Submission to be uploaded-- see file attachment 1

To whom it may concern
I object to Santos `Narrabri Coal Seam Gas Utilisation Project (Wilga Park Power Station)
Modification 4 - Beneficial Use of Gas from Coal Seam Gas PEL 238'.
I am objecting because of the growing body of evidence, in Australia and internationally, that coal seam gas mining (CSG) has catastrophic effects on the environment and public health, and that too little is being done to restore the destruction mining companies inflict.
I am concerned that (to date) it appears that no-one is held accountable for the destructive consequences of CSG, especially environmental and agricultural ruin that cannot be undone; mining companies seem to up and abandon the devastation they wreak, while politicians continue to politic and deny their culpability. I don't trust that any proposed CSG mining contracts and/or protection agreements are worth the paper they are written on.
The risk to human and environmental health, as a consequence of coal seam gas mining, cannot be ignored. Australian citizens have a legal right to the safety and protection of our water systems, agricultural resources and native environment. And it is the duty of Australian government officiates to act under their sworn allegiance to protect both citizens and country to guard both.

SUPPORTING REFERENCES
https://www.youtube.com/watch?v=LNzv0F3sLrA

https://www.youtube.com/watch?v=ayhPNCUoQ7I

https://www.youtube.com/watch?v=b61lkgfw464

http://www.edonsw.org.au/court_to_decide_if_santos_pilliga_csg_facility_illegal

Yours sincerely
Tracey Rieniets

Armidale Action on Coal Seam Gas and Mining is grateful for the opportunity to have its views in the matter of Modification 4 considered.
AACSG&M is gravely concerned regarding a number of aspects of the Modification and consider that the ill-conceived amendment in 2015 to the Petroleum Exploration Onshore Act of 2007 (PEOA) is being used by Santos to effect a movement from exploration into production covertly There is inadequate, or indeed no, information in Santos' proposal concerning:
 the environmental impact of using this gas in the power stations relative to flaring or releasing it  the amount of clearing that would be required for the necessary water and gas pipelines  at what time royalties would become payable and at what percentage scale. Currently, it appears that NSW will derive NO direct financial benefit from any gas produced CSG production in the Pilliga has been rejected by the community; Santos and the Government have no social licence.
This modification allows a devious bypassing of proper process.
The Minister must reject this application and require Santos to fully declare its intentions in the Pilliga; the quantity of gas it intends to extract and burn, or flare and release, the length of time it intends to continue expanding its exploration activities and whether this will go beyond the 850 wells already planned, with inadequate environmental concern and public scrutiny.
Kind regards, AACSGaM per Jan Brahe, Treasurer.

I now understand the tactics that Minister Andrews and Josh Frydenberg were referring to when they laughed with each other at COAG over how people would hate them. This move by SANTOS is completely underhanded and nothing short of a malicious attack not only on our water security today, but the water security for generations of Australians to come. How is it POSSIBLE that with the evidence from around the world that this is a dangerous form of mining (despite manipulative efforts by the gas industry to suppress this evidence with confidentiality agreements and/or gag orders) and in a country such as ours we should even consider this toxic form of mining given our 'perilous water security ' (Rob Vertessy, outgoing head of the BoM).
All of you who are complicit in this I hope will find yourselves facing trial under these new international laws on environmental crime. http://mobile.abc.net.au/news/2016-09-17/icc-to-turn-focus-to-environmental-crimes-over/7854696
And as you consider expanding the power station, it is high time to leverage our abundant renewable resources. In case you have forgotten, this Paris agreement has been ratified, so agin, what are you thinking? http://unfccc.int/paris_agreement/items/9444.php
The fact this is also going ahead without an EIS in place is also evidence of appalling mismanagement or corruption. Although an EIS that gives this the thumbs up would have to be seriously questioned ~ you don't have to look hard to find hard evidence of irreversible water contamination where onshore gas mining has taken place. http://www.usatoday.com/story/money/business/2014/01/05/some-states-confirm-water-pollution-from-drilling/4328859/
Are those moving this forward in such haste also aware of the exponential increase in law suits awarding damages to those impacted by onshore gas mining? Why are you walking into that?
Despite the dreadful effort of that industry PR stint, the movie Fracknation, to discredit Gaslands, here are examples of the kind of damages being awarded for the contamination in Dimock http://www.ecowatch.com/jury-awards-two-dimock-couples-4-2-million-after-finding-cabot-oil-gas-1882188335.html
Is our government willing to compensate like this? They will be called upon to do it eventually ~ just look at QLD water in the gas fields to find out why. Or is SANTOS going to couch up for this? Are their shareholders aware?
Finally, what right do you have to reduce the value of the farmers' land in the area to nothing with this intrusion in agricultural zones? https://www.theguardian.com/environment/2016/sep/30/commonwealth-bank-coal-seam-gas-makes-property-unacceptable-as-loan-security
If we continue to do this on the limited agricultural land we have in Australia at a time of population growth and growing global instability we will send our farmers off the land. We need to protect our water and our long term food supply above all else.
Do not allow this project to expand, in fact you should move to shut the whole thing down right now.
Also taking into consideration the impact on the true an entire traditional Gomeroi people's, their sacred areas and the land, animals and plants that is not yours to destroy !!!
Thanks for the opportunity to make a submission.
With great concern, Helen

As a resident of the adjoining PEL450 I wish to lodge an objection to Modification 4 - Beneficial Use of Coal Seam Gas from PEL238 by Santos.
I am appalled at what appears to be complete bypassing of proper process without adequate scrutiny by concerned and affected community members. Santos seems to be using a loophole regarding so called "beneficial use" to push aside required assessment before any expansion to the number of wells and their use for production and in addition infrastructure that they might need - it would amount to "production by stealth". There are a large number of reasons for my objection to this modification :-
* Santos have not yet produced an EIS for the project despite being 2yrs overdue. This modification does not assess disturbance to forest or threatened species caused by well or pipeline construction. Nor does it yet provide any solution to salt produced from the proposed Leewood RO plant operation.
* using this loophole allows Santos to avoid royalties to NSW taxpayers for this gas - so it's not very financially "beneficial" to taxpayers just to shareholders!
* right across the North West of NSW communities and LGAs have expressed strong opposition to CSG production in the Pilliga and elsewhere, with many councils passing resolutions to this effect. There is no social licence to expand this project in any way and especially without public scrutiny of such a modification to their current operation.
* the Santos application is short on detail - how much gas will be removed and used, what will that impact have from the power station, what provision is there for monitoring 'fugitive emissions' or health implications of "additional wells and supporting infrastructure" into the future.

The Minister should completely reject this poorly detailed application for modification which appears to be an open ended application for "open slather" production through the back door with completely inadequate assessment of impacts on water, health, threatened species, forest integrity, air quality and dangerous methane fugitive emissions from an unspecified expansion of wells and infrastructure.

I am against any modifications in this project until a detailed environmental impact study is approved detailing where waste is placed , I also am against this development due to the social and environmental impacts that this industry practices example the Surat Basin in Queensland

Submission from Armidale / Tamworth Greens
Santos Mod 4

The Armidale / Tamworth Greens would lodge an objection to Santos submission of Modification 4 of the application for the modification to the Part 3A approval to the original conditions to Narrabri Coal Seam Gas Utilisation Project which was originally granted to Eastern Star gas with the New South Wales (NSW) Department of Planning. Since 2011 Santos have applied for and been granted three (3) other modifications to the original approval all of which were small in nature.

Modification 4, has the potential, if granted, will enable Santos to use the coal seam gas from exploration wells, both existing and future build without lodging an EIS. Santos will profit from the use of this gas under the guise that the gas is for beneficial use. Santos indicate the gas will be used at the Wilga park power station, but does not limit the use to this function.
The Application states on page 2, Santos is seeking approval for the following modification allowing- Use of coal seam gas from existing or future well within PEL 238 at the Wilga Park Power Station consistent with the recent  amendment to the Petroleum (Onshore) Regulation 2007. This would be in addition to the currently approved use of gas from pilots within PAL 2 and PPL.

The application then goes on to state- This modification application applies to any existing or future approved pilot wells within PEL 238.

On page three after listing all the existing pilot wells that are outside the PAL 2 and PPL3 the application states- exploration and appraisal continues within PEL 238 and PAL 2, approval for the  installation of additional pilot wells and supporting infrastructure may be sought.

Santos is abusing the provisions of beneficial use of gas during the exploration phase. It would not be wise to flare or vent, rather than use the gas, but Santos are expanding their operations significantly without providing an Environmental statement or community consultation, under the guise of an allowable modification. By continuing to produce gas for profit on an exploration licence Santos are avoiding their social responsibility to pay royalties on an unknown quantity of gas
Santos are required to be transparent and gain a production licence, also to submit Environmental Impact Statements for every development.

There are many community concerns regarding this misuse of Section 28B of the Petrolium Onshore Act-
* There is no mention in the application of Santos' full scale production project for 850 wells. Why is further exploration and appraisal activity required in PEL238 if Santos have now applied for a production project?
* The community has rejected CSG production in the Pilliga and approval of this modification would amount to a devious bypassing of proper process by Santos and the Government, allowing CSG production to occur with little to no environmental assessment or public scrutiny, despite much public opposition.
* There are many unanswered questions, the amount of clearing planned in the Pilliga, and the effect on wildlife, particularly endangered species and the iconic Pilliga koala population.
* How do Santos intend to manage the issue of light effecting the Siding Springs Observatory?
* While quietly increasing production Santos will also increase the quantity of produced water. Without an EIS the community cannot comment on the plans to use the water and manage the large quantity of salt.
* Santos will be in full production by stelth, without submitting an EIS
The Minister must reject this modification application and require Santos to fully disclose their plans in the Pilliga, the quantity of gas it intends to extract and burn, or flare and release, and the length of time it intends to continue expanding its exploration activities without submitting and EIS.

Yours Sincerely

Pat Schultz
Armidale Tamworth Greens

I would like to object to the modification:

Santos is seeking approval for the following modification allowing: Use of coal seam gas from existing or future wells within PEL 238 at the Wilga Park Power Station consistent with the recent amendment to the Petroleum (Onshore) Regulation 2007. This would be in addition to the currently approved use of gas from pilots within PAL 2 and PPL 3.

Comment: We have laws and planning acts in place for a reason. Producing gas to burn to create electricity to sell is gas Production. It must require that gas obtained to fill the power station is obtained via a Production licence.

CSG exploration activities and licences in NSW are not subject to the same level of assessment as production wells and licences.

If Santos wants to sell gas into a power station, the company should first apply for a production licence for the area of their wells. Go through the proper process, and get an outcome. That is what should be expected of any company operating in NSW. The grid of gas pipelines compression stations and processing plants is already questionable to have been approved just for CSG exploration.

The community expects the best from the NSW Government and to take a firm but common sense approach to this modification.

Thank you for considering this submission. Please advise that it has been received.

Kind regards,

Santos is seeking to modify the existing Wilga Park approval to enable the use of coal seam gas from existing or FUTURE WELLS within PEL 238 WITHOUT ANY EIS. Santos' existing approval only allows them to use CSG from wells in PAL2 & PPL 3 , which has limited wells.

It is important that Santos complete another EIS for future wells in PEL 238. The process must be seen by the public to be open and transparent and not subject to favours. No one person or company should be above the legal process, after all we still are a democarcy and want no corruption.