More EIS Notes –Final edition
14.3.5 Groundwater Systems
Shallow Groundwater System
“The system is also more prone to modification due to the infiltration of pollutants, nutrients and agricultural chemicals,
such as fertilizers, herbicides and pesticides, into shallow subsurface profile due to land development, settlement and
urbanisation.”
The Queensland Water Commission’s Draft Underground Water Impact Report states that “Recharge to the aquifer occurs
primarily due to infiltration from the Condamine River, with some contribution directly from rainfall and laterally from the
surrounding bedrock and tributaries of the Condamine River. The consistent layer of low permeability black soil (up to 10m
thick) over most of the Condamine Alluvium restricts rainfall recharge.”
And see also 14.3.5 Groundwater Systems
Shallow Groundwater System, which states that “Shallow aquifers in the project development area recharge predominately
from surface drainage, in particular the main branch of the Condamine River. However, recharge of the Condamine
Alluvium aquifer can be inhibited by the presence of surfical cracking clay soils that swell when wet and reduce the volumes
of infiltration to the watertable below.” See also Appendix G – 3.5.10
If the low permeability black soil layer over the Condamine Alluvium restricts rainfall recharge, then it seems unlikely that
the infiltration of pollutants is a problem. That the Condamine Alluvium is the town water supply to half a dozen towns in
the local region as well as the domestic supply to hundreds of rural residential dwellings emphasizes this point. This is a
serious point as Table 5.1 lowers the biological value of this resource because of the claim that this water is modified by
pollutants.
•
•
The proponent must provide evidence to support the claim that shallow groundwater systems, namely the
Condamine Alluvium are prone to modification due to the infiltration of pollutants, and to the extent that these
supplies are not potable.
If the proponent cannot provide evidence that the shallow groundwater systems including the Condamine
Alluvium have been modified by pollutants then the environmental values of these groundwater resources must
be reassessed and reassigned a higher value.
Table 14.6 Summary of Groundwater Values
“Shallow Groundwater System – Ecological Value
The system is more prone to modification due to the infiltration of pollutants, nutrients and agricultural chemicals, such as
fertilizers, herbicides and pesticides, into shallow subsurface profile due to land development, settlement and urbanisation.”
The Queensland Water Commission’s Draft Underground Water Impact Report states that “Recharge to the aquifer occurs
primarily due to infiltration from the Condamine River, with some contribution directly from rainfall and laterally from the
surrounding bedrock and tributaries of the Condamine River. The consistent layer of low permeability black soil (up to 10m
thick) over most of the Condamine Alluvium restricts rainfall recharge.”
And see also 14.3.5 Groundwater Systems
Shallow Groundwater System, which states that “Shallow aquifers in the project
development area recharge predominately from surface drainage, in particular the main
branch of the Condamine River. However, recharge of the Condamine Alluvium aquifer can
be inhibited by the presence of surfical cracking clay soils that swell when wet and reduce
the volumes of infiltration to the watertable below.” Also Appendix G – 3.5.10
If the low permeability black soil layer over the Condamine Alluvium restricts rainfall
recharge, then it seems unlikely that the infiltration of pollutants is a problem. That the
Condamine Alluvium is the town water supply to half a dozen towns in the local region as
well as the domestic supply to hundreds of rural residential dwellings emphasizes this point.
This is a serious point as Table 5.1 lowers the biological value of this resource because of the
claim that this water is modified by pollutants.
•
•
The proponent must provide evidence to support the claim that shallow
groundwater systems, namely the Condamine Alluvium are prone to modification
due to the infiltration of pollutants, and to the extent that these supplies are not
potable.
If the proponent cannot provide evidence that the shallow groundwater systems
including the Condamine Alluvium have been modified by pollutants then the
environmental values of these groundwater resources must be reassessed and
reassigned a higher value.
Table 14.6 Summary of groundwater values
Potential Consumptive and Productive Uses
“Groundwater from this system has generally low to moderate total dissolved solids
concentrations (average of approximately 1,300 mg/L), allowing a wide range of beneficial
uses; however, it is predominantly suitable for agricultural use within the project
development area.”
The proponent has understated the environmental value of the Condamine Alluvium
aquifer. I cannot find a single reference within the entire document that states that the
Condamine Alluvium aquifer is a potable water supply that is accessed by the towns of
Pittsworth, Millmerran, Dalby, Brookstead, Macalister and ??????? and provides drinking
water to hundreds of rural residents on properties within the project development area.
•
The proponent must reassess, properly describe and reassign to a higher value, the environmental values relating
to shallow groundwater systems in the project development area.
Table 14.7 Sensitivity of the value of each groundwater system
“Shallow groundwater system
• Groundwater from this system is a supply generally suitable for agricultural uses.
• The shallow groundwater system is dynamic, with several recharge mechanisms, producing a resilient system and
enabling regular and rapid groundwater level recovery, compared with confined systems.”
The Condamine Alluvium aquifer is an important potable water supply. Failure to acknowledge this undervalues the
sensitivity of the system. SEE SALINITY YIELD MATRIX
Upstream of Tipton, the Upper Condamine River is a losing stream, which means that water moves from the river to
recharge aquifers. Inflow from the Condamine River is the major source of recharge for the Condamine Alluvium. However,
the extent of this recharge is spatially heterogeneneous. Groundwater levels recharge significantly more rapidly closer to
the river than they do in the central portion of the Condamine Alluvium, some distance from the river. Therefore, there are
areas where the system is resilient and areas where the alluvium is significantly less resilient.
Table 14.8 Summary of predicted unmitigated indirect groundwater drawdown in shallow, intermediate and deep
groundwater systems states that for the Condamine Alluvium “Recovery is predicted to be slower than drawdown, with
groundwater levels not returning to initial levels by 2061. Additional model outputs (Appendix G, Groundwater Impact
Assessment Report) show that groundwater levels also do not recover to initial levels by 2071, which is the maximum
temporal extent of the model.
In light of the above, the sensitivity of the shallow groundwater system in the project development area has not been
properly assigned.
•
•
The proponent must assess the Condamine Alluvium’s use and potential use as a potable water supply. This is
essential to determine the system’s level of sensitivity with regard to consumptive and productive values (see
Table 14.3)
The proponent must assess the variation in the Condamine Alluvium’s ability to recharge. Such investigations
may alter the systems level of sensitivity regarding resilience to change, system dynamics and rehabilitation
potential (see Table 14.3).
14.4.5 Other subsurface Activities
“Other activities conducted in the subsurface profile have the potential to impact on groundwater values as listed below:
• Incomplete or incorrect well installation may result in interconnection of aquifers and consequential crosscontamination.”
I can find no other information in the Environmental Impact Statement that addresses incomplete or incorrect well
installation and the potential impacts of these on groundwater environmental values.
•
•
•
•
What percentage of wells does the proponent estimate will be incompletely installed?
What percentage of wells does the proponent estimate will be incorrectly installed?
Has a risk assessment been conducted to determine the potential impacts of incomplete and incorrect
installation of wells on groundwater values?
If not, the proponent must be instructed to provide all necessary information to satisfy the above questions.
An additional comment on the groundwater model
I recall from a community engagement session in Cecil Plains in May 2011 that Arrow stated that non-petroleum
groundwater extraction was not factored into the Arrow Groundwater model. Given that the current level of extraction is
215,375 ML per annum in the Great Artesian Basin Plan area, more than double the level of extraction estimated by the
Queensland Water Commission in the Draft Underground Water Impact Report, this is a serious deficiency in Arrow’s
model.
•
Arrow’s groundwater modelling must be rerun, including annual extraction by non-petroleum and gas
groundwater users.
Chapter 15 – Surface Water
15.3.1 Overview
“Six sub-basins and 64 subcatchments lie within the project development area. The Condamine is the predominant subbasin within the project development area, accounting for over 50% of the total area.”
The Condamine sub-basin is an important source of surface water for agriculture, both in the form of stream flows in the
Condamine River and its tributaries, and from overland flows of surface water across the floodplain. Overland flows within
the Condamine sub-basin can occur as a result of;1. overflows out of the Condamine River and its tributaries;
2. flooding of the land due to heavy and/or high rainfall;
3. a combination of 1. and 2.
Given that more than 50% of the project development area lies within the Condamine sub-basin, and the importance of
overland flows on the Condamine floodplain to the stream systems and to agriculture, it is surprising that the proponent
has not recognised the environmental value of overland surface water in this assessment.
•
Chapter 15 – Surface Water, Appendix H - Surface Water Part A and Appendix I – Surface Water Part B must be
rewritten to account for overland flow surface water. The environmental value of overland flow water must be
identified and properly described. After this, the appropriate impact assessment must be undertaken and
mitigation strategies proposed to minimise harm.
15.3.3 Stream Flow
Condamine-Culgoa Basin
“The Condamine River, which forms the northern headwaters of the Murray-Darling river system, is largely a continuous
flowing river that distributes flood flows into such watercourses as Wilkie Creek during large flood events.”
The Condamine River is not largely a continuous flowing river. It is in fact an ephemeral river, that undergoes periods of no
flow during dry times. There are many references in the literature to support this. It is crucial to understand the fluvial
morphology of this river, particularly when coal seam gas proponents are gaining approvals to dump coal seam gas water
in it.
•
The proponent must redescribe the Condamine River as an ephemeral river.
15.3.6 Flooding
“A review of historical flood information, including extent, levels and frequency, has been undertaken for major waterways
within the project development area using information available from BOM.”
The proponent’s failure to identify the environmental value of overland flow water means that a review of the historical
overland flow flood information has not been undertaken and its importance not realised.
•
A review of historical flood information for overland flow on the Condamine floodplain must be undertaken.
15.3.6 Flooding and Appendix H – 4.6 Flooding Frequency and Extent
“For the Condamine River, the December 2010 flood event is estimated to be a 30-50 year ARI flood event for the project
development area upstream of Dalby.”
This is an interesting finding. The BOM records for river gauge heights at Cecil Plains indicates that the December 2010
flood had the highest river height recorded since February 1942, measuring 9.22 metres. This is also the second highest
river height measurement for Cecil Plains ever recorded, the record dating back to the 1890’s. It is strange therefore, that
the proponent estimates the December 2010 flood to be a 30-50 year ARI flood event. Anecdotal evidence from
landholders in the area also indicates that the December 2010 flood was the largest in living memory, based on flood
heights in and around houses and the extent of overland flow observed. The December 2010 flood was a 50-100 year ARI
event.
•
The data presented needs to be changed to reflect the December 2010 flood as a 50-100 year ARI event.
15.6.1 General Mitigation Measures
“Note that, in Table 15.6, the only directly relevant sensitive area for surface water is Lake Broadwater Conservation Park, a
Category A ESA; however, the proposed buffers for all category ESAs are provided for completeness.”
Table 15.6 Proposed buffer distances from the ESA boundary
ESA Category
Proposed Activities within
Proposed Activities within
the ESA
200m of the ESA Boundary
Category C: excluding
Low-impact activities
Low-impact activities
regional ecosystems with
an ‘of concern’ status,
state forests and timber
reserves
Proposed Activities within a
Secondary Protection Zone
Limited petroleum activities
within 300 m of the primary
protection zone
*ESA buffers (derived from the guidelines under the EP Act 1994: Model Conditions for level 1 Environmental Authorities for
Coal Sean Gas Activities) will be applied unless the activity occurs in pre-existing cleared areas or significantly disturbed land
within the buffer and no reasonable practicable alternative exists.
- Low-Impact Activities. These activities include the limited prescribed activities that do not result in the clearing of native
vegetation, cause disruption to soil profiles through earthworks or excavation, or result in significant disturbance to land.
Examples of such activities include but are not limited to soil surveys; topographic, cadastral and ecological surveys; and
traversing land by car or foot via existing access tracks or routes.
- Limited Petroleum Activities. Such activities include single well sites not exceeding 1 ha of disturbance and multi-well sites
not exceeding 1.5 ha of disturbance, geophysical surveys, ecological and geological surveys, gathering pipelines from a
wellhead to the initial production facility, supporting access tracks, and roads and communication and powerlines necessary
for the undertaking of petroleum activities. The definition excludes construction of dams, borrow pits, production facilities
and construction camps.”
The Upper Condamine Irrigation Project is a Category C ESA. SEE ATTACHEMNTS This status has been assigned to the area
for its agricultural / irrigation significance. The landscape has been cleared and significantly disturbed from its natural state
for agriculture, but it is these attributes that have resulted in the area being given Category C ESA status. These attributes
include the agricultural fields, the water return systems associated with the irrigation fields and all of the associated hard
irrigation infrastructure including dams, pipes and pumps.
The proponent has stated that ESA buffers will be applied unless the activity occurs in pre-existing cleared areas or
significantly disturbed land AND no reasonable practicable alternative exists. The proponent has identified that there will
be limited petroleum activities occurring over the entire extent of the project development area (see Appendix M, Table
2.1 and Figure 9.1 for examples). Therefore, there are no shortage of reasonable practicable alternative locations for
limited petroleum activities within the project development area.
•
The administering authority must condition that within the Category C ESA buffer of the Upper Condamine
Irrigation Project area, only low-impact petroleum activities can be undertaken by the proponent.
Chapter 17 Terrestrial Ecology
Figure 17.2 Environmentally sensitive areas within the project development area
This map indicates an extensive area of the project development area covered by category C Environmentally Sensitive
Areas.
17.6 Avoidance, Management and Mitigation Measures
17.6.1 General Measures
Planning and Design
“•Aim to avoid
- Category C ESA’s
Table 17.10 Proposed buffer distances from the ESA boundary
ESA Category
Proposed Activities within
Proposed Activities within
the ESA
200m of the ESA Boundary
Category C: excluding
Low-impact activities
Low-impact activities
regional ecosystems with
an ‘of concern’ status,
state forests and timber
reserves
Proposed Activities within a
Secondary Protection Zone
Limited petroleum activities
within 300 m of the primary
protection zone
*ESA buffers (derived from the guidelines under the EP Act 1994: Model Conditions for level 1 Environmental Authorities
for Coal Sean Gas Activities) will be applied unless the activity occurs in pre-existing cleared areas or significantly disturbed
land within the buffer and no reasonable practicable alternative exists.
- Low-Impact Activities. These activities include the limited prescribed activities that do not result in the clearing of native
vegetation, cause disruption to soil profiles through earthworks or excavation, or result in significant disturbance to land.
Examples of such activities include but are not limited to soil surveys; topographic, cadastral and ecological surveys; and
traversing land by car or foot via existing access tracks or routes.
- Limited Petroleum Activities. Such activities include single well sites not exceeding 1 ha of disturbance and multi-well sites
not exceeding 1.5 ha of disturbance, geophysical surveys, ecological and geological surveys, gathering pipelines from a
wellhead to the initial production facility, supporting access tracks, and roads and communication and powerlines necessary
for the undertaking of petroleum activities. The definition excludes construction of dams, borrow pits, production facilities
and construction camps.”
The Upper Condamine Irrigation Project is a Category C ESA. SEE ATTACHEMNTS This status has been assigned to the area
for its agricultural / irrigation significance. The landscape has been cleared and significantly disturbed from its natural state
for agriculture, but it is these attributes that have resulted in the area being given Category C ESA status. These attributes
include the agricultural fields, the water return systems associated with the irrigation fields and all of the associated hard
irrigation infrastructure including dams, pipes and pumps.
The proponent has stated that ESA buffers will be applied unless the activity occurs in pre-existing cleared areas or
significantly disturbed land AND no reasonable practicable alternative exists. The proponent has identified that there will
be limited petroleum activities occurring over the entire extent of the project development area (see Appendix M, Table
2.1 and Figure 9.1 for examples). Therefore, there are no shortage of reasonable practicable alternative locations for
limited petroleum activities within the project development area.
•
The administering authority must condition that within the Category C ESA buffer of the Upper Condamine
Irrigation Project area, only low-impact petroleum activities can be undertaken by the proponent.
Chapter 18 – Landscape and Visual Amenity
18.6 Avoidance, Mitigation and Management Measures
18.6.1 Planning and Design
“• Hide or screen the facility using natural landscape features or planted native vegetation barriers, where appropriate to
the landscape sensitivity. Avoid removal of mature trees and other woodland features that screen views to facilities.
Establish screening barriers using endemic species in advance of construction of the facilities. [C267]”
And see also Plate 18.1 and 18.2
The planting of large stands of native vegetation to screen project facilities in Type B , Arable Lands landscapes will result in
land subsidence in these areas. This will be extremely problematic for irrigated land use operations, and would potentially
constitute a breach of environmental authority conditions. It is known that land can subside several feet in Type B areas
where vegetation has been planted and remains growing for some time.
•
•
How will the proponent effectively screen production facilities in areas where plant screens cause land
subsidence and consequent issues to current land use?
How does this information affect the results of Table 18.5 Summary of landscape and visual amenity impact
assessment for Landscape Type B?
Chapter 19 Roads and Transport
19.2.1 Identifying Existing Road Conditions
“ To establish the current conditions of the roads and road network throughout the project development area, a desktop
study and a qualitative assessment were conducted including:
• Review of existing data and information to identify volumes of traffic, construction standard (e.g., sealed or unsealed), rail
crossings, stock routes, school bus routes and safety record.
• Characterisation of road types within the project development area and the associated values of each.
• Classification of sensitivity for each road type in relation to its vulnerability to changed traffic conditions.”
The current conditions of the roads throughout the project development area were determined through desktop
assessments only. No field assessments were undertaken. This approach fails to factor in other environmental influences
which may impact on the conditions of roads within the project development area, particularly the variation in soil type
that roads are constructed on.
The desktop assessment assumes that each of the road types are constructed to the same standard regardless of location
and underlying soil type. This may be the case. Certainly this Road Impact Assessment assumes as much. Assuming this is
so, variations in soil type over the project development area will also contribute to the existing road conditions. Gravelly or
sandy soil types contribute to roads that are in better condition and have higher tolerances, relative to high clay soils, all
else being equal.
•
The proponent must conduct field assessments of the current condition of each road type over the all of the
various major soil types found within the project development area.
19.2.3 Strategic Traffic Modelling
“Traffic generated by workforce personnel during the construction phase has been considered for traffic travelling to and
from Toowoomba or Brisbane and traffic travelling to and from production facilities and wells to the construction camps.”
Figure 9.2 of Appendix M – Road Impact Assessment shows the location of ‘well parcel centroids’ over the project
development area. This figure demonstrates that wells will be located over the entire project area, including the area
generally east of Cecil Plains.
There is a considerable gas reserve located in the area east of Cecil Plains associated with geological formations known as
the Cecil Plains Syncline and the Horrane Trough. Figure 9.2 also shows that there will be no traffic from the proposed
project travelling from Toowoomba to the proposed gas fields in the area generally east of Cecil Plains, even though “traffic
generated by workforce personnel during construction has been considered for traffic travelling to and from Toowoomba
and Brisbane”, and the Toowoomba-Cecil Plains is the most direct route to this Horrane Trough area from Toowoomba and
Brisbane. The Toowoomba-Cecil Plains Road is a reasonably heavily used road that is currently in very poor condition owing
to the underlying soil type, the heavy use of this road by light and heavy vehicles, and the floods and wet weather in recent
years.
There is therefore a fundamental error in the modelling undertaken by the proponent with regard to workforce vehicle
movements from Toowoomba and Brisbane.
•
The Road Impact Assessment modelling needs to be redone to take into consideration traffic movements to and
from the Dalby and Millmerran/Kogan blocks of the project development area along the Toowoomba-Cecil Plains
Road.
19.3.2 Traffic Growth and Volumes
“ Annual average daily traffic volumes (based on 2009 data) for state-controlled roads within the project development area
vary, with highest volumes (1,000 to 2,999 vehicles per day) on roads servicing the main townships (i.e., Chinchilla, Dalby
and Millmerran).”
There has been a considerable expansion of coal seam gas industry activity in the project development area since 2009.
Table 7.1 Projects in Surat Gas Project Development area in Appendix M – Road Impact Assessment provides an estimated
start date of 2011 for the GLNG and QCLNG projects, and these projects have in fact commenced, as has the APLNG
project.
I can appreciate that the most recent data available for Arrow’s Road Impact Assessment may have been in 2009, but the
proponent needs to be mindful of a couple of points. Firstly, that Appendix M – Road Impact Assessment was completed
in September 2011, almost two full years after the end of 2009. Second, that Appendix M states that “those projects with a
higher traffic generating potential over an extended period of time are the larger resource projects (predominately coal and
gas production. These projects have 20 to 40 year timeframes and are likely to significantly contribute to additional
background growth on the road network.” Only their potential effects are discussed in Section 14 – Cumulative Impacts.
Section 14 – Cumulative Impacts states that “Other major projects in the wider area are assumed to use similar methods
and technology to the Surat Gas Project meaning it is likely that their production methods and facilities will generate a
similar traffic generation. Therefore, given that the scale of operations of other gas projects is assumed to be similar to the
Surat Gas Project, it is likely that over the project life a similar traffic generation is expected assuming similar levels of
operation.”
From my personal experience of driving on these roads, I find it very difficult to believe that, as the proponent has
estimated, the total increase in traffic volumes from these other projects will only be in the order of 1% to 4% of total
traffic volumes. However, the proponent has indicated this is a significant increase. The three other coal seam gas
proponents undertake fraccing activities which significantly increases the total number of vehicle movements, particularly
heavy vehicle movements in relation to the proponent’s vehicle movements.
•
What are the actual traffic generation data from the other three coal seam gas proponents within the project
development area?
•
In order to determine the actual increase in vehicle movements from these other projects since 2009, and prior
to any impacts from this project, current 2012 traffic volumes on highways and regional connecting roads within
the project development area must be determined.
19.3.9 Road Attributes
“• Safety. Safety includes aspects of the physical road infrastructure that relate to safety, e.g., bridges, rail crossings, cattle
grids and standard of road construction.”
The standard of road construction as a safety aspect road attribute is not included in Table 19.1 Environmental
characteristics of functional road types (typical observations). 19.3.10 Environmental Values states:- “The environmental
values of highways have been identified as having low sensitivity to changes in traffic and transport conditions due to their
high construction standard suited to a higher-order purpose. Regional connecting roads display a moderate sensitivity to
change in road conditions, and rural connecting roads and rural access roads display a high sensitivity due to lower
construction standard and lower existing usage.”
•
If standard of road construction is a safety aspect of roads and is an environmental value of roads depending on
road type, then Table 19.1 must be amended to include standard of road construction under the Safety heading,
and describing the identified environmental value according to road type.
Table 19.2 Estimated traffic generation by key project activities
Activity
Quantity
Activity
duration
Traffic Generation (Two-way Trips)
Heavy Vehicle
Bus
Light Vehicle
Construction Phase
Production wells
7,500 wells
10 days
50/well
-
91/well
Table 5.4 Aggregate volumes
Production facility construction aggregate volumes based on the following:
Integrated processing facility = 5,000 m3
Central gas processing facility = 2,500 m3
Field compression facility = 1,500 m3
Camps = 2,000 m3
Assumes that there will be 1,500 production wells in each development region.
5.2.3 Production Facilities states:The approximate footprint for a field compression facility is 100 m x 50 m.
The approximate footprint for a central gas processing facility is 600 m x 250 m.
The approximate footprint for an integrated processing facility is 800 m x 250 m for plant and associated buildings and one
to two km2 for water storage.
When the calculations for foundation aggregate thickness of facilities are made using the aggregate volumes provided in
Table 5.4 and the dimensions of the production facilities as per 5.2.3 the results are:Field compression facility foundation aggregate thickness is 30 centimetres;
Central gas processing facility foundation aggregate thickness is 1.67 centimetres;
Integrated processing facility foundation aggregate thickness is 2.5 centimetres;
For production well access roads and well pads the following dimensions were used;
Well pad dimensions 85 m x 85 m (from Appendix F, 6.2 Production wells)
Access track length 1,100 m (from Appendix F, 6.3 Low Pressure Pipelines)
Access track width 5 m (from Chapter 5, Figure 5.13)
When calculations for foundation aggregate thickness of production well access roads and well pads are made using the
above dimensions and aggregate volumes from Table 5.4 the result is a foundation thickness of 1.1 centimetres.
Clearly, the aggregate volumes that have been estimated for the foundations of all of the production facilities have been
substantially underestimated. I would conservatively estimate that aggregate volumes required for the project would be in
the order of 20 to 50 times the volume stated in Table 5.4. The total aggregate would increase from 1,099,500 m 3 to at
least 20,000,000 m3. Such an increase would place considerable pressure on existing borrow pits and quarries, other users
of those resources, transportation and road infrastructure to name a few. It should be noted that this information impacts
substantially on the results of the road impact assessment (Appendix M).
•
•
•
How many of the 50 heavy vehicle movements per production well are accounted for by the cartage of aggregate
for construction of the well pad and access track?
If the figures for the number of heavy vehicles carting aggregate for access tracks are included in the total heavy
vehicle trips for gathering infrastructure and not production well construction, how many of the total two way
trips for gathering infrastructure are for cartage of aggregate?
The above questions apply equally for all project activities in the Construction Phase of the project and the
decommissioning phase of the project where aggregate is removed for rehabilitation.
19.4 Issues and Potential Impacts
“The significance of the potential impact caused by an increase in traffic is dependent on the percentage increase in volume
occurring on individual sections of road and the sensitivity of the functional road type. Highways are designed for higher
volumes of traffic and are more resilient to impacts related to increased traffic volumes than lower order roads.”
The proponent has provided the authors of the Road Impact Assessment with a Field and Facility Development Sequence
(Appendix C of the Road Impact Assessment) which includes the total number of wells commissioned in each year. The EIS
states that wells are constructed in ‘pods’ consisting of 10 wells and associated gathering infrastructure. Most of the
production wells in the project development area will be constructed on lands adjacent to rural connecting roads and rural
access roads, which have the highest sensitivity due to lower construction standards and lower existing usage.
Many of the rural access roads within the project development area are unsealed roads. Environmental conditions at the
time that traffic is operating on these roads will have a bearing on the level of impact they will sustain. Conditions where
the roads are too wet or too dry for the weights and volumes of traffic operating will cause damage to these roads.
It is inappropriate for the proponent to compare the project’s annual average daily traffic with the annual average daily
traffic volume servicing the main townships, which are located at junctions of highways and regional connecting roads with
low to moderate sensitivity.
If the significance of the potential impact is dependent on the percentage increase in volume occurring on individual
sections of road and the sensitivity of the road type, then the data from this modelling must be presented in this way.
•
•
•
•
If there are 63 heavy vehicle movements and 105 light vehicle movements related to the construction of each
well head and its associated gathering infrastructure, and this figure is multiplied by ten for the pod under
construction, what percentage increase in volume of traffic on rural connecting roads and rural access roads does
this represent?
Please provide the percentage increase in volume of traffic that will occur on the road types associated with the
locations of the parcel numbers in Appendix C of the Road Impact Assessment?
Are there threshold limits for vehicle numbers and/or vehicle weights according to the road type? If yes, do these
limits vary between regional council areas? Provide information on the traffic threshold limits for each of the
road types by regional council area within the project development area?
Will the proponent impose travel restrictions on project activities and travel when environmental conditions,
such as wet and dry, are such that the likelihood of road damage is increased?
19.6.2 Efficiency, Safety and Amenity of Regional Connecting, Rural Connecting and Rural Access Roads
“• Assess and identify the need to upgrade unsealed roads or widen sealed roads where project activities and traffic will
create road safety issues. Such works will be done in consultation with the relevant council (If a local government road) or
DTMR (if a state road).[C258]
The proponent does not state which party is responsible for upgrades of unsealed roads or widening of sealed roads where
project activities create road safety issues. Appendix O – Economic Impact Assessment states that “Surat Gas Project
activity in these areas is expected to reduce pavement life by approximately 5% or more. That is, in the absence of
upgrades/increased repairs and maintenance, roads will deteriorate more rapidly, with potential (direct and indirect)
economic and social costs.
It is anticipated that Arrow will collaborate with local council’s to identify relevant contributions for road upgrades and
maintenance. Assuming relevant transport impacts related to the Surat Gas Project are compensated by Arrow, the net
budgetary impact to government will be zero (additional costs will be offset by additional revenue).”
•
•
•
Is the proponent or is the relevant government authority responsible for the financial cost of road upgrades
where it has been identified that project activities and associated traffic will cause road safety issues?
Is the proponent or is the relevant government authority responsible for road repairs required as a consequence
of the proponent’s activities and traffic on roads that have not been previously identified in collaboration with
local councils?
Has the proponent conducted an economic assessment of the financial cost to the relevant government
departments from increased road repairs and maintenance as a consequence of project development activities?
19.6.2 Efficiency, Safety and Amenity of Regional Connecting, Rural Connecting and Rural Access Roads
“Maintain the integrity of private roads and tracks and minimise dust generation, where appropriate, in consultation with
relevant landowners and council. [C031]”
•
•
•
•
•
What does “maintain the integrity” mean?
How will the integrity of private roads and tracks be maintained?
What are the minimisation of dust generation strategies? Does this refer to wetting unsealed roads with
produced coal seam gas water?
If so, in what instances is the minimisation of dust generation appropriate? In which instances is it not
appropriate?
What coal seam gas water qualities will be used for dust suppression on soils in the project development area
with a clay content of greater than 30%?
19.6.2 Efficiency, Safety and Amenity of Regional Connecting, Rural Connecting and Rural Access Roads
“Undertake threshold assessments to determine whether upgrading of rail crossings is warranted. [C286]”
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If threshold assessments are possible, then why have threshold assessments of the various road types in the
project development area not been undertaken?
The proponent must undertake threshold assessments of all of the road types within the project area.
The proponent must determine whether the threshold is different between locations within the project
development area of differing soil type.
Chapter 20 Noise and Vibration
20.2 Assessment Methods
“The noise and vibration assessment involved identification of the baseline noise environment, modelling of potential noise
sources and assessment of potential impacts associated with the project.
As the site location and facility design are yet to be finalised, the impact assessment was based on a typical site layout and
indicative equipment, with the site assumed to be located in an acoustic environment typical of the project development
area.”
The project development area already contains operational production facilities for the Dalby Expansion Project. These are
located at Tipton/Grassdale and Daandine. Therefore, the site locations for some of the project processing infrastructure
are known, and the proponent has the ability to take actual noise readings from these facilities to compare with the
modelled noise levels. These comparisons would provide information on the accuracy of the predicted modelled noise
levels from production facilities and would inform as to the accuracy of the model.
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The proponent must measure the noise levels from existing production facility infrastructure within the project
development area to compare with noise levels predicted through modelling. This information will inform as to
the accuracy and relevance of the modelled limits.
20.2 Assessment Methods
“For the purposes of the assessment a sensitive receptor is considered to be a location in the vicinity of the proposed
development, where noise may affect the amenity of the land use. Sensitive receptors in the project development area are
generally considered to be dwellings (but also include a library, childcare centre, kindergarten, school, college, university or
other educational institution; a hospital, surgery or other medical institutions).”
According to the Environmental Protection (Noise) Policy 2008 (Qld) (EPP Noise) commercial places are also considered to
be sensitive receptors.
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What is the definition of a commercial place?
Why has the proponent not included commercial places in their list of sensitive receptors in this Section?
Are commercial places located on the proponent’s sensitive receptor maps?
If not, why?
20.2.3 Modelling Assumptions
“Given that construction equipment and techniques have not been finalised, noise levels were modelled based upon
knowledge of sound levels of typical construction equipment.”
“ Operational noise levels were modelled on indicative equipment.”
Since Arrow has already drilled some hundreds of production wells and has processing facilities for their domestic business
located at Tipton and Kogan, I find it interesting that at this time, construction equipment and construction techniques for
the Surat Gas Project have not yet been finalised.
One must also question why previous measurements of construction and operational noise levels for production facilities
and wells have not been taken at existing locations. Especially since 20.2.7 Vibration states that “The assessment of
vibration impacts of the project on sensitive receptors has been based on previous measurements of vibration levels at
similar facilities with similar equipment and settings.”
So similar facilities with similar equipment and settings are available for noise measurement. It would have been nice to
compare the noise levels modelled in this Impact Assessment with noise measurements previously taken.
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Are there any noise measurement data available for the construction and operation of production facilities and
wells within the project development area to compare with modelled predicted levels in Appendix N – Noise and
Vibration Impact Assessment?
20.4.4 Predicted Construction Noise Levels
“For construction of production facilities, modelling predictions indicate that, under worst-case meteorological conditions
where noise propagation is pronounced, the daytime long-term noise criterion of 40 dB(A) will be met at sites located 3 km
or more from the facility site.
If activities were to be undertaken at a distance of less than 3 km from the noise source, acoustic treatment would need to
be applied in order to meet the criteria.
Similarly, for construction of production wells and pipelines, modelling predictions indicate that if activities were to be
undertaken at a distance of less than 1 km from the noise source, acoustic treatment would need to be applied in order to
meet the criteria.”
Table 8.4 and Table 8.19 of Appendix N – Noise and Vibration Impact Assessment, list the main noise sources and their
maximum overall sound power during construction of the production facilities and during construction of production wells
respectively. All of these noise sources are from commonly used plant and equipment such as trucks, graders and air
compressors. It is therefore reasonable to expect that the various acoustic treatments that can be applied to each of these
types of plant and equipment are known, as are the post treatment sound pressure levels.
Section 8.1.8 of Appendix N – Noise and Vibration Impact Assessment lists the mitigation measures to be implemented to
reduce the noise impact at sensitive receptors. These include the following:• Ensuring noise reduction devices such as mufflers are fitted and operate effectively;
• Ensuring machinery or equipment is not operated if maintenance or repairs would eliminate or significantly reduce a
characteristic of noise from its operation that is audible at the nearest residences;
• Locating noise making equipment or processes such that their impact on the closest sensitive receptor is minimised. This
will be achieved by maximising the distance to the closest sensitive receptor, or using structures or elevations to create
barriers;
• Operating equipment and handling material so as to minimise impact noise;
• Shutting or throttling down equipment when not in actual use;
• Using off-site or other alternative processes that eliminate or lessen resulting noise;
• Commencing any particular noisy part of the work after 9:00am;
•Where practicable, restricting noisy construction work or equipment to the hours of 7am to 6pm.
The proponent also highlights that “In practice, it is unlikely that all equipment will operate continuously and
simultaneously. Specific mitigation measures will be confirmed once actual construction processes are known and modelling
or measurements have been conducted.
In certain circumstances, the established criteria may not be able to be achieved due to the nature of the construction
activity. Where there is potential for such an event to occur, community liaison and communication will be conducted.”
For plant and equipment that when purchased, have a muffler, it is likely that the maximum overall sound power level for
such plant and equipment has been measured with the muffler on.
The protection of environmental values is achieved by adhering to the noise criteria at sensitive receptors as prescribed by
the administering authority, in accordance with the relevant legislation. The minimisation of noise is not an appropriate
mitigation of its own, unless the noise minimisation achieves a resulting noise level at sensitive receptors in accordance
with the relevant noise criteria for the type of noise event.
Similarly, commencing noisy work after 9:00am is not an appropriate mitigation of its own, unless the noise level at 9:00am
at sensitive receptors is in accordance with the relevant noise criteria for the type of noise event.
Restricting noisy construction work or equipment to the hours of 7am to 6pm, where practicable is also not an appropriate
mitigation of its own, unless the noise level during this time period at sensitive receptors is in accordance with the relevant
noise criteria for the type of noise event.
That specific mitigation measures will be confirmed once actual construction processes are known and modelling or
measurements have been conducted appears to indicate, in light of all of the above, that the proponent actually doesn’t
have a clue how it will comply with the noise criteria at sensitive receptors during construction of production wells and
production facilities. The same could also be said of the construction of pipelines.
Section 8.2.1 of Appendix N – Noise and Vibration Impact Assessment states “It is noted that Arrow will locate equipment
associated with the production wells that produces noise at a minimum distance of 200m from a sensitive receptor. There
may be infrastructure, which will be located within 200m of a sensitive receptor, such as the underground pipelines,
however the infrastructure will not produce significant noise and will not have a noise impact at the sensitive receptor.”
Table 8.24 models noise levels from the construction of pipelines and shows that the noise criteria for sensitive receptors
will be exceeded for all periods of the day for all the distances modelled from 50m up to 1000m away.
It appears likely that the mitigation measures proposed above will do little to reduce the noise levels at sensitive receptors.
For a company that has been producing gas since 2006 and proposes to expand operations to the extent proposed in this
EIS, it seems implausible that “actual construction processes” and “specific mitigation measures” apart from those
identified above, are at this time still unknown. Rather, the omission of this information from this document appears
deliberate, because the specific mitigation measures are those already identified, apart from individual site selection of
infrastructure. Similarly, the actual construction processes are those that have been identified here and are similar to
construction processes already undertaken by the proponent. If the existing infrastructure was deemed similar enough for
vibration measurements then surely it is similar enough for noise measurements. The proponent then confirms that the
above comments are in fact true by stating that “in certain circumstances, the established criteria may not be able to be
achieved due to the nature of the construction activity.”
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What are the acoustic treatments that would need to be applied in order to meet the noise criteria at sensitive
receptors if production facility construction activities were to be undertaken at a distance of less than 3 km from
sensitive receptors?
Similarly, what are the acoustic treatments that would need to be applied in order to meet the noise criteria at
sensitive receptors in production well construction and pipeline construction activities were to be undertaken at
distances less than 1 km from sensitive receptors?
Provide evidence of the extent of noise reduction achieved by acoustic treatment to the plant and equipment
used for production well, pipeline and production facility construction?
Are there any other forms of acoustic treatments that may be used, for example structures or elevations to
provide noise reduction at sensitive receptors?
Provide evidence of the extent of noise reduction at sensitive receptors achieved by structures or elevations?
Evaluate how the use of structures and elevations to reduce noise at sensitive receptors impacts on other
environmental values such as soils, agriculture, surface water and visual amenity.
For plant and equipment that are constructed with mufflers attached, confirm whether the maximum overall
sound power level provided in Tables 8.4 and 8.19 for these plant and equipment is with the muffler attached.
When will specific mitigation measures and actual construction processes be known?
When they are known, will specific mitigation measures be modelled prior to construction of production wells,
pipelines and production facilities?
Describe the nature of community liaison and communication in the event that noise criteria at sensitive
receptors cannot be achieved?
Will this community liaison and communication be conducted prior to construction of any production wells,
pipelines and production facilities?
20.6.3 Operation
“• Where practicable, schedule planned flaring events (e.g., those preceding shut-down maintenance) for the period
between 6 a.m. and 10 p.m. [C313]”
Temperature inversions are common climatic events within the project development area. There is a potential that flaring
during a temperature inversion can cause environmental harm.
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What is the usual duration of shut-down maintenance?
Do planned flaring events associated with shut-down maintenance last for the duration of the maintenance
period?
What time of the day are temperature inversions most prevalent?
What happens when flaring occurs during a temperature inversion?
20.7 Residual Impacts
“Residual impacts are expected to be negligible as the impact assessment determined that relevant criteria can be achieved
at sensitive receptors through the use of appropriate mitigation measures, where necessary.”
20.6.1 Planning and Design states that “the principal mechanism for avoiding impacts on the acoustic environment of
sensitive receptors is through site selection and incorporation of acoustic treatments into facility design.” Site selection
would be the principal mechanism for avoiding impacts relating to infrastructure construction, while site selection and
acoustic treatments in facility design together are mechanisms for avoiding impacts during production facility operation. In
light of the comments for 20.4.4 it is clear that the residual impacts for construction of production wells, pipelines and
production facilities will not be negligible unless production wells and pipelines are sited at distances greater than 1 km
from sensitive receptors and production facilities are sited at distances greater than 3 km from sensitive receptors.
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Will the proponent employ the principal mechanism of site selection for avoiding impacts on the acoustic
environment of sensitive receptors from construction of production wells, pipelines and production facilities,
given the other mechanisms are unlikely to significantly reduce the impacts?
Appendix N – Noise and Vibration Impact Assessment
5.2 Description of Existing Environment
“ML 4 is situated at a sensitive receptor, approximately 3.8km from Tipton West Central Gas Processing Facility and
approximately 800m to 1500m from existing production wells, while ML 1 is situated approximately 1700m to 2200m from
existing production wells.
The calculated RBLs for ML 4 are significantly greater than those for the other three locations as the measured background
noise levels at ML 4 were influenced by continuous noise predominately from existing production wells with hydraulic well
heads”
The production wells are closer, but the processing facility might be noisier.
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What percentage of the RBLs for ML 4 are attributed to the production wells and what percentage to the
production facility?
* Appendix C: Measured Background Noise Levels, Figure C:4 Measured ambient and background noise levels at ML 4
shows that LAeq and LA90 exceed the noise criteria at sensitive receptors for long-term noise events for the time period
10:00 p.m. to 6:00 a.m.
* Has the proponent considered the noise impact of reverse beepers fitted to light and heavy vehicles in this Noise and
Vibration Impact Assessment?
I understand that it may be an OH&S obligation for the beepers to be fitted to vehicles engaged in project development
activities. The noise from these beepers is loud and annoying. Considering that project activities can occur over a 24 hour
period, reverse beepers have the potential to cause serious impacts to sensitive receptors. If they haven’t been considered
in the assessment then they need to be.
Chapter 21 Economics
21.3.2 Local, State and Commonwealth Government Taxes and Revenues and the Australian Dollar
“A strong Australian dollar assists many businesses and households that purchase goods and services from overseas
through potential effects of exchange rates on the price of these goods and services. However, a strong Australian dollar
can also be a negative for industries that sell their products and services overseas (for example, manufacturing, some
agricultural commodities, and tourism related sectors), as these products and services are more expensive to foreign
buyers.”
This is also the case for export sale of LNG. Chapter 3 – Project Need states “In 2008/09, LNG accounted for A$10.3 billion
of Australia’s export income. In 2009/10, the value decreased to A$7.8 billion, though exports increased by 16% to 18Mt.
The global economic downturn, and the increased strength of the Australian dollar relative to the US dollar, contributed to
lower LNG prices during the latter period.”
Further uncertainty regarding the export price of LNG has occurred since the publication of this document, primarily
through the increase in competition on the global market, most notably through US sellers. Massive cost blowouts and
time delays are also reducing the financial viability of the LNG projects. Increased global competition surely will place
downward pressure on the price of gas over time, further decreasing export income. Arrow has claimed that they are
immune to these external pressures since they are essentially selling to a parent. However, they are not selling to the other
parent, who will expect to return profits from their investment, and Arrow is thus not closeted from market issues. In any
event, the result for Queensland, who owns the gas, is a significant relative reduction in income proportional to the
volumes of gas sold.
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What is the extent of the energy sector’s impact on the Australian dollar?
What will be the proponent’s contribution to impact on the Australian dollar from the Surat Gas Project?
Can the proponent provide estimates of the sale price of LNG over the life of the project?
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Can the proponent provide estimates of the relative loss of revenues over the project life because of a high
Australian dollar?
21.3.3 Population, Employment, Workforce and Wages
“The Darling Downs’ resident population has been growing at a slower rate than Queensland in recent years and
projections by the Queensland Government suggest population will expand at a similar rate over the next 20 years.
However, these estimates and projections do not take into account the region’s sizeable and growing transient population
that has been attracted by significant mining and gas exploration and development activity.”
There is a lot of mixed information regarding transient mining populations. Undoubtedly, they increase pressure on rental
markets and transport infrastructure and take much of the wealth generated in a region out of that region.
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What is the demographic of the sizeable and growing transient population related to mining and gas activities?
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What is the projected size of the transient workforce for the Surat Gas Project?
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What is the economic impact of transient mining and gas populations on the Darling Downs?
21.3.8 Summary of Values
“The stability and sustained growth of the Darling Downs economy is the most important value of the economic
environment in the project development area.”
I would add that a diverse economy is also one of the most important values of the Darling Downs economic environment.
The coal seam gas industry is a short-term industry, compared with other local industries such as agriculture and
administration. It is a potentially dangerous economic situation where a single short-term industry is growing at the
expense of the other sectors.
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Would the proponent consider that a diverse economy is also one of the most important values of the economic
environment in the project development area?
How is the proponent fostering a diverse economy within the project development area?
21.4.2 Impacts on Local, State and Commonwealth Government Taxes and Revenues and
the Australian Dollar
“Additional workers locating permanently or temporarily can be expected to contribute to
council revenues through additional rates revenue associated with dwellings and workers
camps that are constructed to meet additional demand and any appreciation in land values
brought about by increased population. The net impact on each regional council is expected
to be neutral in the long run, with additional revenues used to fund additional capital or
operating expenditure to ensure the marginal cost to users is the same.”
It is my understanding that workers do not pay rates for living in workers camps. Further,
there is no financial gain to regional councils from workers camps in the local council area.
However, these camps place upward pressure on council infrastructure. Their presence
however, may add to appreciation in land values.
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Do workers camps contribute to local government rates revenue?
What are the positive and negative economic impacts of workers camps to local
governments?
Provide the analysis to show that the net impact to regional councils will be neutral?
21.4.2 Impacts on Local, State and Commonwealth Government Taxes and Revenues and
the Australian Dollar
“Payroll tax and royalty revenues will be the two largest contributors to Queensland
Government revenues, with a total estimated at $1.69 billion.
On an annual basis, the project is estimated to provide approximately $120.8 million to the
Queensland Government”
Out of these payroll tax and royalty revenues, the state government must deduct any costs
to the state from project impacts. The cost to the state government for road repairs that
occur as a consequence of project development would bite heavily into the annual payroll
tax and royalty revenue. Although Chapter 19 – Roads and Transport and Appendix M –
Road Impact Assessment calculate that the impact from the project on roads will be
negligible, there are serious errors in their assessments and predicted outcomes.
The amount of aggregate for the various project activities has been seriously
underestimated, thereby increasing the use of roads in the project development area by the
proponent. No field assessments of current road conditions within the project development
area have been undertaken, and many of the roads are in very poor condition. This
information is not captured in the Chapter and Appendix. Further, the sensitivity of some of
the roads have been incorrectly identified because the soil type under the roads, which
influence road condition, have not been taken into account. Lastly, some of the roads in the
project development area that will be heavily utilised during project activities have been
excluded from analysis, so the assumption for these roads is zero impact.
There will be other additional costs to the state and federal governments from the Surat Gas
Project, including telecommunications, health and administration to name a few.
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The proponent must calculate the dollar amount that the state government (and
local and federal governments if applicable) will spend per annum on road repairs
that are related to project activities.
The proponent must provide information about all additional costs to local, state and
federal governments resulting from the Surat Gas Project.
21.4.2 Impacts on Local, State and Commonwealth Government Taxes and Revenues and
the Australian Dollar
“Support for the Australian dollar will be provided through production of high-value gas for
export as LNG. This will, in turn, result in lower comparative prices for foreign goods and
services.”
The proponent makes this sound like a high Australian dollar is a good thing. The high
Australian dollar is negatively impacting on tourism, education, manufacturing and
agricultural industries as well as cutting into the profitability of petroleum and mineral
exports.
Chapter 3 – Project Need states “In 2008/09, LNG accounted for A$10.3 billion of Australia’s
export income. In 2009/10, the value decreased to A$7.8 billion, though exports increased by
16% to 18Mt. The global economic downturn, and the increased strength of the Australian
dollar relative to the US dollar, contributed to lower LNG prices during the latter period.”
According to these figures, if the 18Mt of LNG sold in 2009/10 was sold at 2008/09 prices, it
would have accounted for almost A$16 billion in export income, but actually achieved only
half of this.
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What will be the impact of the Surat Gas Project on other export industries including
tourism, manufacturing, education and agriculture?
Has the declining profitability of LNG exports been considered in Queensland’s and
Australia’s balance of payments projections?
Has the proponent provided alternative scenarios of export income from the Surat
Gas Project with varying values of the Australian dollar?
Appendix O – Economic Impact Assessment
Appendix H: Cost Benefit Analysis Results
Approach
“The following CBA to assess the net impact of the Surat Gas Project has been conducted at
the state level.”
Identification of Impacts
“This section provides a summary of the identified costs and benefits anticipated to result
from the development of the Surat Gas Project that would not otherwise occur.”
Costs
“•Lost incomes of employees as a result of foregone production outlined above. It should be
recognised, however, that this is largely a reallocation of labour (and the source of their
income) rather than actual loss, and has a corresponding benefit in terms of additional
incomes generated by these new activities (included below);
• Potential environmental impacts of the project, e.g., groundwater impacts, greenhouse gas
emissions, or damage to any natural habitats within the development footprint.”
It is pleasing to see that the proponent admits that the employment benefit of the project is
less to do with providing new jobs for Queenslanders and Australians, but largely a
reallocation of labour instead. This reallocation of labour has already begun, as employees
from the agriculture, manufacturing and service industries are moving across to the mining
and petroleum sector. The impacts to these other industries is severe, and likely to continue
and worsen as the labour demands from projects already approved increases and new
projects come on line.
Farmers are struggling to find and keep staff and labour costs are increasing. The
agricultural service industry is struggling to maintain staff levels and continually retraining
new employees is an added cost. Resturants in towns like Dalby are losing staff because
they can’t compete with the wages being paid for service employees at work camps. There
are difficulties getting mechanical repairs done to private vehicles due to shortages of
labour. Small manufacturing businesses are closing their doors because they cannot find and
keep staff.
The value of foregone production across the Queensland economy as a result of additional
competition for, and reallocation of, constrained resources (e.g., labour) does not
adequately cover all of the other negative financial impacts to businesses that are occurring
as a result of resource development.
The cost of tree clearing, whether in natural habitats or on third party properties, has not
been included.
The additional infrastructure costs to the state as a result of the project have not been
identified, even though impacts to these infrastructure have been raised in the Chapter.
21.4.6 Impacts on Local Infrastructure and Services states “Infrastructure constraints are
already being experienced in the region, in particular road and rail transport and
telecommunications infrastructure. The Surat Gas Project is expected to place additional
demand on this infrastructure.”
The additional infrastructure costs to the regions and the state from the project have not
been included in the cost benefit analysis.
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Negative business impacts other than the value of foregone production must be
included in the cost benefit analysis including higher costs of operation or closing of
businesses resulting from labour constraints or increased input costs, or other.
The cost of tree clearing must be included in the potential environmental impacts as
part of the cost benefit analysis.
Provide information on the dollar value of the cost to environment that was used in
the cost benefit analysis.
The proponent must redo the cost benefit analysis including the infrastructure costs
to the state.
* If the cost benefit analysis has been undertaken at the state level, how are the revenues to
the proponent, which is a wholly foreign owned company in a 50-50 joint venture between
Petro China and Royal Dutch Shell, considered a benefit when all profits are going off-shore?
* The cumulative economic impacts of the Surat Gas Project and each of the three other
major LNG projects that have been approved, has not been properly assessed. This
assessment needs to identify the cumulative cost benefit of the three other proponents
without the Surat Gas Project. Whilst the benefits may be reasonably straightforward to
assess, the costs will really only become evident after project activities proceed. Only when
the costs of the other projects are calculated can a proper assessment of the cost benefit of
the Surat Gas Project be determined.