Please make a quick submission on Santos plans for more dangerous CSG exploration drilling in the Pilliga. Just visit this page, scroll down and make your submission directly online. Use the quick points below as a guide. Submissions are due by 9th December.
Santos have stated publically that this exploration project is just the beginning and that they plan to drill 850 wells across the pristine Pilliga Forest, the largest inland forest left in NSW, and the recharge zone for the Great Artesian Basin.
Feel free to copy and paste the points below into the online submission box or write your own reasons why the beautiful Pilliga Forest, a refuge for so many threatened birds, marsupials and wildflowers, is important to you:
SUBMISSION POINTS - SANTOS DEWHURST GAS EXPLORATION PILOT EIS
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.
- 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.
- 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.
- 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.
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.