28 February 2013
Manager
SCER Secretariat
Department of Resources, Energy and Tourism
Canberra ACT 2601
Dear Sir/Madam
The Draft National Harmonised Regulatory Framework for Coal Seam Gas
The Water Services Association of Australia (WSAA) welcomes the opportunity to provide comment
on the above draft framework. WSAA is the peak industry body that brings together and supports
the Australian urban water industry. We have 31 members, the largest water utilities in Australia.
Our members service around 17 million Australians with urban water services. Our Association
facilitates collaboration, knowledge sharing, networking and cooperation within the urban water
industry. We also provide a forum for debate on issues important to the industry and a voice for
communicating the members’ views.
As part of the industry’s 2030 Vision for Urban Water we have four key outcomes:
 striving to be the most efficient, trusted and valued service providers in Australia
 contributing to National policy
 improving our contributions to strategic land use planning
 providing stewardship for the urban water cycle
WSAA understands the importance of coal seam gas and other unconventional gas development to
Australia’s economic and energy future given worldwide demand for energy and the need to
develop sources not associated with high levels of greenhouse gas emissions. As this draft
framework applies only to coal seam gas (CSG) our comments reflect those particular experiences
and views of our members in Queensland and NSW where the fastest growth rate of CSG
development is occurring. Hence, our intention is to highlight some of the broader issues (Table 1)
rather than provide a detailed submission. A number of Queensland and NSW water utilities are
planning to separately submit details of their experiences and make recommendations for
improvement to the draft framework.
Table 1. Broader issues for the draft framework
Issue
Community
engagement
Skilled
resources
Database of
incidents
Impacts on
water supply
authorities
National
Water Quality
Management
Strategy
Local vs
regional
impacts
Comment
It’s likely that the full potential for CSG and indeed unconventional gas development will
depend on:
 setting the broader context for these projects in terms of Australian and global
energy security and greenhouse gas emissions reductions
 good community engagement encouraging transparency in decision-making
processes (including clearly articulating roles and responsibilities)
 avoidance of the use of technical jargon.
As CSG projects may directly or indirectly impact current or future drinking water supplies
WSAA seeks a greater focus in the regulatory framework on best practice community
engagement. This may be appropriate to really identify, assess, understand and manage
social, environmental and economic values associated with water sources.
A loss of skilled staff from regulatory agencies (which is already occurring) may negatively
affect the regulation of CSG activities. The comprehensive development of standard
procedures, guidelines and tools may mitigate this. But there are gaps in the publicly
available guidelines or criteria for assessing risks and developing mitigation mechanisms.
Improving transparency of decision-making processes should assist this.
Create a nationwide database of water quality and environmental incidents at facilities.
Analyse and report on trends.
 Establish appropriate avenues for information sharing and engagement between
regulators, operators and water supply authorities during project appraisal and
operations (particularly incident management). This includes advising water supply
authorities of the risk assessments made for hydraulic fracturing so those
authorities may make their own appraisal of the risks and the adequacy of their
own monitoring and risk management activities.
 ‘Make good’ or compensation arrangement s should be extended to cover instances
where water supplies are interrupted or otherwise compromised because of water
quality impacts from CSG activities
Make explicit the links between the draft framework, the NWQMS and guidelines prepared
under the strategy.
The impact of broader regional, particularly incremental changes in water levels over time
may need further assessment. Water allocation issues really need to consider the flow on
and cumulative effects particularly where aquifers interact over a number of surface
catchment areas.
WSAA is happy to elaborate on any of the above.
Yours sincerely
Adam Lovell
Executive Director