"I am employed by Santos in NSW with the majority of my work responsibilities relating to the development of the Narrabri Gas Project. However, I would like it noted that I am making this submission in a private capacity as an individual that has knowledge of the gas industry; the Narrabri Gas Project; and who also lives locally. Please note that my comments, observations and opinions are solely my own and may not be attributed to Santos and do not necessarily reflect the official policy or position of Santos."

I am providing a submission to the NSW Department of Planning and Environment in relation to Santos' proposed Narrabri Gas Project's EIS. I would like to raise some points regarding the proposed Narrabri Gas Project (NGP) and corresponding Environmental Impact Statement (EIS):

I have worked for Santos in NSW for approximately 5 years. During that time, I have witnessed the integrity of this company, the lengths it goes to protect the environment and the respect it holds for the communities in which it works and for the landholders who host our activities on their land. I am proud to say that I work for Santos, an Australian Company. I can honestly say, if I wasn't confident that Santos could operate with minimal to no harm to the environment I would not be writing this submission, nor, be working for the company.

We have stated publically that we will reserve the Gas produced from our Narrabri project for the NSW Domestic market. Internally, there has never been any other discussions that I have been privy to, to suggest otherwise.
This project could stand to supply up to half of NSW's gas needs. Currently more than 1,000,000 homes and 33,000 business in NSW rely on the supply of affordable natural gas.

Working for Santos has also given me the opportunity to return home to my family and to our small country town and live. If it wasn't for the opportunity provided to me by Santos, I wouldn't be able to live here, I would be forced to relocate to a larger area or back to the city to seek employment.

It is also through Santos that I have been able to purchase my first home. A dream that was impossible to achieve living in Sydney. If our project doesn't go ahead, I will be forced to sell my home and relocate back to Sydney away from my family.

I do not want to leave town. I want to see this project go forward, I want to see the local communities grow and develop. I want to see local people employed, both directly by Santos and indirectly by the other industries that our industry affects, such as other trades, hospitality and hotels. I want to see NSW benefit from the possible $1.2 billion in royalties that this project could create. I want to see improvements to local hospitals, roads, child care and aged care, all of which will be possible with the Community Benefit Fund Santos has pledged to support local community groups and programs.

This will be a fantastic project for the Community and the state of NSW. I hope to be a part of it for a long time to come.
I believe in this project and can proudly walk around town in my Santos uniform with my head held high knowing that we are doing the right thing by everyone involved in our project, now and into the future.

Thank you for your consideration.

I am opposed to the Narrabri Gas Project due to its large potential for harm to human health, and its adverse impacts on the climate and the local environment.

The Narrabri Gas Project risks contaminating two very significant natural water resources: the Great Artesian Basin and the Murray-Darling basin. Drilling fluids have the potential to get into the waterways and contaminate these otherwise pristine water resources. Secure access to clean water is crucial for the livelihoods of farmers and rural communities in the area.

The Narrabri region holds cultural significance to the Indigenous people in the area, the Gamilaraay people. Hundreds of cultural sites are located in the area, along with many songlines and stories that strongly connect the Gamilaraay people to the land. A coal seam gas (CSG) project has the potential to damage these cultural sites and destabilise these connections, which would be a great loss for these Indigenous people who have lived successfully in the area for many, many years.

Santos has a long history of chemical spills and leakages from the storage ponds, pipes and well-heads associated with the infrastructure that has been built at test sites in the area. A freshwater aquifer in the Pilliga has been contaminated with uranium (contaminated to 20 times higher than safe drinking levels). There have also been leaks of lead, aluminium, arsenic and barium. Toxic CSG water has also leaked from storage ponds in the area. This track record is not a good one and I do not believe that Santos can be trusted to operate in a safe manner.

There are several other reasons that I oppose the Narrabri Gas Project. These include:
1. The Pilliga is a haven for threatened wildlife such as the Koala, Spotted-Tailed Quoll, Black-Striped Wallaby, Eastern Pigmy Possum, Pilliga Mouse, and South-Eastern Long Eared Bat.
2. CSG projects have the potential to contribute to global warming by inadvertently releasing methane into the atmosphere during CSG production, processing, transport and use. Methane is a far more potent (global warming potential wise) greenhouse gas than carbon dioxide.
3. Human health is compromised by coal seam gas. Hydrocarbons and volatile organic compounds are released into the air from coal seam gas operations. These chemicals are harmful to humans; they may result in eye, nose and airway irritation, headaches, nausea, dizziness, and loss of coordination.
4. Methane flare stacks would be operating day and night. This would increase the risk of bushfires in an already highly bushfire prone area.
5. The viability of AustraliaÂ's premier optical astronomical observatory Â- the Siding Springs Observatory Â- is at risk, as light and dust pollution from the CSG operations could inhibit the ability to see the night sky in that area.
6. Thousands of tonnes of salt waste would be produced from the CSG operations and, with no clear method of processing or disposing of this waste, it has potential to become a toxic leftover of the mining operations.

To: the NSW Department of Planning and Environment. This is a Submission to the Narrabri Gas EIS.

I object to this project for the following reasons:

1* It will extract over 35 billion litres of toxic groundwater, much of it in the first five years. This water will be treated and in the early years will generate tens of thousands of tonnes of salt, for which there is no safe disposal plan.

2* It will clear close to 1,000 hectares of the Pilliga Forest, fragmenting the largest temperate woodland in New South Wales, home to unique wildlife.

3* It will cause significant diversion of water from a recharge aquifer of the Great Artesian Basin, which is a water resource relied upon by rural communities across western NSW.

4* It will lead to large deliberate and fugitive emissions of methane, adding to climate change.

5* It will cause more trauma to the regional Aboriginal community because the area of impact is crucially important to the spiritual, cultural and social life of Gamilaraay people.

6* It is not justified: Santos' own Coal Seam Gas export activities in Queensland have caused gas prices to rise and supply to become unpredictable. NSW should respond to this by investing in more reliable and ultimately cheaper renewable energy, not by letting Santos inflict more environmental, social and economic harm.

7* It will cause economic upheaval in Narrabri and put agricultural industries at risk, as well as causing light pollution that will ruin the dark night sky needed by the internationally renowned Siding Spring Observatory.

8* Coal Seam Gas is harmful to health. Neither the NSW Government nor Santos have investigated or dealt with the serious health effects of coal seam gas now appearing in peer-reviewed research in the United States. I have visited the gasfields of Queensland's Western Downs on many occasions and have raised money for the Health Testing of 18 residents ranging in age from 3 years to 68 years and all showed signs of:chemicals of concern in their urine, with the exception of one. The samples contained Hippuric acid (the main metabolite of Toluene)along with varying combinations of phenol, cresol, PAH and methyl ethyl ketone. Tank water testing (which was funded from another source)in some cases showed extremely acidic pH and concerning levels of heavy metals such as lead as well as radio-activity. All these chemicals are linked to gas extraction and can clearly be linked to the neurological condition of at least one of the children. It is also in keeping with other symptoms particularly in children, such as bleeding noses, eye irritation and breathing difficulties etc. To ignore all of these test results and the resulting health conditions would be a dereliction of duty by any government.

It is clear that the Narrabri gas project is a poor decision by the government. The project puts at risk the precious water resources of the Pilliga region; farmers are against the project due to issues of water contamination; the traditional custodians of the land - the Gamilaraay people are against the project due to the destruction of areas that are important for the continuation of their ancient culture; Santos has a record of contaminating freshwater supplies in the Pilliga region. It's time that governments across this country took as sensible stand and put the necessary investment into renewable energy sources. Do not go ahead with this project.

This is my submission in relation to SSD 6456, the Narrabri Gas Project.
I have not made a reportable political donation in the last two years.


I object to the proposed Narrabri Gas Project, for each of these reasons:

CSG appears to be even worse than burning coal as a way of generating energy, because of its fugitive emissions -- although we don't have useful measurements of how bad those emissions are. But even if we make optimistic assumptions about low fugitive emissions from this project, it's still pretty greenhouse-gas intensive, and certainly a LOT worse than any renewable source of energy!

The proposal would reduce the pressure of the Great Artesian Basin and/or the Gunnedah Basin, and pollute the waterways (Bohena Creek in particular).

The locals - the Gamilaraay (Gamilaroi?) people - object.

The Pilliga Forest is a biodiversity hotspot; we should leave it alone.

I understand that the proponent plans to produce lots of salt - but does not have the facility to store all that salt on site, but also has no plan for disposing of all that salt.

Further, several other aspects of the proposed Narrabri Gas Project have not yet been specified, such as exactly where the well pads will be located, and how much PM2.5 particulate pollution will be generated. (This may be a reason to send the proposal back to the proponent as unfinished, rather than just rejecting it.)

Finally, consider what good would come of approving the project:
Some presumed profit for the proponent (in the form of a higher sale price, I believe), some energy which we could obtain in far better ways, and a relatively small number of jobs. That's the complete list of positives, so there's not much to recommend the project, and much to argue against it.
(Even the proponent is not sure that it wants to go ahead!)

The Minister

Dear Sir,
I strongly object to the Narrabri Gas Project on the following grounds :
1. Poisoning and extraction of a huge quantity of ground water, no safe disposal plan for the poisonous salt and no replacement of this essential water resource needed by farmers and rural communities over western NSW.
2. Enormous clearing of this valuable forest, the largest temperate woodland in NSW and home to precious wildlife.
3. It will create huge emissions of poisonous methane gas adding to dangerous climate change.
4. There is plenty of evidence of the harmful effects of coal seam gas and the mining process, people should not be subjected to this danger.
5. Renewable energy is the way of the future. We need to protect our land, particularly farming land, not pollute it and increase the risk of disastrous climate change. We should be investing in clean renewable energy if we and our children are to survive into the future.

Thank you.

I wish to state that I agree with Santos using the resources of the Pilliga Scrub.

I think that Santos have very high ideals in relation to the environment in the Pilliga.
I am happy to have them look after their parts of the Pilliga Scrub.
What I am not happy about is the amount of feral animals allowed to roam free in the scrub. The protesters would be much better off spending their time on the eradication of cats, foxs, pigs and goats. These animals cause a lot of damage to all the native species in the scrub.

Keerrong NSW 2480

17 May 2017

ATTN: Executive Director, Resource Assessments
NSW Department of Planning and Environment

RE: Objection to the Narrabri Gas Project

I am writing to express my strong objection to the Narrabri Gas Project after reading the Environmental Impact Statement lodged by Santos NSW (Eastern) Pty Ltd.

I am concerned about the removal of 37.5GL of groundwater from the proposed gasfield over the lifespan of the project, with most of it to occur in the early years of development. Santos has admitted that the removal of groundwater will eventuate in a reduction of the Great Artesian Basin (GAB). As a significant national store of drinking quality water, the GAB is a crucial resource for life and agriculture in Australia.

I am also concerned about Santos' treated water management plan. Santos proposes to dump up to 115 tonnes of salt per day into landfill, which poses an ecological danger of toxicity to ground and surface water. The treated water management plan indicates that untreated water will be stored in `double lined dams' and transported through pipes, which are both vulnerable to corruption over time resulting in untreated water contaminating the surrounding ecosystem, which is proven by Santos' history of at least 20 gas wastewater spills in the Pilliga.

Santos proposes to `beneficially reuse' treated water for crop irrigation, stock watering, dust suppression and construction and `managed release of treated water into the Bohena Creek'. As peer-reviewed studies suggest, even treated CSG water has potentially harmful health effects when people are exposed to it through practices such as irrigation, dust suppression and construction. Harmful chemicals can include fluoride, boron, mercury, lead, arsenic, uranium and benzene. Benzene is a known carcinogen linked to leukaemia, while `lead has been associated with nephrotoxicity, central nervous system effects, cardiovascular disease, impaired fertility and adverse pregnancy outcomes', is a `probable human carcinogen' and is associated with reduced brain function. The Compendium of Scientific, Medical, and Media Findings Demonstrating the Risks and Harms of Fracking (Unconventional Gas and Oil Extraction) (4th ed, 2016), published by the Concerned Health Professionals of New York, shows mounting evidence for health damage by unconventional gas operations.

Santos claims to have a deep respect for the Gomeroi/Gamilaraay Peoples of the region and for national water policy informing the Water Act 2007 (Cth) and the Water Management Act 2000 (NSW). Yet there is no mention in Santos' environmental impact assessment of the National Water Initiative's requirement that water plans incorporate Indigenous social, spiritual and customary objectives, in addition to accounting for native title interests. While Santos is not statutorily required to consider Indigenous social, spiritual and customary objectives, it is clear from the level of discord and resistance to the Narrabri Gas Project from the Gomeroi/Gamilaraay Peoples that they are deeply concerned the project will interfere with social, spiritual and customary objectives regarding the use and management of water in the Piliga State Forest. Santos' claim that they will protect sites of significance is NOT ENOUGH. Groundwater plays a significant role in the law, culture and spirituality of many Indigenous Nations, and until more information is available directly from a unified Gomeroi/Gamilaraay Nation, groundwater should be left in the ground.

If the environmental and health dangers are not enough to persuade you of the danger of this project, I urge you to consider the recent research by the Melbourne Energy Institute showing that Australia is most likely drastically underestimating the amount of fugitive methane emissions released from coal seam gas mining. Combine this with mounting evidence that humanity has underestimated the likely progression of climate change, and it becomes clear that the only option that makes any sense is to cease approving any new CSG projects and transition to renewable energy sources. Renewable energy technology is advanced enough to cater for our energy needs and will provide a commensurate employment rate, if not create more jobs with a more stable future, while also ensuring the future stability of the New South Wales and greater Australian economies.

I urge you to reject the Narrabri Gas Project application submitted by Santos to ensure our own safety and that of future generations. It is clear Santos' environmental impact assessment is lacking detail about exactly how threats to the environment and public health will be mitigated. Santos has a long and tragic history of at least 20 gas wastewater spills in the Pilliga, and that's while they've only had 56 exploration wells operational. Imagine the devastation that will be caused by the ongoing mismanagement of what is potentially a further 800 gas wells.

The community is united in its declaration that it does not want energy from coal seam gas production. The community wants investment in renewable energy sources to mitigate the immediate threat posed by climate change. Leave the gas in the ground!

Yours sincerely

Kel Raison

We, as Australians must remember that we are custodians of the land. It is a precious and delicate resource. I come from a family which has a long history of farming both livestock and crops. We understand the profound devastation wrought on our landscape in North-Western N.SW.( and elsewhere) though the ignorance and the arrogance of past European farming practices. The waterways and aquifers are a precious resource and they should not be trifled with.

It is inconceivable to anyone with eyes who has close connection to our land, that this complete disregard for the natural and agricultural environments continue in his age. Apparently we have not learnt the difficult lessons of the past. Those officials who are tasked, under solemn oath, to serve their communities and protect our future are squandering this resource.

This arrogance and deliberate ignorance must stop.

The majority of Australians want to preserve, not just our land, but our world for the future. This is not a crazy ideological campaign, but a fight for our children. Deliberate blindness, caused by the short term search for the dollar colours this debate with continued arrogance and ignorance. The arguments for economic rationalism no longer fool us. We see the lies. There is no rationalism in that approach.

Another significant argument must be that this is not our land to squander. Its traditional owners overwhelming reject this violation. The erroneous falsehood of Terra nulius has been assigned to the past mistakes people who say they represent us have made. They do not represent us now in this matter.

This arrogance and deliberate ignorance of violating the Pilliga for the economic gain of Santos must stop. It is not in my name.