Narrabri Gas

Hello

These are 9 only individual submissions made by members of Manly Land Water Life.

Thank you for the opportunity for them to make submissions.

I am opposing this project on numerous fronts, but particularly due to risk to Australia in regards to water reservations (GAB), Environment, Gas Cartel economics, Ecology, Farmland protection, Climate Change and the list goes on. There is no gas shortage just a mismanagement of conventional supplies with no domestic gas reservation enforced and the greater threat of this to other Australian industries and the pressure on house holds. This project is not needed with the risks so high .... what is needed is a conventional Gas reservation policy and a look to energy of renewables. There is no immediate economic benefit to the majority of Australia but a very real cost!

Submission is uploaded below

Part 2 - rest of the appendices

Please find attached a letter of support in relation to the Narrabri Gas Project EIS and DA application.

Attn: Executive Director, Resource Assessments
Department of Planning and Environment
GPO Box 39
Sydney NSW 2001

I object to the Narrabri Gas Project.
Coal Seam, unconventional or on-shore gas projects all over the world are known to cause significant environmental, human health and economic harm to regions in which gasfields are built. Property prices fall dramatically, Doctors and Vets report harm to health of people and livestock and toxic spills and emissions happen. Workers are exposed to conditions which can kill them (checking tanks).

The Narrabri Gas Project is no exception.

Santos EIS submission does not detail gas well sites and other project infrastructure due to the new 'Field Development Protocol'. This seems a haphazard approach and makes Santos less accountable to the public.

Unconventional gas is expensive to produce and has a relatively low yield. When this is balanced against the environmental harm and the harm to the existing industries of agriculture and tourism, there is no sound basis for this project.

Groundwater and the Great Artesian Basin
Santos' project is expected to remove 37.5GL of groundwater over the life of the gasfield. The coal seam needs to be dewatered to release the gas, but this aquifer lies beneath the Pilliga Sandstone, part of the Great Artesian Basin recharge. Santos' EIS admits that the project will result in a loss of water from the GAB recharge aquifer over time. CSG in Queensland has drawn down GAB aquifers already. We can't afford to risk this crucial resource.

Salt
The water removed from the ground by Santos will be treated, but this creates another problem: what to do with the toxic salt? Coal Seam water is millions of years old and contains elements, many of which are toxic like arsenic, lead and radioactive compounds. Peak salt production at Narrabri CSG will be 115 tonnes per day, or two and a half B-double truckloads per day. In the peak year, this would mean the creation of 41,900 tonnes of salt for disposal, which Santos says will take place in landfill.

Cultural heritage and the Pilliga
The Pilliga is a spiritual, cultural and social icon for
Gomeroi/Gamilaraay people. The connection that original peoples have to the land is something that I particularly resonate with. In times of stress, many people turn to places with significant natural value for healing and renewal. The Pilliga Forest is one such place as it offers a haven of woodland and wildlife. It is an amazing floodplain that sees times of aridity and times of flood. As the largest remaining temperate woodland in New South Wales, it really does offer significant spiritual value to even non-indigenous people. The colours, the wildlife, the special sites, the harsh conditions and the long connection that local original custodians have, mean that the Pilliga is a very special place indeed.
People are passionate about the Pillaga
Not only local people will continue to protest against this this project, but people from all over New South Wales who object to unconventional gas extraction and who value natural heritage will continue to oppose it. When Metgasco were endeavouring to drill at the Rosella site in Bentley, Northern New South Wales, the police recommended to the State Government that the risk to Public and Police safety 'is high to extreme' and that there were many risks identified including 'catastrophic' risk of litigation arising out of the Police operation to assist Metgascos' activities, see attachment one. Ordinary people are willing to do extraordinary things when they feel that their lives are threatened.

Biodiversity and the Pilliga
The Pilliga is also the largest temperate woodland in New South Wales. Santos propose clearing nearly 1,000ha of the Pilliga, including habitat for critically endangered Regent honeyeater and for koalas, which are already in decline in the Pilliga. Spread across the whole forest, this clearing will fragment much larger areas of habitat. The gasfield will clear breeding habitat for Pilliga Mouse, which lives nowhere else, and breeding habitat for other wildlife.It will fragment and degrade the forest.Without specific information about where the wells and lines will be located, a proper ecological impact assessment can't be completed. Regardless, the Pilliga is a cherished natural and cultural icon and must be protected from becoming an industrial gasfield.

Ecology
'The Pilliga Forest is the largest remaining unfragmented block of temperate dry forest and woodland in eastern Australia. It functions as a key flora and fauna refuge in a landscape largely cleared for agriculture and is recognised as part of a National Biodiversity Hotspot and as a globally significant Important Bird Area. It supports several
endangered ecological communities and core populations of many threatened flora and fauna species.' Pilliga Eco Report.

I agree with the findings in the Pilliga Ecological Report and hope that its recommendations, starting on page 46, will be taken into consideration and acted upon. I have attached this report.

I am so keen to see the Pilliga protected from mining that I contributed to the Bohena Creek Plant Survey, which I have also attached. Doing this survey confirmed for me that the risks to the Pilliga woodland from unconventional gas extraction are too great.

Air quality
The air quality assessment fails to include health;
damaging fine particulate pollution with a diameter of 2.5 microns or less (known as PM2.5). With diesel generators at
each well pad and at the water treatment and gas compression plants, there will be significant PM2.5 emissions. The air quality assessment and greenhouse section also fail to model the likely substantial escape of fugitive methane emissions.

Dark sky
Light pollution from flares, compressor stations and the water treatment plant will obliterate the dark sky needed by the internationally renowned Siding Spring Observatory.

Thank you for your time and consideration,
Naomi Tarrant
Richmond Hill
NSW 2480

Please find attached BirdLife Australia's submission on this matter.

See attached letter

I have uploaded

I object to this proposal

Dear Planning Officer,

I grew up in NSW, and having observed this industry's tactics and activities in Queensland, I would strongly advise you not to proceed with this.

Like you I was faced with thousands of pages of paper from the proponent. And when I went searching for basic information, it was like looking for a needle in a haystack, and then realising it wasn't there.

Please accept the following documents in relation to Santos' coal seam gas activities in Queensland.

This activity is unsustainable on every level (environmentally, socially and economically).

Please protect the beautiful wildlife, land, water, air and the health of the people in your State.

Thank you,
Simone

Attn: Executive Director, Resource Assessments
Department of Planning and Environment
GPO Box 39
Sydney NSW 2001
Michael Mullen
22nd May2017 Bathurst NSW

RE: Submission to the Narrabri Gas Project EIS.

I object to this project and believe it should be rejected.

I am deeply concerned about the impacts of coal seam gas extraction on groundwater and the resultant impact upon the farming communities of North West NSW. We cannot farm without water. We cannot get insurance to cover us when we sell livestock that have, through no fault of our own, become contaminated from drinking contaminated groundwater from CSG operations.

It will cause economic upheaval in Narrabri and put agricultural industries of the North West Region at risk. The Narrabri Gas Project will drill through a recharge aquifer of the Great Artesian Basin and draw water down from a water resource relied upon by rural communities across western NSW. Santos EIS stated that there is no way to ensure gaswells will not fail, even with world's best practice used.

This Narrabri Gas Project, if approved, would extract over 35 billion litres of salt laden groundwater, much of it in the first five years. This water will be treated and will generate almost 500,000 tonnes of salt waste, for which there is no safe disposal plan. There has already been a number of times that SANTOS operations have resulted in heavy metal pollution, due to inadequate disposal of waste water in recent years, in the Pilliga Forest.

The clearing close to 1,000 hectares of the Pilliga Forest for 425 well pads and the associated infrastructure of pipelines and processing plants will fragment the largest temperate woodland in New South Wales, home to unique wildlife. This land clearing and the entire development of project 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.

There is clear science from USA that CSG extraction and processing results in large and deliberate emissions of methane from venting and leakage, adding to climate change.

The project 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.
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 urge the Government to reject this project and make the Great Artesian Basin recharge off-limits to gas mining.
Yours sincerely,
Michael Mullen
Bathurst NSW

Please see submission in uploaded attachment 1.

Hello Department of Planning and Environment.

Our submission is in the attachments I have uploaded.

Please contact me if this was unsuccessful

Regards

Bruce Holland
Secretary
The Norwood Resource
[email protected]

Please note:
My submission has been uploaded as an attachment.

Please Note:
My submission has been uploaded as an attachment.

Please Note:
My submission has been uploaded as an Attachment

submission attached

Our submission has been uploaded as an Attachment.

Please Note: This is not the final version of our submission. As per my discussion with [the Department] earlier this afternoon, a final review of our submission is still to be undertaken and will be completed sometime tomorrow. The revised submission will be emailed to [the Department] before close of business on Tuesday 23rd May 2017.

Please contact me if you have any queries - 0407 924 765.

This last weekend I was travelling along a track in the Pilliga and the driver said,' This will all be gas wells if Santos gets the go-ahead' - I felt sick with horror at the thought that such vandalism could be countenanced.
I object in the strongest possible terms to the Narrabri Gas Project and believe it must be rejected.
Besides personal travel to the Pilliga and region, I have accompanied students from New England high schools to the Warrumbungles on at least 25 occasions over the past 40 years: introducing them to the Pilliga Forest and the astronomical facilities at the Observatory; lying under the night sky and being told the stories of the Gamilaraai; teaching of the significance of the Great Artesian Basin and the forests as `the earth's lungs' and of the effects of fossil fuels on climate change.
As a teacher and regional resident I believe the following points must lead to the proposal being rejected: 1. the EIS is completely inadequate

 there is no information provided as to where the 850 wells and the lines and infrastructure connecting them will go  a `Field Development Protocol' which allows for future development planning `on the run' is ludicrously inadequate  16 plans mentioned in the EIS are to be developed AFTER approval, this proposal makes a farce of any concept of proper planning

2. There is no economic justification for the project

 Santos is one of the companies which has engaged in contracting to supply unrealistic amounts of gas to overseas markets  the gas produced at Narrabri might be as little as 4.9% of the volume contracted for sale out of Gladstone. Rather than lower gas prices, the Narrabri Gas Project could well drive them up as unconventional gas like CSG is so expensive to produce and yields are so low  The number of jobs the project will support once the construction is over is just 145  In Narrabri, this project will have negative impacts on cost-of-living, the labour and housing markets. The latter is cited as a benefit of the project but it will not benefit low-income renters in the short-term and there are no long-term economic benefits  The effect of the project on cost-of-living in the Shire needs to be modelled, assessed and considered, as do the labour dynamics of the project;  Tourism will be adversely affected as will local industries such as that based on the production of honey.

3. The Narrabri Gas Project risks compromising the Great Artesian Basin and the MurrayDarling Basin and will create a toxic salt legacy

 The area of the Great Artesian Basin with the highest recharge rates is almost entirely contained within the Pilliga East forest. In a worst-case scenario, the water removed for CSG extraction could reduce water pressure in the recharge areas--potentially stopping the free flow of waters to the surface at springs and bores across the whole Great Artesian Basin.  Creeks in the Pilliga run into the Namoi River--a part of the Murray Darling Basin. This system is vulnerable to contamination from drilling fluid spills and the salty treated water produced from the proposed 850 wells.  Three new species of stygofauna have recently been discovered in the
aquifers of the Pilliga; stygofauna feed on bacteria and help to maintain water chemistry and keep groundwater clean; they symbolize the fragility and interconnectedness of the aquifers. Too little is known of the biodiversity and vulnerability of species in the Pilliga to allow the destructive exploitation of csg  The NGP will extract over 35 billion litres of toxic groundwater which will be treated to create tens of thousands of tonnes of salt, for which there is no safe disposal plan. Santos has no solution except land fill for disposing of the hundreds of thousands of tonnes of salt that will be produced. Between 17,000 and 42,000 tonnes of salt waste would be produced each year. This industry would leave a toxic legacy in NSW.

4. The Gamilaraay Traditional Custodians are opposed to the project

There are hundreds of cultural sites and stories connecting the Gamilaraay to the forest and to the groundwater beneath. Gamilaraay people are deeply involved in the battle against CSG. 5. Farmers and other local community members reject the project

Extensive community surveys have shown an average of 96% opposition to CSG. This stretches across a massive 3.2 million hectares of country surrounding the Pilliga forest, including 99 communities. Hundreds of farmers have participated in protest actions unlike any previously seen in the region. 6. The Narrabri Gas Project has a long history of spills and leaks of toxic CSG water--Santos cannot be trusted to manage the project safely

 Santos has already contaminated a freshwater aquifer in the Pilliga with uranium at levels 20 times higher than safe drinking water guidelines, as well as lead, aluminium, arsenic and barium  In addition, there have been over 20 reported spills and leaks of toxic CSG water from storage ponds, pipes and well heads  All wells will eventually fail; the Narrabri Gas EIS contains no plan for maintenance of plant and replacement of equipment and infrastructure beyond the projected life of the project  I visited a spill site over the weekend which was contaminated over 15 years ago - 15 years of `rehabilitation' has simply led to the zone of destruction spreading downhill towards the creek  Rehabilitation proposed by Santos In the EIS (Appendix V) will not meet sign-off criteria: existing sites demonstrate the inadequacy of Santos' rehabilitation programs- only a few native species regenerate- very few under-storey plants or grasses survive  Spillage cannot be remediated and exacerbates the problems of regeneration  Only limited seed banks are proposed

7. The Pilliga is a haven for threatened wildlife; the Project stands to destroy this sanctuary

 The Pilliga is one of 15 nationally listed 'biodiversity hotspots' and is vital to the survival of threatened species like the Koala, Spotted-tailed Quoll, Black-striped Wallaby, Eastern Pygmy-possum, Pilliga Mouse and South-eastern Long-eared Bat.  The forest is home to over 200 bird species and is internationally recognised as an Important Bird Area.
 The Santos gasfield would fragment 95,000 hectares of the Pilliga with well pads, roads, and water and gas pipelines, damaging vital habitat and threatening the survival of endangered species.  While each of the considerations above is, of itself, sufficient to see the proposal rejected, Santos' failure to investigate cumulative risk is deplorable. A tool such as The Namoi Cumulative Risk Assessment Tool (NCRAT) quantifies the risk of cumulative impacts across ten natural resource assets: land use, soils, carbon, surface water, groundwater, vegetation extent, vegetation type, vegetation condition (intactness), vegetation connectivity and threatened species. A proper ecological impact assessment is contingent upon detailed and adequate information as to the placement of all infra-structure. Until such information is provided and adequate ecological impact assessment undertaken, the project must be rejected.
8. Air Quality will be compromised and the Project will contribute to dangerous climate change  Methane is by far the major component of natural gas, and is a greenhouse gas 72 times more powerful than CO2.  Scrubbed CO2, extracted from the methane before it is sent down the gas pipeline is exhausted into the atmosphere; scrubbed CO2 is not mentioned in EIS  CSG fields contribute to climate change through the leakage of methane during the production, transport, processing and use of coal seam gas  The air quality assessment fails to include health-damaging fine particulate pollution with a diameter of 2.5 microns or less (known as PM2.5). With diesel generators at each well pad and at the water treatment and gas compression plants, there will be significant PM2.5 emissions. The air quality assessment and greenhouse section also fail to model the likely substantial escape of fugitive methane emissions.

9. Human health is compromised by coal seam gas  A range of hydrocarbons and volatile organic compounds can be released into the air from coal seam gas operations, including flaring of gas wells. The effects of volatile organic compounds vary, but can cause eye, nose and airway irritation, headache, nausea, dizziness and loss of coordination. These impacts have been documented in human populations nearby to existing gasfields in Queensland and in America.  Santos' social impact assessment is three years old and utterly inadequate. The compendium of health studies produced by the Concerned Health Professionals of New York shows mounting evidence for health damage by unconventional gas operations, including water contamination and respiratory illness. The Government must insist that Santos conduct a proper health impact assessment including modelling exposure pathways, reviewing literature and engagement with the Narrabri community.
10. The nation's premier optical astronomical observatory is at risk from light pollution and pollution impacts on the Narrabri radio telescope facilities have not been recognised  The Siding Springs Observatory, situated in the Warrumbungles and adjacent to the Pilliga, is under threat from the Narrabri Gas Project due to light and dust pollution. The area has been internationally recognized as a 'dark sky park' and the 50m high gas flares proposed by Santos threaten the viability of the facility.  There is no recognition of the cumulative impact of future expansion from PEL238 to other gas license areas much closer to the observatory  Santos has failed to propose adequate mitigation of light pollution from flaring operation- no flare shielding is proposed in-spite of it being an recommendation of the Environmental
Protection Agency  The EIS contains contradictory information about the number of flares: `up to 6' (5.3.3) pilot well flares yet 25 pilot flares operational at any one time (Chapter 24)  Santos has not recognized or mitigated chemical air pollution impacts on the Narrabri radio telescope facilities

Santos has failed to ensure that vital astronomical assets of the Commonwealth of Australia, and 50 other international research institutions are not detrimentally impacted.

11. Risk of fires would increase throughout the Pilliga  Methane flare stacks up to 50m high would be running day and night, even on total fire ban days. The Pilliga is prone to severe bushfires. The project would increase ignition sources as well as extracting, transporting and storing a highly flammable gas right within this extremely fire-prone forest  On page 59, the EIS states that "the proponent would prepare a bushfire management plan". Given that Santos are already flaring in a high bushfire risk forest, how is it that they do not already have a bushfire management plan? The credible risk of catastrophic fires, for which Santos has no management plan, is sufficient reason to reject the proposal.
Any ONE of the considerations outlined above should be sufficient to see the Narrabri Gas Project EIS rejected.