Santos's oil and gas ventures in Asia, and infrastructure within Australia, as well as some interests in Western Australia and in the eastern states.

http://www.afr.com/business/energy/gas/santos-shares-slip-after-wrapping-up-25b-capital-raising-20151202-gle28n

(68) Santos capital raising falls short
Dec 2, 2015 The retail component of a $2.5 billion capital raising to strengthen the balance sheet of energy company Santos has come in short.

Only 57% of the 1 for 1.7 share entitlement was taken up by retail shareholders. This raised $775 million.
https://www.businessinsider.com.au/santos-capital-raising-falls-short-2015-12

(69) Santos unveils $3bn capital raising
11 May 2009 Under the offer, Santos will issue two shares for every five held at a discounted price of $12.50 each.

Share in the company last traded at $17.09
https://www.businessnews.com.au/article/Santos-unveils-3bn-capital-raising

(70) Lower prices hit Santos despite record first-half production
JULY 22 2016 Record first-half production at Santos thanks to the start-up of the second train at the company's large Queensland liquefied natural gas project was not enough to offset the impact of lower oil and gas prices.

But analysts took heart at signs of progress under new chief executive Kevin Gallagher to reduce break-even costs for the oil and gas producer to fit a new world of lower commodity prices.

Santos is aiming to reduce break-even costs from between $US45 and $US50 a barrel to between $US35 and $US40 a barrel, with the focus on internal action within the company before resorting to any asset sales. Analysts are expecting fuller detail on cost reduction targets and progress made so far at Santos' first-half earnings report next month.

The ramp-up of the cost-cutting efforts came after a $3.5 billion package of capital measures was required last November to urgently cut debt, which had blown out to help fund Santos' $US18.5 billion GLNG venture in Queensland.

But sales revenues were 6 per cent lower for the half, at $US1.191 billion, while quarterly sales dropped 3 per cent to $US590 million.
http://www.smh.com.au/business/energy/lower-prices-hit-santos-despite-record-firsthalf-production-20160721-gqb7vp.html

(71) Gladstone produces first gas but costs Santos $1 billion
19 August 2016 SANTOS' (ASX: STO) Gladstone liquid natural gas plant has cost the company US$1.05 billion, just months after it made its first shipment of gas.

The energy company reported its first-half results today, announcing a $1.1 billion net loss, largely led by the GLNG write-off, but also affected by low oil and gas prices, which pushed the company to an underlying net loss of US$5 million after tax.

The positive impact of a 32 per cent increase in sales volumes was more than offset by lower oil and oil-linked LNG prices, as a result sales revenue decreased by 6 per cent to US$1.2 billion.

The average realised oil price fell 29 per cent to US$42.79 per barrel, while the average LNG price was 42 per cent lower at US$5.70/mmbtu.

Managing director and CEO, Kevin Gallagher, who started with the company in February, says, Santos' goal is a breakeven point of between US$35-$40 per barrel.
http://www.businessnewsaus.com.au/articles/gladstone-produces-first-gas-but-costs-santos--1-billion.html

(72) Santos slumps to $US1.1b half year loss
AUGUST 19, 2016 Energy giant Santos will not pay a dividend after plunging to a $US1.1 billion ($A1.4 billion) half year loss on the back of lower oil prices and a large impairment against its massive new LNG project.
The huge loss compares to a $US30 million profit a year earlier. Revenue in the six months to June dropped six per cent to $US1.19 billion, despite sales volumes rising by a third.
Santos had earlier this week outlined a $US1.5 billion non-cash impairment charge against the carrying value of its Gladstone LNG terminal in Queensland because of lower oil prices, a slower-than-planned ramp-up in production and higher costs of sourcing gas from other parties.
Production at the $18.5 billion project started in September 2015, but its prospects have been squeezed by weak oil and gas prices and uncertain supplies from Santos' own coal seam gas wells.
Recently appointed chief executive Kevin Gallagher said on Friday the company's short term priority is to stabilise the business and increase operating cash flow.
"The results reflect the impact of lower-for-longer oil prices," he said.

http://www.news.com.au/finance/business/breaking-news/santos-slumps-to-14-bln-firsthalf-loss/news-story/555cc3c9f3e5b1f06afbb04d87abda62

(73) Adding further concern to the situation is persistent chatter that many CSG wells are performing below expectations crimping the supply outlook even further.
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See attached

See attached

Dear Sir/Madam;

Thank you for the opportunity to respond to the Narrabri Gas Project Environmental Assessment.

The Maules Creek Community Council is alarmed by the Santos Narrabri Gas Project (NGP) Environmental Assessment and the limited data that it provides for landholders. We do not think that a project determination can be made and it must be rejected in its current form.

Should the NGP get the tick of approval from NSW Planning and obtain funding to construct the Narrabri gasfield it is inevitable that Santos or the NGP's future owners will apply for additional wells, eventually in the vicinity of Maules Creek.

The precedent that this Environmental Assessment is attempting to set in NSW is of serious concern to our community and is likely a concern right across the state.

The Maules Creek Community Council (MCCC) is a community-based organisation whose mission is to educate and inform the community and to liaise with government, resource companies and other community groups about issues relevant to the Maules Creek community. Maules Creek is located in the heart of the agricultural powerhouse of the Namoi Valley in North West NSW.

Please see the attached file for our full submission.

Regards


MCCC

Please see attached letter on behalf of RDA Northern Inland NSW.

Email: [email protected]
Website: https://bccag.org.auhttps://bccag.org.auhttps://bccag.org.auhttps://bccag.org.auhttps://bccag.org.auhttps://bccag.org.auhttps://bccag.org.auhttps://bccag.org.auhttps://bccag.org.auhttps://bccag.org.au https://bccag.org.auhttps://bccag.org.auhttps://bccag.org.auhttps://bccag.org.au https://bccag.org.auhttps://bccag.org.auhttps://bccag.org.au
22nd May 2017
NSW Government,
Planning and Environment,
Major Projects Assessments,
Narrabri Gas Project,
Madam/Sir,
Re: Assessment of the Narrabri Gas Project
We thank you for the opportunity to make a submission on the Narrabri Gas Project..
This Project has implications that transcend the borders of NSW.
It is with the national implications in mind that the Bayside Climate Change Action Group is making this submission, hereby attached.
Sincerely
David Rothfield
Acting President
Bayside Climate Change Action Group
14B Ebden Ave.
BLACK ROCK VIC 3193
2
Submission to NSW Government - Planning & Environment Major Projects Assessments Narrabri Gas Project 22nd May 2017
This submission is by The Bayside Climate Change Action Group (BCCAG) in Victoria. BCCAG's vision is `A safe climate for all'. We work to raise awareness about the consequences of climate change, to influence decision makers at all levels of government to implement necessary mitigation strategies and to encourage sustainable practices amongst Bayside residents.
Summary
This submission relates to the Environmental Impacts Statement (EIS) submitted by Santos in relation to its proposed Narrabri Gas Project. Having studied the EIS, the Bayside Climate Change Action Group (BCCAG) strongly objects to this project. We are confident that others closer to the locality than we are, will find objections arising from unacceptable risks to the immediate environment. Our submission, places the project in a wider context, that of its impact on Australia's greenhouse gas emissions, and potentially our ability to meet our international climate change commitments.
The risks of substantial fugitive emissions are explored and shown to be a cause of extreme concern to anyone who wishes to embark on a serious policy of emissions reduction in response to climate change. We furthermore show that, contrary to popular perception, the demand for gas on the domestic market is actually declining as alternative renewable energy sources become more cost competitive. Allowing CSG projects such as this, with its many attendant risks works contrary to policies aimed at mitigating the impacts of climate change.
Introduction
We live in a world threatened with the dramatic and devastating consequences of climate change. The Australian Government has joined the global community in committing to limiting global warming and transitioning to a zero-carbon economy by mid-century. With extreme weather events, such as Cyclone Debbie setting new norms and record ocean temperatures bleaching the Great Barrier Reef now for two consecutive years, we are reminded of the consequences of ignoring the risks that climate change poses to the fabric of our way of life.
It is in this context that planning authorities must view regional energy production plans such as the Narrabri Coal Seam Gas Project. The crucial test for this project is whether Coal Seam Gas production has a proven track record of reducing emissions or whether undeclared and unmeasured fugitive emissions actually mask a significant addition to declared emissions. Planners must also question the validity of such a large, disruptive CSG project, ostensibly needed for the domestic market, at a time when the domestic gas market is shrinking and being replaced by more cost effective renewable energy systems.
email: [email protected]
website: https://bccag.org.au
3
Quantifying Greenhouse Gas Emissions
According to the Santos EIS, ` ...The most material greenhouse gas emissions from the project are associated with carbon dioxide venting and combustion of fuel during gas processing. .'. That Santos can overlook the potential contribution of fugitive methane emissions on such a far-flung project is astounding, given the substantial evidence now available of the presence of high methane levels in CSG production areas.
In 2014, Scientific American quoted two studies that concluded that, on a global scale, gas fields may be leaking enough methane to make the fuel as polluting as coal for the climate (Appx 1.).
In 2016 The Melbourne Energy Institute (MEI) published a review of current and future methane emissions from Australian unconventional oil and gas production. (Appx 2.) This review includes the following assessments.
* There is significant uncertainty about methane emission estimates reported by oil and gas producers to the Australian Government.
* Current Australian methane emission estimation methods ignore this potential source (of migratory or fugitive emissions).
* Migratory emissions could significantly increase with continued depressurisation of the coal seams.
* If methane emissions from unconventional gas production are being significantly under-reported, this could have a large impact on Australia's national greenhouse gas (GHG) accounts.
Until now, estimates of fugitive emissions have been based on those occurring at the point of combustion only. This may have been valid when production took place at large, central industrial locations. However, the CSG production process is spread over a far-flung scattered network encompassing a range of activities from exploratory drillings at multiple sites, sinking of multiple production wells, transport of gas via an interconnected network of hundreds of kilometres of pipes and various control devices and processing at a remote central processing plant. There is evidence of varying degrees of leakage taking place at all of these production stages.
Do we need more gas?
Until now, governments and industry have promoted natural gas as a necessary `transition fuel', between coal fired generation and renewables. This belief arose during a time when gas was considered cheap and renewables were considered expensive.
This is no longer the case. Gas prices have risen dramatically in recent years as Australian gas has become available on the international market. Over the same period, wind and solar generation costs have plummeted so that today they can, in most situations, compete with new coal. As a result, we have witnessed a decline in gas demand across Eastern Australia.
4
The MEI studied the causes of this trend in a report published in 2015, Switching off gas - An examination of declining gas demand in eastern Australia (Appx 3.) The key points from this report include:
* According to the Australian Energy Market Operator (AEMO), since 2012, the amount of gas consumed in eastern Australia has declined each year and will continue to decline.
* With the recognition of declining demand, AEMO's previous concerns about gas supply shortfalls were withdrawn.
* Developing coal seam gas has proven to not be as easy, nor as cheap as had been expected - which has contributed to gas price pressures.
* Retail gas prices are increasing, also due to increasing distribution and retail costs
* In eastern Australia, there are potentially half a million to a million homes where residents are unaware that they can immediately start to save hundreds of dollars annually on their heating bill by using their existing reverse-cycle air conditioners (RCAC) (for heating) instead of gas.
The following table from the MEI report shows the savings that typical households in different regions of Eastern Australia can make by switching from gas heating to electric RCAC heating.
Governments have a responsibility and a duty of care to all their citizens to take effective action to mitigate climate change and to ensure they have access to the best advice on saving energy costs. In relation to energy policy, that responsibility and duty obligates them to ensure renewable energy can compete on a level playing field with high emissions producing energy generators. That includes recognition of the societal costs resulting from emissions.
email: [email protected]
website: https://bccag.org.au
5
Coal seam gas production may possibly be less emissions intensive than coal fired generation, though until we have independent verification, we must regard such a proposition with skepticism. Furthermore, an investment in gas production means fewer resources are available for zero emissions energy production from renewables. That in turn means a slower transition process to a zero-carbon economy.
Conclusions
1. There is reason to believe that emissions from CSG production such as the Narrabri Project, are being significantly under-reported, thus compromising the validity of Australia's GHG accounting.
2. The demand for gas on the domestic market in eastern Australia is declining as retail gas costs increase and the cost of renewable energy production decreases.
3. Allowing a CSG project such as the Narrabri Project to proceed, with its attendant environmental risks, goes contrary to government policy to promote a timely transition to a zero-carbon economy. In so doing it throws in to doubt Australia's ability to meet its international climate change commitments.
Appendices
1. Scientific American. Leaky methane makes gas bad for global warming (2014).
2. Melbourne Energy Institute. A review of current and future methane emissions from Australian unconventional oil and gas production (2016).
3. Melbourne Energy Institute. Switching off gas. An examination of declining gas.

Please see attachedPlease see attached

Response attached

Please refer to the attached submission.