I am writing to submit opposition to the Dewhurst Gas Exploration Pilot Expansion SSD 13_6038 on behalf of No CSG Gilgandra District Inc. There are a number of facets to this program that we oppose, including the production of enormous amounts of waste water that Santos currently have no use or valid disposal plans for. We also oppose the use of 'triple stacked' drilling through the very important aquifers that supply underground water for a large area of Eastern Australia through the Great Artesian Basin. In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future.
This drilling by Santos will also have an unprecedented impact on the flora and fauna that is so important in the Pilliga forest. Many species of fauna, like the Pilliga mouse, will have their habitats destroyed by this exploration and production using coal seam gas methods.
It is also extremely disappointing that Aboriginal Heritage requirements were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.
Finally, we feel there is insufficient baseline data of water, flora, fauna, and long-term impacts of Coal Seam Gas exploration and production on the Pilliga forest and surrounding habitats and communities. We believe that this Coal Seam Gas exploration within the Pilliga forest should be ceased immediately, and further details and consideration of the impacts of this intrusive mining be taken into account by Santos prior to any further development of these wells.

There are many reasons that Gas Mining should not go ahead in Australia:
1 - TRIPLE-STACKED HORIZONTAL WELLS -

The 'Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.
When questioned about sealing these junctions in July this year, NSW 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 drill fluids or gas escapes and the down draining of aquifers.

2 - ECONOMICS -

The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.

3 - WATER -

The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have have not yet been commissioned and some are still to be constructed.
In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future.

4 - BIODIVERSITY -

The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.

Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse and other threatened species.

5 - AIR QUALITY -

The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

6 - GREENHOUSE GASES -

The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

7 - HAZARDS -

The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

8 - HERITAGE -

It is extremely disappointing that Aboriginal Heritage requirements were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

Please do not approve this proposal. This could be on the following grounds:

1. that the proposal includes the 'Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells. Leakage is inevitable in the kick off points. It is clear that Santos holds little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers.

2. that the proposal does not lead to a "net benefit" to the state of NSW. In fact, the assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively. The assessment does not comply with DGRs, which requires a full cost benefit analysis.

3. that the proposal will generate on average an additional 248 ML/yr of highly saline water. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a threat to local creeks and groundwater from spills.

4. that the proposal adds to the fragmentation and destruction of threatened species habitat, including habitat for the endemic Pilliga mouse and the regionally important population of the koala.

5. that the proposal will add to the state's Greenhouse gas emissions. The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

6. that the proposal does not include a bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days. The Pilliga is a fire-prone environment and so the lack of a bushfire strategy is a major omission.

I strongly object to the proposition for the following reasons:

TRIPLE-STACKED HORIZONTAL WELLS -

The 'Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.
When questioned about sealing these junctions in July this year, NSW 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 drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -

The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -

The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have have not yet been commissioned and some are still to be constructed.
In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future.
BIODIVERSITY -

The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.


Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse and other threatened species.
AIR QUALITY -

The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

GREENHOUSE GASES -

The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

HAZARDS -

The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

HERITAGE -

It is extremely disappointing that Aboriginal Heritage requirements were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

I strongly object to this proposition for the following reasons:

TRIPLE-STACKED HORIZONTAL WELLS -

The 'Triple Stacked' drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral.
When questioned about sealing these junctions in July this year, NSW 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 drill fluids or gas escapes and the down draining of aquifers.
ECONOMICS -

The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
DGRs call for a demonstration of "net benefit" to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed.
WATER -

The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.
In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have have not yet been commissioned and some are still to be constructed.
In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future.
BIODIVERSITY -

The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.


Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse and other threatened species.
AIR QUALITY -

The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

GREENHOUSE GASES -

The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

HAZARDS -

The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

HERITAGE -

It is extremely disappointing that Aboriginal Heritage requirements were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

Dear Santos,

I am deeply concerned about your further plans for more dangerous Coal Seam Gas exploration drilling in the Pilliga for the following reasons:

-The 'Triple Stacked' drilling of horizontal gas wells through the casing of the existing wells, as it poses great danger to the Great Artesian Basin and other aquifers. Water is a valuable resource, which needs to be protected in terms of it's quality and quantity for the survival of life on earth.

-The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.

-The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Your company still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills.

-The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala's, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater.

-The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

-The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

-The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days.

-It is extremely disappointing that Aboriginal Heritage requirements were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through `song-lines', sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal.

My above mentioned concerns regarding Coal Seam Gas in general and exploration and drilling in the Pilliga in particular have resulted in wide-spread community outrage regarding the lack of thought and respect shown by your company towards the natural environment that we rely on for our air, water, food and health.

Please strongly consider the impact of your activities on current and future generations.

Your sincerely,
Alice Graham

I believe that the coal seam gas exploration and mining in the Pilliga should be stopped for the following reasons:
1 We know the casings leak and the toxic chemical cocktails will permeate through to the Great Artesian Basin. This will ruin a water resource that will be of incalculable value as we move through the 21st Century.
2 There has not been a proper cost benefit economic assessment done. The assessment that has been done doesn't take into account any costs of the project, only claimed benefits. This approach has been labelled as "biased", "abused" and "deficient" by the ABS, Productivity Commission and Land and Environment Court respectively and doesn't comply with DGRs.
3 The wells will produce hundreds of megalitres of salty water contaminated with heavy metals and petrochemicals. Santos can't safely dispose of this water which will be a constant threat to local creeks and groundwater.
4 The still haven't done proper baseline testing. The only reason to not do baseline testing is to make it hard to be held responsible when some catastrophe happens. We all know this.
5 The drilling an infrastructure needed for these wells is another catastrophe in the making for threatened endemic species such as the Pilliga Mouse, koalas, the black striped wallaby, eastern pygmy possums, birds and others too numerous to mention. Santos has already admitted that their exploration will destroy habitat for the Pilliga Mouse. Protecting the Pilliga is more important than enriching massively wealthy people whose agenda will trash the planet.
6 They haven't conducted a baseline study to use as when assessing future fugitive emissions that are affecting the global climate. You can't let them start drilling until proper baseline studies have been done.
7 Gas emissions from drilling and fracking are worse than we previously thought. It's not safe to go drilling for this stuff.
8 Santos hasn't even got a proper bushfire strategy and they want to go flaring gas 24/7.
9 The Gomeroi traditional owners of the Pilliga Forest are being denied their rights as custodians of this land. There hasn't even been a cultural heritage assessment done.
For all of the above reasons and others too numerous to mention I urge you to reject coal seam gas exploration and mining in the Pilliga.

no drilling within the pilliga forest. Protect the artesian basin, our valuable water supply

I strongly oppose this project on the grounds of the unquantified risks posed to the Murray Darling Basin and Great Artesian Basin.

Despite the risks posed by the new tri-lateral wells there is no established baseline data for the Pilliga Sandstones, the crucially important intake area that recharges the Great Artesian Basin. This is THE most important groundwater system in Australia and we cannot afford to damage it. The bores required to do monitor this aquifer have have not yet been commissioned and some are still to be constructed.

We MUST have baseline information if an adaptive management framework is to be used.

The cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future.


Over three years the Dewhurst 13-18H and Dewhurst 26-31 pilot wells will produce between 331 and 413 megalitres of highly saline water containing heavy-metals and petrochemicals. This is the headwaters of the Murray Darling Basin, subject to the Basin Plan which will have water quality objectives and targets. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks - and groundwater resources - from spills.
We have seen the mess left by Eastern Star Gas' spill which Santos was supposed to clean up but which is still to be properly addressed.
We have seen environmental problems and health issues arising from or associated with CSG developments.
We do not want or need this development in the Pilliga forest.
Yours sincerely
Sarah Moles

I am astounded that Santos plans to proceed with drilling in the Pilliga Forest. The impact on the natural and cultural heritage of this country has not been properly assessed, but it already apparent that the environmental impact is significant. The rights of the Gomeroi people have not been respected and their traditional knowledge has. most unfortunately for this proposal, not been taken in to account. This is a fundamental flaw in the process.

There can be no confidence whatsover that the waters of the Great Artesian Basin will not be affected by depressurization or contamination.

I watched the 7.30 Report. The threat to the environment of spills of the toxic water produced is too great. The cost of this project, including in to the future is far greater than any alleged economic benefit. The Director General's Requirements have not been met, a net benefit has not been established. The guidelines from NSW Treasury and Department of Planning in November 2012 are specifically to guide cost benefit analysis of mining and CSG project but they have not been followed.

And an essential reason for rejection of this application is that the basline monitoring and data of groundwater is not in place. Planning Department, in good faith, should not be able to approve this application.

Department of Planning also needs to signify that the immediate and unknown future impact on biodiversity is unacceptable. It is acknowledged by Santos that habitat of the Pilliga Mouse, found only in the Pilliga, will be destroyed. The impact of this proposal on this species,and also the other species threatened with extinction, not only in the Pilliga but in NSW, must be properly assessed.This includes Koalas, the Black Striped Wallaby, Eastern Pygmy Possum and the many threatened woodland birds.
Baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse and other threatened species must be done. It is foolhardy to
risk the ecosystem functions of the Pilliga for coal seam gas production.

The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously thought. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the country's largest coal-seam field, near Condamine on Queensland's Western Downs.

The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted.

It is totally inappropriate to do a piecemeal assessment of the impact of an overall plan to drill 850 wells. The cumulative impact needs to be considered. The baseline data needs to be collected and monitoring systems in place. Planning Department must reject this application