1
Public Consultation Submission
First Exposure
Draft of the National Harmonised
Regulatory Framework for Coal Seam Gas
TO:
EMAIL:
MAIL:
FROM:
AUTHORISED
REPRESENTATIVES
POSITIONS
ADDRESS
EMAIL:
PHONE:
NOTE
CONFIDENTIALITY OF
SUBMISSION
SCER Ministers
scer@ret.gov.au
Manager
SCER Secretariat
Department of Resources, Energy and Tourism
GPO Box 1564
Canberra ACT 2601
FRIENDS of GIPPSLAND, MIRBOO NORTH – Lock the Gate
Against New Coal & CSG (including shale & tight gas) (FoGMN)
A Clark, A Corcoran, P Halabarec, A & R Hall, G Margaret, S
Massey, D Menzies, P Piper, K Schilke, M Thomas & S
Wightman
FoGMN, SCER Submission Working Group Members
www.fogmirboonorth.org.au
gayle@forgmirboonorth.com.au or info@fogmirboonorth.com.au
P Piper 03 5668 8276
Unless stated, quotes are from the SCER Report
PLEASE MAKE OUR WHOLE SUBMISSION PUBLICLY
AVAILABLE ON THE SCER WEBSITE
2
SUMMARY OF FoGMN’s SCER Submission
Our group started about 18 months ago and are now a network of 100s of people who stay
in touch through email, by phone, face to face in the streets and local newspaper articles. A
core group of about 15 people attend planning meetings and are active in informing ours
and surrounding communities about the CSG Industry and developments via market stalls
and gaining their support for our community actions. We are currently:



Surveying local households to gain their support for a Coal & CSG free community.
As a community, we, like Poowong, want to declare our town New Coal & CSG free;
Collecting signatures on our petition to the Victorian Government to BAN fracking
and the CSG and similar Industries like shale and tight gas and to change legislation
to give landholders the right to say no to Mining on their land. This petition is about
to go on the GetUp website, on other community group websites and on facebook;
and
Writing our submission to the SCER Report on behalf of the community.
Gippsland is a diverse region with a mix of people from young families to retired people. It
is a beautiful, pristine area with scenic views that attracts people for lifestyle, business,
employment, recreation and tourism reasons.
Gippsland is Victoria’s food bowl. It has a reputation for clean, quality agricultural products.
It provides about 25% of Australia’s dairy products. It also includes other farming like beef
cattle, sheep for food and wool, alpacas for wool, orchards, vegetables (especially potatoes)
and vineyards. It has a growing tourism Industry that includes B&Bs, boutique foods (like
cheeses, beers and wines), historical, recreation and leisure activities (like Golf, Bowling
and sporting clubs, walking and riding trails). It has a vibrant, diverse retail sector with new
shops and an active, civic-minded community. These Industries/sectors already provide a
very high level of employment and income for local communities.
The 4,500 bike riders on the Great Victorian Bike Ride stayed overnight in Mirboo North last
December. They voted Mirboo North their “favourite town” that they visited along their ride
from Lakes Entrance to Phillip Island. Bicycle Network Victoria, gave this feedback from the
riders: “Mirboo North is a beautiful location and the community hospitality and spirit was
absolutely fantastic…There was a great vibe, a sense of community spirit and pride by all
which the riders acknowledged and appreciated.”
THIS IS ALL AT RISK FROM NEW COAL MINING, CSG, SHALE & TIGHT GAS. The
region is covered by several Exploration Licences owned by Mantle Mining and other
Companies (see DPI Maps). The Licences cover black and brown coal mining and CSG.
This is WHY people from all walks of life have come together to support and volunteer their
time and skills to stop new coal mining and unconventional gas extraction like CSG, shale
and tight gas.
All Australian state, territory and federal governments have finally acted on the community
groundswell of concern across the country as well as those raised by individuals at the
hearings of the Senate Inquiry headed by Bill Heffernan last year (A final report has still not
been released – only media articles). There is a Moratorium in place while our state,
territory and federal governments decide what to do. We expect these decisions to be
made in May/June at the next COAG meeting when the Moratorium is due to stop and the
Standing Council on Energy Resources (SCER) will report to the Coalition Of Australian
Governments (COAG).
3
The SCER, which is made up of all state, territory and federal Ministers for Energy
Resources, released its Report titled “The Draft National Harmonised Regulatory
Framework – Coal Seam Gas” (The SCER Report) on 14th December 2012 for community
consultation by 28th February 2013.
The SCER Report is INCOMPLETE. It refers to the Multiple Land Use Framework (MLUF)
of which only a 3 page outline including a flowchart page is available at the moment.
However, this is the “OVERARCHING” document to the SCER Report. How can any real
consultation occur when only half the information is available?
The MLUF is based on the Governments’ principle of CO-EXISTENCE. This concept is
flawed. It starts from the premise that multiple land uses are desirable and then includes
CSG in the mix. We do NOT accept this. CSG is too high a risk for all other COMPETING
(non compatible) land uses including:
 residential (our health and well being);
 business (our local economies including agriculture, horticulture (orchards, nurseries
and wineries), retail, tourism, accommodation, recreation and leisure etc.)
 farming (our food supply)
 water catchments (our water supplies – including bores, springs, dams, irrigation
etc.)
 heritage and cultural areas
 environmental (preservation and conservation of our fauna and flora); and
 public/crown lands (our amenity and scenic landscapes).
Many landholders, Real Estate Agents and Councils have identified other UNacceptable
risks that the CSG Industry brings with it. These include:
 Devaluation of properties;
 Devaluation of businesses;
 Devaluation of Council rateable properties (and so Council income);
 Inability to sell properties; and
 Inability to sell businesses
People coming together via the Lock the Gate Movement have been very successful in
informing and empowering each other to take action to prevent New Coal Mining & CSG
companies and their representatives from coming onto their private land. Many people
have put up Lock the Gate yellow triangular signs for this purpose and got their Councils to
support a motion for a Moratorium which all state, territory and federal governments have
since adopted.
People have been so effective in this that the SCER Report recognises that access to
private land is now a problem for the CSG Industry. It therefore proposes to plan for current
and successive multiple land uses. What will be the process for the development of these
new Planning Laws? How will communities participate in this development process? What
are the implications of these new Planning Laws? Will Local Councils be responsible for
adopting and enforcing these new Planning Laws?
The SCER Report is LIMITED in its coverage of only CSG. It does NOT include other forms
of unconventional gas that use similar techniques like shale and tight gas. Doctors for the
Environment, Australia have argued for CSG, shale and tight gas to be treated together.
We support this and note that our comments made in this Submission are just as relevant to
the New Black and Brown Coal Mining Industry too.
The SCER Report does not mention the issue of the huge quantities of highly contaminated
salt produced and stored by the CSG Industry in settling/holding ponds and in heaps that
4
are kilometers long and metres high, that cannot be decontaminated, used or disposed of
safely. What, if anything can be done about this problem?
This is a particular issue in flooded areas eg. QLD currently where, these settling/holding
ponds and these huge storage piles of highly contaminated salt have mixed several times in
recent years with flood waters, entered our soils, streams and marine environments. See
the Lock the Gate Alliance website.
We expect this to be treated as part of the Report’s discussion of water contamination. The
National Toxics Network has identified many harmful toxins in both the contaminated water
that the CSG Industry produces and their stores of salt. Why has this matter not been
discussed in this Report?
The SCER Report is also based on the Governments’ principle of BALANCED DECISION
MAKING. This is a misrepresentation of the facts. The Environmental Defender’s Office
Victoria (EDOV) has identified that the Mining Industry including CSG receives
“PRIVILEGED LEGAL TREATMENT” and will continue to do so if the SCER Report is
adopted by Governments.
In its Report “Reforming Mining Law In Victoria”, the EDOV recommends reforms to our
Coal and CSG regulation because it currently “…fail(s) to protect or respect regional
communities, fails to protect key natural resources (like groundwater and prime agricultural
land) and treats the environment as an afterthought……….(It) does not give (people)
information about projects that may affect their health and livelihoods and…does not give
(people) a real say in whether or how mining goes ahead…(The EDOV) condemns the
privileged legal treatment that the mining industry receives. (It feels that this is)…based on
the shaky assumption that mining is an inherently desirable activity, the public benefits of
which always outweigh the costs. (This) privileged treatment is in stark contrast to the
equivalent rules for renewable energy. The laws that apply to wind farms in Victoria, for
example, are a lot more stringent than those that apply to coal mines…Recognising these
failures, the (EDOV Report) calls for reform (including)…more protection for the
environment…more rights and respect for regional communities....any person to have the
right to appeal a licence decision on the merits….(and)…to enforce a breach of the mining
laws.” We support the EDOV’s recommendations.
The SCER Report also stresses the importance for Governments to make BALANCED
DECISIONS about:
 The CSG Industry’s continued growth (based on Net Benefit, Energy Security and
Sustainability)
 Land use/s (based on Co-Existence/MLUF and redefining Community)
 The issues raised by the community in regard to the CSG and similar gas Industries
(based on Scientific Evidence)
 The risks posed to people and our environment including water, soil and air by the
CSG Industry (based on Best Global Practice, Applied learning, Self Assessments,
Monitoring & Reporting by the CSG Industry)
Governments believe that the CSG Industry will be of NET BENEFIT to the Australian
community now and in the future. We do NOT agree. The GROSS COSTS, Collateral
damage or Consequences of the CSG and similar industries are UNACCEPTABLE.
The SCER Report argues we need the CSG Industry because it will provide the following
NET BENEFITS to Australians now and in the future. We do NOT accept this.
5

Economic – The Report argues that the CSG Industry will provide income through
royalties and contributions to GDP for current and future generations of Australians.
But it does not cover all the economic, social and environmental costs to
communities. These matters are excluded from the Report and include:
o Costs to us for road maintenance and repairs due heavy truck use;
o Costs to us for our declining health, medical and wellbeing costs
o devaluations to our assets ie. homes, farms, businesses
o devaluations of our social assets like public/crown lands, reserves, state
forests and national parks

Energy Security – The Report argues that the CSG Industry is sustainable. Bill
Heffernan’s Senate Inquiry refuted this. The Inquiry estimated that CSG Wells have
a maximum life of 15 years and that the whole CSG Industry has a maximum life of
50 years.

Environmental – The Report argues that CSG is cleaner than coal fired power
stations and so contributes less to carbon dioxide emissions and climate change. Bill
Heffernan’s Senate Inquiry refuted this. Reports by both Southern Cross and
Melbourne University also demonstrate that methane leaks by the CSG Industry are
7 to 25 times worse for Green House Gas Emissions and Climate Change than
carbon dioxide.
Governments are too complicit with the CSG/Mining Industry eg. Gina Rinehart & Alexander
Downer, deals made by the former NSW Minister for Energy Resources, Eddie Obeid with
the Mining Industry; the makeup of the supposedly Independent Expert Scientific Panel on
CSG that includes several CSG/Mining representatives, the 2012 Brisbane Conference
between Government and the CSG Industry/APPEA that excluded community participation
etc. This needs to be redressed.
There is also little Independence of Regulating bodies and Supervisors when they are
employed/paid by the CSG/Mining Companies and when investigations by Regulating
bodies are too slow, lack power and are done with the forewarning of the companies.
Even submissions to this report are able to be made confidential in whole or part. How
does this support transparency in decision making and instil confidence and trust in the
public?
The REAL PURPOSE of the SCER Report is to give more certainty and to make it easier for
the CSG Industry to operate anywhere in Australia under the same regulations. Why should
the public pay for this audit of Australia’s existing regulations, global literature review and
amendments to existing regulations in order for our Governments to facilitate an Industry
that we don’t want?
The SCER Report is CONTRADICTORY:
 On one hand it says that the Report shows that Governments are listening to
community concerns and on the other it dismisses our concerns as perceptions that
are not evidence based.
 The Report states there is a need for Governments to provide the community with
evidenced based information and key messages. It hopes that this information will
instil a sense of confidence, agreement and “mature” participation by communities
about each project. Governments are too complicit with the CSG/Mining Industry,
should not become the promotional arm of the Industry and should not allow the
Industry to produce misleading information eg:
6


about employment creation without acknowledging the many jobs that are
lost or displaced including devaluation of farms, homes and businesses and
the loss in Council rates due to property devaluations;
 about support for community services without acknowledging the conditions
for such contributions, sponsorships and donations like not being able to make
public statements about the CSG Industry or the added infrastructure costs
that the Industry creates for communities like road repairs due to heavy truck
usage for transport of water and gas, or
 about misrepresenting the CSIRO’s findings about the levels of water
contamination by the CSG Industry
On the one hand it says that the existing Regulatory mechanism is robust. And on
the other it has undertaken audits etc. and produced a report that outlines best global
practices to guide Governments and the CSG Industry.
The SCER Report hopes to create a tripartite system where all stakeholders, Governments,
the CSG Industry and the public will all AGREE to best global practices being adopted by
the Industry and work together in a “transparent” way that builds “confidence” in the CSG
Industry. The public will NOT agree to this
The Report outlines Governments’ roles:
 Educate and inform the public with key messages and facts so that we can provide a
“more mature” response ie. be the promotional arm of the Industry. The public
believes that Governments are ignoring their social and environmental protection
responsibilities;
 Regulate the Industry ie. work closely with the Industry. Like other Regulatory bodies
it will be under resourced, toothless when it comes to enforcement and behind the
8ball to start with;
 Conduct random audits of the Industries Reports
The Report outlines the public’s roles:
 Participation in decision making about individual projects
 We would rather Governments establish a formal advisory role for community groups
like EDO Vic, Doctors for the Environment Australia, National Toxics Network, Lock
the Gate Alliance etc. to participate in decision making about all aspects of the Coal,
CSG and similar Industries.
The Report outlines the CSG Industry’s roles:
 Be willing to adopt best global practices
 Do its own risk and environmental assessments
 Deal with unforseen/unpredictable problems as they arise. This is termed “applied
learning” and only reinforces the fact that there is a lot that is unknown and
unpredictable with this technology.
The majority of the SCER Report (about 60 pages) is dedicated to the BEST GLOBAL
PRACTICES for the CSG Industry. Overall our response to these is that:



The risks are too High. Many incidents around the world, in QLD and in NSW show
this to be the case.
Mitigation will not help. Prevention and Protection of social and environmental assets
is the responsibility of Governments and the Industry and is being ignored.
ALL these processes are optional for Industry. The Report does NOT make it
compulsory for the CSG Industry to adopt these best practices or as a condition of
licence.
7




Self assessments, monitoring and reporting by the CSG Industry are
INADEQUATE.
Applied learning ie. continually adapting to unexpected unforseen or unpredictable
situations that will occur in such a high risk Industry is UNACCEPTABLE.
The Industry will always be able to argue that a problem occurred because it was not
“reasonably practical” to do such and such ie. it cost too much. As such, it will not be
held accountable
Government Regulators will be under resourced, toothless, reactive and working
closely with the CSG Industry, be open to corruption.
The SCER Report is biased in its requirement for SCIENTIFIC EVIDENCE. The public has
already presented and keeps presenting evidence based on documents, media articles,
knowledge, experience, independent laboratory testing etc. that our Governments continue
to down play or ignore. These principles are only an attempt to disguise the politics and
vested interests of the CSG issue. Governments are being heavily pressured by the Mining
Industry to facilitate their short term profits and private wealth creation. We want to see our
Governments act in the public’s best interests over the long term across all it’s portfolios.
Mining should not dominate our natural resources especially water, soil and atmosphere.
Have Governments asked all Departments to prepare advice as to the impact the CSG
Industry would have on their areas of responsibility and on their budgets?
The SCER Report EXCLUDES key people’s involvement in the consultation process by its:
 shear length
 very repetitive nature
 requirement for all submissions to be on SCER’s template ie. to comment chapter by
chapter; and
 requirement for all comments to be supported by evidence – they are not interested
in our perceptions.
Many people, especially older farmers, who will be directly and indirectly affected by the
CSG Industry are too busy running the farm, their business and their families and/or do not
have/use computers. There has been little publicity by SCER about this Report and it has
only been released via the SCER website in the lead up to the Christmas holiday period.
This is Unacceptable.
Currently there is an attempt by Governments to water down our Environmental Laws in
Victoria. The EDO Vic has said:
“In Victoria offsets have been widely used in the context of the regulation of native
vegetation clearing. They are intended only to compensate for unavoidable ecological
damage and loss. The logic of compensating for ecological damage faces the fundamental
problem of equivalence between what is destroyed and the ‘gains’ represented by the
offset…Recent proposals to change native vegetation clearing rules in Victoria foreshadow
a major weakening of these laws and much expanded use of offsets.” (EDO Vic current
newsletter)
Major weakening of these laws will further undermine the supposedly sound legislative
mechanism that the Report says already exists. This will also confer more preferential
treatment for the CSG Industry – NOT balanced treatment!
We hope that governments do NOT follow the example of the NSW Government who cut
funding to its EDO in NSW. These organisations and the people who are active with the
Lock the Gate movement are TRUE monitors and regulators of the Australian Environment.
Their work should be given due consideration by all Governments in regard to the CSG
8
Industry as they inform and reflect public concerns for individuals, communities and the
environment and make recommendations to governments regarding environmental
legislation that reflect public needs. The same could be said of organizations like Doctors
for the Environment, Australia and the Toxics Network etc. These organizations should
have a formal role in any regulatory process.
Environmental Defenders Offices, Lock the Gate Alliance, Doctors for the Environment,
Australia and the National Toxics Network are expert community based organizations that
need to be included in an advisory capacity to Governments regarding all coal, CSG, shale
and tight gas Industry matters. We support them in their cautions about the GROSS
COSTS, UNACCEPTABLE RISKS & FAR REACHING CONSEQUENCES of the coal,
CSG, tight and shale gas Industries for us. These COSTS are TOO HIGH. We believe all
Governments should immediately STOP all current and proposed unconventional gas
projects like CSG, shale and tight gas.
Individuals and community groups want to debate the question of whether/not the CSG
Industry is warranted in Australia. This question goes to the heart of the question of What
sort of Energy future do we want in Australia? This question should go to referendum.
Then Australian state, territory and federal Energy Policy, Legislation & Regulation would
reflect the public’s preference for a Renewable Energy future.
We want Governments to adopt similar transition policies and programs as Germany to stop
its reliance on fossil fuels and uranium for energy production and replace them with
renewable sources. It has already achieved about 25% of the country’s energy production
from renewables. If Germany can do it why can’t Australia?
As one Reporter has said “ this is the biggest land rights issue in Australia since Mabo”. We
urge everyone to GET INVOLVED. Get together with other people in your area. Like us,
we all felt no-one else shared our concerns until we got together. Then we pooled our
resources and got active.
CONCLUSION
By its omissions, limitations, misrepresentations and regulatory approach, the Report has
tried to shape and direct community input to support Governments’ management of the
CSG Industry. We do NOT support the MLUF or the Regulatory Framework. As Bob
Wilson has reported, the Senate Inquiry criticised Governments handling of the CSG
Industry. It says that Governments’ approvals for CSG Industry developments were “given
prematurely”, and that ‘the pace of the CSG Industry’s development is too far ahead of
scientific investigation into its lasting impacts’. It also says that ‘attempts by Governments
to regulate the CSG Industry are not keeping pace with the Industry’s development’. In fact
the CSG Industry continues to operate without a full and comprehensive understanding of
its impacts while the Moratorium is in place for only NEW licenses.
The CSG Industry is inherently UNable to be socially or environmentally safe. It represents
UNacceptable social and environmental. The only way to adequately address this matter is
to BAN the CSG Industry in Australia.
We believe that it is now up to our Governments to reject and ban the CSG (and other
unconventional gas) Industries as well as New Coal Mining. At the very minimum,
Governments should ban all fracking due to its UNacceptable high social and environmental
risks/costs and stop all means of legal privileged treatment of the CSG/Mining Industry over
individuals and the public (as per the EDOV’s recommended legislative changes).
9
The SCER and Governments now have an opportunity to make the difficult but necessary
decision to abandon the CSG Industry in Australia. Governments have previously made
similar decisions about other out dated industries like Petroleum (to remove lead),
Refrigeration and Air Conditioners (to remove CFCs), Asbestos (to stop its use), Tobacco
(to stop promotion of smoking and harmful additives).
We are still suffering the social, environmental and economic consequences of having
endured the development and growth of these harmful Industries/Industrial processes. Let’s
act now to avoid making the same mistake with the CSG (including shale and tight gas) and
New Coal Mining Industries. We do not want or need another story of toxic contamination
for generations to come.
This is also an opportunity for Governments to institute widespread Energy Conservation
and to transition to Renewable Sources of Energy Supply. Germany, with its large
manufacturing economy, has already done this – so, why can’t we?
We would very much like to see some goodwill on the part of our Governments regarding
this consultation process. We are hopeful that the public submissions of individuals and
groups to the MLUF and SCER Framework Report will NOT be ignored for financial or any
other reasons, as has happened with other community consultation processes like the
Greenfield Report. We do not want any more empty reassurances from
Governments. We look forward to the SCER’s and Governments response.
OTHER QUESTIONS THAT WE ARE CURRENTLY INVESTIGATING
The Industry keeps saying that CSG etc. is NOT Mining. Is this a tactic to exclude these
Industries from paying the new Mining Tax?
Can our current civil rights to prevent Trespass on our land be planned out of existence
under the MLUF?
Are there current Section 32 responsibilities in Victoria (and in other State’s Regulations) to
declare that your property is under a Coal and/or CSG Exploration Licence when attempting
to sell?
See the end of our Submission for WEBLINKS to some of our reputable sources of
information and advice
10
Draft National Harmonised Regulatory Framework
Part 1 – Preface
GOVERNMENTS ARE NOT LISTENING TO THE PUBLIC OR ACTING IN OUR BEST
INTERESTS
“The Framework is an important demonstration that governments are listening and
responding to community concerns and are working together to strengthen regulation and
ensure there is a balance between protecting social and environmental values and
achieving economic outcomes.”
This is a misleading comment. TV news & current affairs programs, radio and news paper
articles along with social media (which include interviews with prominent government and
CSG industry representatives) all show that the government is not listening and acting in the
best interest of all stakeholders. Denial is their main weapon of choice. Furthermore if
Governments were really listening then some action would have been taken when problems
first started to appear – See the weblinks at the end of this submission about accidents in
the CSG Industry in Australia.
THE REPORT ONLY COVERS CSG AND DOES NOT COVER OTHER
UNCONVENTIONAL GAS LIKE SHALE & TIGHT
Well integrity, water management and monitoring, Hydraulic fracturing, chemical use,
environmental stability, multiple land use requirements, social and local economic issues
etc. are similar for all types of drilling. Why limit the Framework to just CSG? ALL forms of
unconventional gas should be included due to the similar problems they pose for
communities and the environment and also because - “Unconventional forms include shale
oil, shale gas, and tight gas and typically require the controversial hydraulic fracturing
technique known as ''fracking''. Read more: http://www.smh.com.au/business/rinehartbuys-strategic-stake-in-minnow-lakes-oil-20130129-2dito.html#ixzz2KB7kKCwt also see
Doctors for the Environment, Australia
Our comments apply equally to Governments complicity and lack of control of the New
Black & Brown Coal Mining Industry too. Where is Governments comprehensive policy and
co-ordinated plan across all portfolios and departments for avoiding Climate Change. We
want to see decision making about whether or not we have any CSG & New Coal Mining
Industries at all based on criteria of whether or not it contributes to Greenhouse gases,
reduces our reliance on fossil fuels and helps to avoid climate change. Where is
Governments and Industry leadership on this?
THE REPORT ONLY COVERS PROPOSED PROJECTS – WHAT ABOUT EXISTING
PROJECTS?
ALL CSG and other unconventional gas projects should be stopped or at the very least
excluded from areas based on their environmental, social, economic, cultural and heritage
asset values. This includes our water basins/catchments, state forests (Leard etc.),
National Parks, farming/agricultural lands, populated areas, aboriginal lands etc.
THE REPORT ACKNOWLEDGES THAT COMMUNITY FACTS, INFORMATION,
CONCERNS & POINTS OF CONTENTION ARE VALID
The Report acknowledges the constructive participation that the public is having in this
debate. The Lock the Gate Alliance has been extremely successful in providing an avenue
for people to share their ACTUAL experiences of the CSG Industry, share information
including cover-ups and misrepresentations by the CSG Industry, our politicians and the
media, develop strategies to resist the CSG Industry etc.. The Senate Inquiry headed by
Bill Heffernan was also outspoken on the rights and expectations of the public that
11
Governments and the CSG Industry has been trampling on.
GOVERNMENTS ARE NOT LISTENING & ACTING RESPONSIBLY ON THE PUBLIC’S
BEHALF
“Community concerns over the development of the CSG industry relate to its potential
environmental, health and social impacts. For instance, the volume of water produced
as a by-product of CSG extraction has raised concerns that the industry may damage
or unsustainably deplete aquifers on which farmers, rural towns, and ecological
communities depend. The failure of wells and the impact this could pose with respect to
the contamination of potable aquifers is also pertinent. Hydraulic fracturing has been a
topic of public concern, specifically with respect to the use of chemicals and the
risk of contamination to the environment. In addition, the treatment and management of
waste water streams and salinity issues have raised questions over possible implications
for human and animal health and food production. Another point of contention is industry
access to CSG resources on privately held land, particularly that used by the agricultural
sector. This has raised issues regarding the rights of individual land owners to limit
access, rights of resource ownership, and the magnitude of compensation afforded to
landowners for their costs, reduced amenity, and any reduction in agricultural
production.”
Have a good look at what is going on with environmental, heath and social issues. These
are not only POTENTIAL but FACTUAL impacts. Denial does not make the problem go
away. “Calculated and perceived risks” are either written down on paper or in people’s
minds. What about the actual risks and damage caused by the CSG Industry? Again
denial does not make the problems go away, they will just pile up and get much worse.
Health, social and environmental impacts should be at the top of this Report’s priorities.
SALINITY ISSUES ie. CONTAMINATED SALT PROBLEM IS NOT DEALT WITH AS
PART OF WATER ISSUES
The Report IGNORES the issue of the huge quantities of highly contaminated salt produced
and stored by the CSG Industry in settling/holding ponds and in heaps that are kilometers
long and metres high, that cannot be decontaminated, used or disposed of safely. What, if
anything can be done about this problem?
This is a particular issue in flooded areas eg. QLD currently where, these settling/holding
ponds and these huge storage piles of highly contaminated salt have mixed several times in
recent years with flood waters, entered our soils, streams and marine environments. See
the Lock the Gate Alliance website.
We expect this to be treated as part of the Report’s discussion of water contamination. The
National Toxics Network has identified many harmful toxins in both the contaminated water
that the CSG Industry produces and their stores of salt. Why has this matter not been
discussed in this Report?
THE REPORT PROMOTES CONTINUED PREFERENTIAL TREATMENT FOR THE
MINING INDUSTRY BY GOVERNMENTS
All governments continue to give the Mining Industry preferential treatment. Governments
are not demonstrating the same level of consideration for social and environmental assets.
These are always sacrificed in the interests of Mining and Money under the guise of
BALANCE eg. “… ensure there is a balance between protecting social and environmental
values and achieving economic outcomes…..”
12
While there is legislation for objection to Black & Brown Coal Mining, there is NO
mechanism in place for individuals and communities to legally object to CSG exploration or
production on their own land. The Environmental Defender’s Office, Victoria has
recommended that the government create this legislation. We support the EDO Vic
recommendations..
THE REPORT DISREGARDS PUBLIC & PRIVATE LANDHOLDERS RIGHTS
Farmers and other landholders across Australia want to have a legal means of
EXCLUDING CSG Mining on their properties and on public lands. They do NOT want to
“LIMIT ACCESS” to their properties and public lands . This is a serious misrepresentation
of landholders’ concerns. If any goodwill and trust of governments and the CSG Industry is
to be established, Governments and the Industry must first listen and not misconstrue the
public’s concerns.
Also, the restrictive means by which people are able to make their submissions to the
SCER, is further evidence that many people have been excluded from this process
especially a lot of older farmers who do not use computers – a key group effected by this
proposed Framework. What will SCER do to ensure individual farmer’s rights are
considered as part of the submissions/consultation? And, to ensure adequate mechanisms
by which all private and public landholders can say NO and object to CSG mining on their
land as per the EDO Vic’s recommendations.
THE REPORT EXPOSES THE REAL INTENTION OF THE REGULATORY FRAMEWORK
Elsewhere the report credits the CSG Industry as being the most informed to make their
own exploration and mining decisions and here it is necessary to “GUIDE…industry on what
leading practice regulation is…..to create certainty and consistency for the CSG Industry”
The real intention of this Regulatory Framework is “providing greater certainty and
consistency for CSG operators”. This means that CSG companies will be able to operate
ANYWHERE within Australia in the knowledge that Governments have spent a lot of time
and public money to bring all relevant legislation and regulation in line to facilitate the ease
of their businesses.
THE REPORT DOES NOT GIVE ADEQUATE CONSIDERATION TO WHETHER OR NOT
WE SHOULD HAVE A CSG INDUSTRY THAT IS RAMPANT IN ITS DEVELOPMENT &
DESTRUCTIVE FOR VERY LITTLE RETURN TO THE AUSTRALIAN PUBLIC
“(In 5yrs) CSG production (IN QLD) increased from 2 per cent to 11 per cent of Australia’s
total gas production”
Anna & Russell Hall, members of Friends of Gippsland Mirboo North – Lock the Gate
against Coal Mining & CSG, have made the following calculations to help us understand
these quantities as follows:
LPG contains about the same energy per kilo as natural gas ie. CSG/methane
Propane contains 50MJ/kg
Methane contains 55/MJ/kg
Therefore, 100L or 45 kg LPG cylinder is equivalent to about 2,250 MJ of energy
Energy of 1PJ = 1,000TJ or 1,000,000GJ or 1,000,000,000MJ
Therefore, 1PJ = 1,000,000,000MJ
Therefore 1,000,000,000MJ divided by 2,250MJ is equivalent to the energy of 440,000 LPG
Gas Cylinders
2006-2007 total CSG production was 99PJ (ie. approximately 44,000,000 LPG Gas
Cylinders)
2010-2011 total CSG production was 239PJ (ie. approximately 106,000,000 LPG Gas
13
Cylinders)
This is very little return for the high risks and negative impacts experienced by the
environment and by communities. 5 major offshore oil and gas fields each with 20-30 oil
rigs produce nearly 90% of Australia’s LPG (Dept of Energy Offshore Petroleum Information
Sheet). Thousands of CSG wells are spread over an increasing area of NSW & QLD.
These CSG wells currently produce just 11% of Australia’s total gas production. The large
areas disrupted and destroyed by CSG developments do NOT warrant or justify the
continued development of the CSG Industry.
THE REPORT IGNORES THE SUBSTANTIAL PRIVATE WEALTH THAT IS GAINED
FROM PUBLIC RESOURCES AT UNACCEPTABLE COST TO THE AUSTRALIAN
PUBLCI
We would like to see the breakdown in both $ and percentage terms of:
Government/Public costs associated with:
Contracts
Meetings eg. COAG
Reports eg. SCER
Legislative and regulatory changes
Regulation of the CSG Industry
Infrastructure eg. roads,
Marketing of the CSG Industry ie. “Government key messages” to the public
Environmental assessments, degradation and restoration works
Community health assessments
Devaluations of private properties and associated decreases in Council rates eg. South
Gippsland Council has estimated a substantial decline in its rate revenue should
Governments allow the CSG Industry to operate in the region
Devaluation and degradation of farms and associated agricultural businesses and services
Employment losses and displacements - The REAL negative impact on existing jobs and
businesses should be counted and valued.
Government/Public income from royalties
Company expenses for CSG including:
Energy used in all facets of its activities,
Embedded energy in the products it uses etc
Company income from CSG
Private wealth gained by people like Gina Rinehart, Alexander Downer, Ian Plimer etc. see
Rinehart Tap for Downer, Business Day p3, The Saturday age 2/2/13
MULTIPLE LAND USE FRAMEWORK (MLUF) ie. THE PRINCIPLE OF COEXISTENCE
IS A MYTH & MISNOMER
The principle of co-existence is FALSE. It has already been well documented that the
principle of co-existence is not workable. See the Lock the Gate Alliance website and those
of associated groups and the weblinks at the end of our submission. They demonstrate the
negative impacts on various communities’ environment, water, social wellbeing, health etc.
that cannot be compensated for and that cannot be restored. Co-existence implies some
sort of compatibility. Clearly, many Australians KNOW that the CSG Industry is
INCOMPATIBLE and therefore cannot coexist with many other existing land uses including
environmental (national parks, wilderness areas, state forests, reserves etc.), farming and
14
agribusiness, residential, tourism, lifestyle and amenity etc.
The community has shown it’s support for areas to be EXCLUDED from CSG development
on the basis of agricultural, cultural, heritage, environmental, social etc. value. Individuals
and communities should have the right to make these decisions. In fact, individuals and
communities ARE continually making these decisions via the Lock the Gate MOVEMENT
and will do so via their up and coming election votes.
The public is being asked to comment on this Framework when the major “overarching”
document – the MLUF – has NOT been released. The Multiple Land Use Framework
Research Study, referred to in this framework, does not mention CSG at all. This is not
being transparent and does not engender trust – both qualities that the SCER Report asks
for from both the CSG Industry and the public. As such we do NOT support this framework
document. The Multiple Land Use Framework does not mention CSG, coal, seam or gas
anywhere in the three page document.
The National Harmonised Regulatory Framework for CSG does nothing to regulate this out
of control industry. The framework pushes for co-existence meaning that the current land
uses like agriculture, urban areas, public parkland and forests along with public health and
the environment must make way for the greed of governments and industry.
SCOPE OF REGULATORY FRAMEWORK IS INADEQUATE & MISREPRESENTATIVE
“The National Harmonised Regulatory Framework for CSG responds to community
concerns about the potential environmental, health and social impacts of CSG
development. It provides guidance on what constitutes leading practice in the core areas
of well integrity, water management and monitoring, hydraulic fracturing and chemical use.
Applied in conjunction with existing regulatory mechanisms, the Framework provides a
consistent approach to managing CSG development from a regulatory perspective. While
its primary purpose is to be a guidance document for governments, the Framework will
benefit the community and industry by providing increased levels of consistency, certainty
and transparency in the management of CSG development in Australia.”
The report excludes many other matters raised by individuals and communities including:
Health impacts on individuals and communities
Environmental degradation
Heritage & Cultural degradation
Devaluations of private properties and associated decreases in Council rates eg. South
Gippsland Council
Severe decrease in property sales once Governments ALLOW/ENABLE the CSG Industry
into a community/area
Devaluation and degradation of farms and associated agricultural businesses and services
Employment losses and displacements - The REAL negative impact on existing jobs and
businesses should be counted and valued. People lose their livelihoods ie. jobs and
income as a result of the Governments allowing the CSG Industry to operate.
When and How will Governments acknowledge and consider these matters? Impacts are
occurring right now, especially on people’s health and water. However, Governments and
the CSG Industry have denied the need for prompt and thorough investigations and actions
to be carried out to understand and prevent these occurring now and in the future? eg.
NSW Community and Health sector calls for an investigation into the health impacts of the
CSG Industry
THE REPORT MINIMISES PUBLIC CONCERNS
15
This report tries to reduce the magnitude and simplify the problems raised by the public
when it reshapes them as technical/technological matters for the CSG Industry to deal with.
The Industry is to come up with solutions that may/not work on the job as they arise. This
does not RESPECT public concern and cannot be a basis for engendering trust and the
tripartite co-operation between Governments, the public and the CSG Industry that the
report pretends to be the basis of.
The report also tries to reduce the validity, depth and magnitude of public concern by
casting them as “perspectives”. The whole instigation of this process/report has been
validated by the legitimate concerns raised by the public (especially via the Senate Inquiry
headed by Bill Heffernan). These concerns have NOT been raised by Governments or by
the Industry. Governments are only seeking to minimize and remove public concerns. This
Report says that Governments will need to provide “key messages” in the hope of gaining
“more mature public participation”. This amounts to Governments promoting the CSG
Industry and is NOT acceptable.
WELL INFRASTRUCTURE AND ITS DECOMMISSIONING ARE
MISREPRESENTATIONS
Each well only has a maximum life of about 15 years ie. VERY SHORT as stated by the
Senate Inquiry. The report never asks the question is all this disruption, degradation,
displacement etc. worth it? The problems associated with well and pipeline security and
safety are never ending Methane leaks, blowouts, fire hazards, induced seismic activity etc.
CONTINUE long AFTER the wells are no LONGER in production. In this report
Decommissioning means mainly filling the wells with concrete – NOT removing them. The
public and Geologists know that the ground is continually shifting – How can any well leak
be secured with concrete – especially in areas prone to flooding, cyclone, bushfire and/or
earthquake?
Wells are ABANDONED ie. Any monitoring and necessary maintenance STOPS! All the
infrastructure of the CSG Industry REMAINS. There is NO CLEAN UP, NO REPARATION
WORKS as with quarries. All the wells, pipelines, site equipment etc. REMAINS above and
below the ground FOREVER.
The Report’s justification of this is the fact that this is how all previous drill/production sites
have been left all over Australia. This is UNACCEPTABLE and cannot be justified on the
basis that there are many “abandoned” wells all over Australia already. There are 100s and
1,000s of wells associated with EACH CSG Industry project – NOT just the comparatively
few already abandoned ones. We do NOT want to INDUSTRIALISE the Australian
landscape. See GasLand for the USA’s experience and images of the QLD experience.
CO-PRODUCED WATERS IS A MISREPRESENTATION
See our comments above about Salt. Governments and the CSG Industry persist to not
talk about this CONTAMINATED SALT problem or acknowledge that this is one of the
INSURMOUNTABLE problems that will be with us now and into the future.
The CSG Industry does NOT PRODUCE any water. It USES the most water of any
industry for its drilling and extraction/production. This includes vast amounts of water that is
brought in by the 100s of truckloads for EACH well that is drilled. It also includes the vast
amounts of water that are RELEASED AND DRAWN TO THE SURFACE from aquifers ie.
FLOW BACK or FRACK WATER. In addition these VAST amounts of water are
CONTAMINATED.
WHOLE OF LIFE CONSIDERATIONS OF WATER ARE MISREPRESENTATIONS
Governments will ENABLE the CSG Industry to LEGALLY USE for FREE, TREAT,
16
SUPPLY & DISPOSE OF the vast amounts of water it CONTAMINATES during its
Exploratory drilling and Production stages. It uses Whole of Life considerations for the CSG
Industry’s water usage and contamination as if we are talking about recycling our rubbish.
This is MISREPRESENTING THE FACTS. There is a big difference between turning
rubbish into other products with recycling and allowing the CSG Industry to contaminate our
water, decontaminate/treat it and then sell it back to us or receive credit for putting some of
it back into the ground/aquifers to create another income stream for the CSG Industry. This
shows that Governments and the CSG Industry do NOT understand that our water (quantity
and quality) are major issues for the Australian public. We should be widely informed of this
proposal and asked for our decision via a Referendum. There would be a resounding NO!
SCER’s REPORT METHODOLOGY
In the interest of transparency can a list of these groups and the stated documents a, b & c
be made available in full. The References and further reading section does not have a
reference to these documents.
For a truly balanced view, serious recognition and consideration would also need to be
given to the recommendations for legislative reform already proposed to Governments by
community organizations like the Environmental Defender’s Office Victoria (EDOV), Doctors
for the Environment, Australia and the National Toxics Network and via the Lock the Gate
Alliance. See their websites for the results of the public’s/community’s constant risk
assessments, monitoring, evaluation and exposes of the CSG Industry and their
recommendations to Governments.
If due consideration was given to the recommendations of these and similar organizations,
this could be a way of formalizing the public’s role in the Regulatory process. It could
ensure a formal way for the public to participate in all Government decision making about
the CSG and other unconventional gas Industries. This would need to include decisions
about every stage including whether/not to proceed with the Industry/projects, assessments,
monitoring and evaluation. This would also need to apply retrospectively to the existing
Industry/projects.
Part 2 – Executive Summary
17
THE SCER REPORT TRIES TO MINIMISE THE ACTUAL LEVEL OF COMMUNITY
CONCERN THAT EXISTS
When the Report says that the CSG Industry has…”at times, outraged local communities.” It
tries to minimise the actual level of community concern that exists. We don’t have a simple
“not in my backyard” concern. We in South Gippsland, care about what is happening to
communities and the environment in the Hunter Valley, NNSW, Western Sydney, and The
Liverpool Plains etc., throughout Queensland, other states and around the world.
This makes it sound like the community is only affected in isolated incidents. This is not the
case. We only need to listen to the news to see the increasing media time that the
environmental and health issues that come with the CSG industry are getting as well as the
continually growing groundswell and diversity of people becoming involved in the Lock the
Gate movement.
GOVERNMENTS’ REGULATION HAS PROVEN TO BE INADEQUATE
“…Governments should aim to provide a policy and regulatory setting that encourages
the growth of the industry, within a regime of relevant, enforced conditions and
legislation to protect the environment and human health and facilitate social
development and sustainability.”
Regulations, like the Victorian Mineral Resources Development Act, already exist. The
enforcement of these acts also lacks transparency and integrity. How will this be
redressed?
As can be seen by drug taking in the sporting industry and by events (A Downer, G
Rinehart, T Obeid) in the CSG/Mining Industry, boundaries are regularly pushed and often
exceeded, leading to denial, minimising concerns and high-level corruption. The CSG
industry will continue to be directed by their bottom line. The environment, human and
animal heath etc. do not matter to them. They will continue to do as little as possible to
prevent problems occurring. They will then continue to deny and misrepresent any issues
arising from problems associated with their industry as Esso has been doing for about 15
years in relation to an accident that occurred at it’s Longford plant in the late 1990s.
Government are lax in mandating and enforcing correct and responsible action by the
CSG/Mining Industry. They have their eye on their perceived economic net benefit to the
detriment of our social and environmental protections.
CSG FOR EXPORT IS UNECONOMIC
The economics of export have not been adequately addressed either on a financial, energy
or environmental basis -especially as to how export/global market prices contribute to ever
decreasing prices for our energy resources and to ever increasing energy costs for
Australian consumers. How can this be justified especially in the context of Australia
working to reduce carbon emissions in an effort to avoid climate change?
THE CSG INDUSTRY DOES NOT & WILL NOT PROVIDE NET BENEFIT TO
AUSTRALIA
Governments believe that the CSG Industry will be of NET BENEFIT to the Australian
community now and in the future. We do NOT agree. The GROSS COSTS, Collateral
damage or Consequences of the CSG and similar industries are UNACCEPTABLE.
The SCER Report argues we need the CSG Industry because it will provide the following
NET BENEFITS to Australians now and in the future. We do NOT accept this.

THE CSG INDUSTRY IS NOT OF NET BENEFIT TO AUSTRALIA





18
Economic – The Report argues that the CSG Industry will provide income through
royalties and contributions to GDP for current and future generations of Australians.
But it does not cover all the economic, social and environmental costs to
communities. These matters are excluded from the Report and include:
o Costs to us for road maintenance and repairs due heavy truck use;
o Costs to us for our declining health, medical and wellbeing costs
o Devaluations to our assets ie. homes, farms, businesses
o Devaluations of our social assets like public/crown lands, reserves, state
forests and national parks; and
o Contamination of our natural resources (ie. our water, soil and atmosphere)
THE CSG INDUSTRY IS NOT NEEDED TO SECURE AUSTRALIA’S ENERGY
FUTURE
Energy Security – The Report argues that the CSG Industry is sustainable. Bill
Heffernan’s Senate Inquiry refuted this. The Inquiry estimated that CSG Wells have
a maximum life of 15 years and that the whole CSG Industry has a maximum life of
50 years.
CSG IS NOT A CLEANER SOURCE OF ENERGY THAN COAL
Environmental – The Report argues that CSG is cleaner than coal fired power
stations and so contributes less to carbon emissions and climate change. Bill
Heffernan’s Senate Inquiry refuted this. Reports by both Southern Cross and
Melbourne University also demonstrate that methane leaks by the CSG Industry are
7 to 25 times worse for Green House Gas Emissions and Climate Change than
carbon dioxide.
SUSTAINABLE DEVELOPMENT OF THE CSG INDUSTRY IS A MISREPRESENTATION
“The social dimension to achieving sustainability in CSG development requires
consideration of how to ensure that future generations have the same or greater access to
social and environmental resources as the current generation. The CSG industry can
contribute to social sustainability through the development of jobs in local communities,
arrested long-term population and service decline, and improved infrastructure. Unless the
community is engaged and supportive of a CSG operation, the project will not be
sustainable. Open and honest dialogue and constructive negotiation are critical to
developing productive relationships between participants.”
The CSG Industry is UNSUSTAINABLE. It is SHORT TERM (well life is only about 15
years and the CSG Industry is expected to operate only for about 50 years – see Senate
Inquiry headed by Bill Heffernan). It is EXPLOITATIVE – the vast amount of social and
environmental degradation caused by the CSG Industry far outweighs the public financial
benefits. A select few people grow their wealth from this Industry.
Australia’s only source of SUSTAINABLE ENERGY (and associated technological
industries) is RENEWABLES. We accept that the country needs to PLAN its transition from
fossil fuels. However, we do not accept that the CSG or any other unconventional gas
Industry is a necessary part of this transition.
There is evidence that even with declining government assistance (ie. research, seeding
money, grants, tax cuts, subsidies, rebates etc.) to the Renewables sector, the public and
business is increasing its uptake of Renewable Technologies, Passive design, improved
Energy Conservation, Efficiencies and associated technologies eg. smart grids. In
combination and actively supported by Governments through policy, subsidies, rebates,
research grants, seeding funding etc., these efforts can put Australia on track to a truly
sustainable future. See Germany and Scotland’s current policies and programs to actively
19
decommission their Uranium Industries and Fossil Fuel Industries and to replace them with
Renewable Energy. If these countries can do it, Why can’t we?
BALANCED CONSIDERATION & DECISION MAKING IS A MISREPRESENTATION
The Report does not give enough credence to the extremely high level of risks posed by the
CSG Industry. It just accepts that there are risks (some that we know of now, some that we
will discover as CSG exploration and production proceed and some that we will discover in
the future). The Report accepts that these risks can and should be managed by the CSG
Industry.
We strongly disagree with this approach. Some risks like contamination of our water
systems (aquifers, bores, spring fed dams, land, rivers and drainage basins) are
UNACCEPTABLE to the Australian public. It is the role of Governments to PROTECT our
water systems so as to PREVENT such contamination – NOT LEGALISE THEIR
CONTAMINATION!
The SCER Report starts from the premise that the development and continued growth of
the CSG Industry is desirable and a given. The Public does NOT agree and wants to have
this debate.
Elsewhere the Report notes the CSG Industry’s role to maximise profits and minimise costs
while trying to be as socially and environmentally responsible as reasonably practical. This
means that profits will dominate all decision making at the expense of social and
environmental considerations – ie. there is NO balance.
Regarding his recent decision to open Tasmania’s World Heritage Tarkine Wilderness to
mining, Tony Burke, Minister FOR the ENVIRONMENT, recently said to media that “I simply
haven't been able to find a way to recognise the natural heritage values with a boundary
that will find a balance.” There is no possibility of BALANCE. When it comes to mining,
Governments are willing to ignore their public responsibilities to protect communities and
the environment and to mismanage our resources. This Report seriously misuses the
concept of “Adaptive Management”.
SOCIAL & ENVIRONMENTAL ASSETS ARE NOT CONSIDERED
The argument for overwhelming ie. greatest net economic benefit of the CSG Industry to the
Australian community is a false one. Not ALL costs are included eg. degradation of the
environment, decline in social wellbeing and health of communities, infrastructure etc.
Government investment in the CSG Industry as subsidies, tax concessions, infrastructure
builds ie. roads, ports etc. outweigh the benefits to Australia of the royalties gained for our
natural resources. Where are the costings and the balance sheets? – Net Benefits versus
GROSS COSTS!
GOVERNMENTS ARE NOT THE PROMOTIONAL ARMS OF THE CSG INDUSTRY
No public money should be spent by Governments undertaking promotion of the CSG
Industry under the guise of Public Education & Information programs. This Report mentions
“a balanced message….key messages and Information about the challenges associated
with CSG development.” Maintaining Government independence while working closely with
the CSG Industry will be difficult. Although the Report says this process will build public
confidence in the CSG Industry, we believe it will have the opposite effect as the CSG
Industry tv advertisements and signboards are already having.
THE ROLES OF GOVERNMENTS
Our Governments have many responsibilities alongside economic ones – especially social
20
and environmental protections. This Report outlines the dismantling and mismanagement
of these other responsibilities under the guise that the Harmonised Regulatory Framework
“…seeks to deliver a balance of social, environmental and economic outcomes for
Australia.”
CONSISTENCY, CERTAINTY & MANAGEMENT OF THE CSG INDUSTRY
The Report says “…the Framework will …provid(e) increased levels of consistency,
certainty and transparency in the management of CSG development in Australia.” We do
not believe this. The Report lists and discusses the global best practices that the CSG
Industry SHOULD be applying NOW and aren’t. The CSG industry has been in production
in Queensland since 1996, has approximately 10,000 wells and is proposing another
30,000. One would think that with these and the multitude of wells being drilled
internationally, that world best practice should be second nature. The need for guidelines
shows that the industry does not care about anything but their own bottom line..
“Successful implementation of the Framework will also depend on the willingness of
industry to further embrace social and environmental responsibility and adopt leading
practice, and the community’s readiness and openness to engage with governments and
industry.” The Report only HOPES that the CSG Industry will take up/adopt these best
global practices: “Successful implementation of the Framework will also depend on the
willingness of industry to further embrace social and environmental responsibility and adopt
leading practice…” These practices are not CONDITIONS of Exploration and Production
Licences. The Government is not COMPELLING the Industry to meet these standards.
Whenever it is “not practical” ie. it costs the companies too much to implement, these things
will NOT be done. The Government Regulators will be behind the 8 ball forever playing
catchup, trying to identify gaps in paperwork NOT on the ground problems, establish
accountability/liability and building cases against the Industry. They will be under resourced
and toothless like other Government Regulatory Bodies. Until Governments and the
Industry take public concerns and wishes seriously this will not change.
This framework is meaningless if it depends on the industry to embrace social and
environmental responsibility the industry is only concerned with extracting the gas from the
ground in the cheapest possible way regardless of the consequences to others and the
environment. The community has been open and is engaging with both governments and
the industry but neither governments nor the industry are prepared to listen.
This framework does nothing to instil confidence that the industry or governments have the
best interests of communities and environments in mind.
PURPOSE & EFFECT/OUTCOME OF LEADING PRACTICE
“The application of the leading practices identified in this Framework will instill a shared
commitment among governments to apply a consistent and leading approach to the
management of CSG in each jurisdiction.” Why should Governments be facilitating the
development of this Industry – especially given the widespread opposition?
INCREASED TRANSPARENCY IS A FALSEHOOD
“…with better informed public discourse through increased transparency and consistency in
decision-making on CSG development...Leading practices should include effective planning
mechanisms where governments, with industry, recognise the community’s expectations,
participation by communities, and proactive engagement and education informed by facts
and conducted in good faith.”
The community is already well informed and experienced with the CSG Industry and has
made its expectations clear. Hence the need for this Report. There is already “informed
21
public discourse occurring”. We know the FACTS, are proactively engaged in this debate,
are educated and informed by facts and are motivated by good faith to protect communities,
farms, businesses, our water and our environment. We do NOT need to be “better”
informed in the sense of persuaded (as meant by the Report). The Lock the Gate
Movement is adept at sharing information and experiences, identifying and investigating
problems, exposing Governments and the CSG Industry and participating legally and
politically.
What is lacking is the integrity and “good faith” of Governments and the CSG Industry.
Governments and the Industry still will NOT accept social, health and environmental
problems that they have already allowed to occur in Queens land and NSW. Further, they
do NOT accept responsibility, refuse to investigate and take the necessary steps to stop the
rampant development of this Industry. Even this Report gives submissions the right to be
partly or wholly “confidential”. What is transparent about that?
The planning mechanisms referred to may be the MLUF, which has not yet been released
to the public and is the overarching document to this Report. What is transparent about
that? We suspect that Governments and the CSG Industry are working to put their
“effective planning mechanisms” in place to enable “co-existing land uses” (other than the
ones we already have – ie. to enable mining and agriculture, horticulture, viticulture,
organics etc. to occur on the same land for now and for successive land use planning into
the future. This may remove or weaken our rights to preventing trespass on our land via the
Lock the Gate signs. We strongly oppose any sort of move in this direction and would like
to know what are people’s legal responsibilities when selling their property to declare that
their land is currently under CSG/Coal Mining Exploration License etc. eg. via Section 32s
in Victoria.
The Report only considers project-by-project community participation. On one hand it
consider that all of Australia is the community that gains a net benefit from any CSG project.
On the other it is happy to divide the Australian community by developing a process
whereby individual communities can participate with Government and CSG Industry
representatives of individual CSG projects to participate in decision making about each of
those projects. Clearly there are issues arising from individual CSG projects that impact on
other communities via their above and below ground water systems/catchments,
environmental impacts etc. Just because we don’t live in/near a certain State Forest or
National Park or Location does NOT mean we don’t care and shouldn’t be part of the
decision making process. This is clearly a divide and conquer strategy and so is NOT
acceptable.
GOVERNMENTS & THE CSG INDUSTRY HAVE LET DOWN THE PUBLIC
“Successful implementation of the Framework will also depend on…the community’s
readiness and openness to engage with governments and industry.” Communities do NOT
trust Governments and the CSG Industry to act in our best interests. This is why we have
resorted to our own community engagement process via the Lock the Gate Alliance.
“…..the regulation of CSG activities promotes openness, transparency and trust within the
community….” No it does NOT!
GOVERNMENTS ARE NOT PART OF THE CSG INDUSTRY
“… the Framework identifies the continuous need for governments to work closely with
industry, through consistent compliance by industry and effective enforcement by
regulators; effective inter-governmental cooperation to ensure national consistency; and
22
proactive international partnerships to learn from international leading practices.”
Governments are already too complicity with the CSG/Mining Industry. When & How will
they stand up to these companies in the best interests of the public?
THE REPORT MISREPRESENTS ADAPTIVE MANAGEMENT
“The Framework forms the foundation for continued improvement in operational leading
practice, built on improved science and data. It also increases public understanding of CSG
issues, the role of governments, industry and communities, and the science and economics
which underpin the development of the sector.”
The public already understands very well the CSG Industry and the science and the
economics that underpin it. We simply disagree with the views and decisions of
Governments and the Industry. No amount of public education programs ie. promotion of
the CSG Industry on the part of Governments or the Industry will improve the situation. It
will only be a cynical exercise aimed at divisiveness.
By continued improvement, the Report means applied learning ie. Whenever negative
impacts and unforseen/unexpected incidents occur in the field during CSG operations, the
Industry will TRY to deal with it as best they can. This is acknowledgement that the Industry
does NOT know enough about the techniques and methods it needs to employ in order to
prevent these impacts. Again, the risks are too high and should not be allowed by
Governments. Government and Industry lack of knowledge and techniques is most
apparent in Chapter 5 Hydraulic Fracturing and Chapter 6 Chemical Use. These Chapters
are full of comments about the lack of information, data, science etc. available about the
chemicals used, the effects of the combinations and quantities of chemicals used, the
underground chemicals that are released by the CSG Industry, the effects of these
chemicals singularly and in combination etc. However, the Report does NOT recommend
any investigation of these matters as a means of dealing with the Unacceptable risks posed
by the CSG Industry. Many groups have called for these investigations to occur while the
MORATORIUM continues, including Doctors for the Environment, Australia, and the
National Toxics Network, Lock the Gate groups, Government and Non-government health
organizations and departments etc. This MUST happen as a matter of priority.
THE 18 LEADING/BEST GLOBAL PRACTICES
“A total of 18 leading practices have been identified to mitigate the potential impacts
associated with CSG development…”. The public knows that the CSG and other
unconventional gas Industries represent an UNACCEPTABLE risk to our health, water, soil
and air/atmosphere which, once contaminated, become unusable. The Report
acknowledges that the Industry can only MITIGATE these risks. There is overwhelming
evidence from Queensland and NSW that farmlands and public lands have been
CONTAMINATED and that Governments and Industry still do not want to recognise and
understand their implications eg. Brian Monk who has no CSG development on his acreage
but whose land and water has become unusable by his family and his animals.
The CSG Industry within Australia and overseas already lacks public support and has an
extremely poor public reputation. This is due to the many instances of contamination and
wide variety of social problems associated with the Industry as well as the many
documented instances that show the CSG/Mining Industry does NOT honour its
commitments. Why then are we looking at these operations for best global practice? This
makes a mockery of the phrase and erodes public confidence further.
Also see the table below for our comments.
23
CURRENT LEGISLATION IS NOT ADEQUATE
“Current legislative arrangements of the Commonwealth and state and territory
governments provide a sound mechanism for managing CSG exploration and development
activities. Common elements for these regulatory systems include legislation for the
protection of human health, conservation of the environment, protection of property rights
and multiple land use. This Framework identifies leading practices that can be adopted by
regulators to provide a harmonised approach to managing CSG activities and hence a
nationally consistent CSG regulatory regime.”
This statement is contradictory. Why are we changing something ie. “build(ing) a robust
national regulatory regime for the CSG industry” when it is already a “sound mechanism”?
Current legislative arrangements do NOT provide adequate protections. Attempts by
community members to obtain covenants on their land to protect the natural environment
have met with the proviso that if mining companies come into the area seeking exploration
and production, the covenant becomes null and void.
Protections for land uses/land users other than for Mining including CSG Do NOT exist.
Current legislation and the proposed framework will only continue this preferential treatment
of the Mining Industry including CSG. Legislation needs to be put in place to give
landholders and communities the right to say No to Mining and to stop preferential
treatment of the Mining Industry.
The existing “sound mechanism” does NOT give landholders adequate protection. The
Environmental Defender’s Office Victoria (EDO Vic) calls this “preferential treatment” for
mining companies and makes many recommendations for legislative reform. See the EDO
Vic report and the Greens Bill before the Senate.
The EDO Vic has stated that:
“In Victoria offsets have been widely used in the context of the regulation of native
vegetation clearing. They are intended only to compensate for unavoidable ecological
damage and loss. The logic of compensating for ecological damage faces the fundamental
problem of equivalence between what is destroyed and the ‘gains’ represented by the
offset…Recent proposals to change native vegetation clearing rules in Victoria foreshadow
a major weakening of these laws and much expanded use of offsets.” (EDO Vic current
newsletter)
Major weakening of these laws will further undermine the supposedly sound legislative
mechanism that the Report says already exists. This will also confer more preferential
treatment for the CSG Industry – NOT balanced treatment!
We hope that governments do NOT follow the example of the NSW Government who cut
funding to its EDO in NSW. These organisations are TRUE monitors and regulators of the
Australian Environment. Their work should be given due consideration by all Governments
in regard to the CSG Industry as they inform and reflect public concerns for individuals,
communities and the environment and make recommendations to governments regarding
environmental legislation that reflect public needs. The same could be said of organizations
like Doctors for the Environment, Australia and the Toxics Network etc. These
organizations should have a formal role in any regulatory process.
This framework is meaningless if it depends on the industry to embrace social and
environmental responsibility. The industry is only concerned with extracting the gas from
the ground in the cheapest possible way regardless of the consequences to others and the
24
environment. The community has been open and is engaging with both Governments and
the Industry but neither is prepared to listen.
This framework does nothing to instil confidence that the CSG Industry or Governments
have the best interests of the community and the environment in mind.
In 2010 the BP Macondo oil disaster in the Gulf of Mexico took 11 lives, in the 87 days it
took to stop the leak 5 million barrels of oil was spilt causing untold environmental health
and social damage to the region. This was despite the fact the “World’s Best Practice” was
applied to this site. This spill occurred because the installed processes were either not
followed, were assumed to be in place or were just ignored. This has resulted in costing BP
billions of compensation dollars but the environmental health and social damage will remain
for decades to come. This Framework does NOT and can NOT protect us against the
social and environmental risks posed by the CSG Industry.
To instil public confidence, in the CSG industry, this industry and the government must not
only “talk the talk” but must “walk the walk” Be open and transparent with work plans (don’t
hide behind the tag ”commercial confidentiality”), environmental studies, identified risks and
engage other stakeholders when performing these. These actions must be a “MUST do”
not a “SHOULD do” action for all concerned.
Current legislative arrangements already are in place, this framework focuses on a cooperative approach. The CSG industry already has government backing to extract a variety
of minerals from the earth with little or a highly reduced return to the owners of the
resources, the Australian people. As highlighted by the failed mineral resources TAX.
The argument that the regulation of CSG activities will promote openness, transparency and
trust is flawed. There is nothing stopping the industry from being open and transparent now.
Having to create this framework shows that the industry does not care about these issue
because it adversely affects the bottom line. Strong regulations must be followed by strong
enforcement. And the regulations must protect the current land owner’s business, way of
life, property values and the surrounding environment.
Chapter 1 – Towards Sustainability and Co-existence
SCER TOPIC
OUR COMMENTS
1.Environmental Impact
Many projects already require EIAs, which are often
Assessment
understated and/or misleading.
CSG companies have already demonstrated their
lack of integrity and reliability when it comes to selfassessment as well as acknowledgement and
identification of environmental risks eg. Esso at
Longford
2.Environmental Management
Demonstrate that environmental risks will be as low
Plans
as reasonably practical
This is a very subjective requirement and does not
address the community’s concern for Governments
and the CSG Industry to acknowledge and exclude
any development that poses ANY risk to existing
environments on the basis of agricultural, natural,
cultural/heritage etc. value to the community etc.
3.Hierarchy of risk control
Many communities know that the CSG Industry
measures
poses unacceptably high risks to them and so want
this development banned. Risks can only be
mitigated by CSG companies. Communities want to
4.Verify key system elements
5.Governance:
Safety,
Design & Construction,
Operation,
Maintenance and
Decommissioning
6.Independent supervision
7.Blow out preventers
8.Baseline Monitoring
25
prevent these risks from having devastating effects.
Knowing about these risks and hoping that the CSG
Industry will do its best to avoid them will not help.
The same is true of Governments who do not work
to prevent these hazards.
Verification and justification will not help. There
have already been too many accidents and negative
impacts that are beyond remediation. This type of
information only helps the CSG Industry avoid legal
responsibility for the hazards and destruction it
causes but distances itself from. See weblinks at
the end.
On one hand this report argues that existing
legislation and regulation is sufficient and on the
other it introduces new regulations for the CSG
Industry such as this on proper governance.
On one hand the report argues that the CSG
Industry is best placed to make decisions about best
practice but on the other hand, it has had to go to
considerable length to research and report on best
global practices for the CSG Industry to “hopefully”
adopt.
These contradictions are throughout the report and
do not evoke trust and reliability of Governments or
the CSG Industry.
On one hand this report argues that the CSG
Industry is best placed to manage their own projects
but on the other hand it argues here that the CSG
Industry requires “independent supervision
regarding well construction”. This passing on of
legal responsibility removes the onus from the CSG
Operator to a third party. The Industry should NOT
be allowed to shirk its responsibilities in this way.
See media coverage of the recent blowout accident
at Seaspray. Regardless of this “best practice”, the
community still sees this as an unacceptable risk.
Developing an accounting system for water resource
management is false accounting and false
economics. The water that is “co-produced”
becomes contaminated by CSG industrial activities.
It is stored and then it is proposed to treat it for
return to the system as either above or below
ground water ie. “managed aquifer recharge” and
“virtual reinjection”.
These water resources belong to both Australians
and to farmers etc. who have irrigation, water
licences etc. Again, the CSG Industry is getting
“preferential treatment”. It has FREE open access
to Australia’s water resources, it can legally
contaminate Australia’s water resources and then it
can treat that water (at whose cost?) and SELL it
back to us or be falsely CREDITED for
environmental returns
For the high public costs of water treatment see the
26
9.Regional Scale Assessments
10.Co-produced water
11.Recycling of co-produced water
12.Geological assessment
13.Hydraulic fracturing process
monitoring & quality control
14.Australian legislation, codes
and standards for chemicals
15.Chemical use
16.Maximise recovery of ONLY
Desal plant, Melbourne Sewerage water treatment
etc.
As per no.8 above
As per no.8 above
As per no.8 above
As per no. 5 above
As per no. 5 above
Process monitoring is evidence of the unacceptable
high risks associated with the CSG Industry. The
difficulty of predicting what effects CSG technologies
will have are well documented in the many incidents
that have been reported in the media and amongst
community groups. Process monitoring is the
proposed way of dealing with incidents as they
occur. The CSG Industry will be learning as it goes
as stated in this report. The Industry is still in its
infancy technically speaking ie. there are still a lot of
“unknowns” and “unpredictables”, despite assertions
that it has been operating around the world since the
1960s. These are a means of cop-out for the
Industry as it would not be “reasonably practical” to
expect CSG Operators/the Industry to be able to
predict what will happen in every project because
they each differ and have so many variables, which
we’d expect them to be on top of if they had learnt
anything since the 1960s. This is also a misuse of
“Adaptive Management.”
Handling, Management, Storage, Transport
Holding ponds for contaminated water are
kilometers long. Contaminated salt stacks are also
kilometers long and metres high. Both pose an
extremely high risk to our water systems and soils.
The Report does not give adequate recognition to
these problems especially in areas prone to
flooding, bushfire and/or earthquake. Contaminated
salt is not raised in the Report. Disposal of the
contaminants contained in the water and salt as a
result of the CSG Industry are not considered. The
CSG Industry puts a heavy burden on our
community roads. Its transport requirements for
deliveries of water, methane, equipment and
infrastructure etc. are not mentioned.
While the aim of minimal use and use of
environmentally benign alternatives seems
commendable, the Industry will be able to easily
justify why it had to use certain chemicals in certain
quantities and combinations. As our experiences of
the CSG Industry have already shown us in Qld &
NSW, Governments and the public will only know
about these misuses when they cause irreversible
problems. The Industry denies it’s responsibility and
independent investigation is not forthcoming from
Governments eg. Esso at Longford
While the aim to maximize recovery of fracturing
30%-70% of fracturing fluids
17.Full disclosure of chemicals
used
18.Assess combined effects of
chemical mixtures
27
fluids seems commendable, the Industry will be able
to easily justify why this was not possible/practicable
in whole or in part – especially when the Report
estimates that the CSG Industry can only recover
about 30%-70% of the fracturing fluids it uses. Why
is the Industry not required to PREVENT
contamination of our above and below ground water
systems/catchments and our soils and air? This is
what the public wants but, we assume, would NOT
be “reasonably practical” for the Industry to do.
Again, the Industry is not held accountable and the
public, fauna and flora cannot be compensated for
its loss of healthy water supplies and of healthy
soils.
While the aim of transparency in the chemical
assessment processes seems commendable,
Companies continually get around these
requirements with the aid of “commercial
confidentiality”, “proprietary information” and
“intellectual property rights”. We have much
experience of the Industry both in Australia and
overseas where identification of chemicals used by
the Industry that has caused contamination has only
been possible AFTER the contamination and by
concerned individuals – not the Companies who
continue to deny their use and responsibility.
Australian legislation and Internationally accepted
testing methodologies are inadequate. Doctors for
the Environment, Australia has already identified the
need for significant investigation by Governments as
there are so many “unknowns” in this area.
GOVERNMENTS’ ROLE IN EDUCATING THE PUBLIC
“In their role as regulators and educators for CSG activities, Australian governments should
further improve their individual and combined efforts in tailoring participation of the
community in decision-making, conducting open and constructive engagement with key
players and ensuring that access to factual and timely information is available to all
stakeholders.”
Most of this report explains what constitutes best global practice in the CSG Industry. It
seems that it is the CSG Industry that needs educating and NOT the public who have
flagged all these problems. The public are well informed, knowledgeable and capable of
maintaining an active role in this debate. The public will not be duped by Governments’
promotion of the CSG Industry and downplaying of the unacceptable risks it presents to us.
COMMUNITY FACTS, INFORMATION, CONCERNS & POINTS OF CONTENTION ARE
VALID
“Coal seam gas, also referred to as coal seam methane or coal bed methane, is a form of
unconventional natural gas that occurs naturally within the pores or fractures of coal seams.
Coal seams can be found at depths generally ranging from 300 to 1000 metres. CSG
consists of approximately 95 per cent methane. The remainder consists of a mixture of
other gases that include carbon dioxide, carbon monoxide, nitrogen, and hydrocarbons
other than methane.”
28
Recent studies from Southern Cross University and Melbourne University report that
methane leaks from the CSG Industry are 7 to 25 times worse for global warming and
climate change than carbon dioxide. What will SCER/COAG do to make sure that all
developments in their Energy Resources portfolios especially those by the CSG Industry
are tested and assessed against their ability to reduce/eliminate (not release) harmful
greenhouse gases. All Industry development should be tested as to whether/not it supports
or counteracts Government policies aimed at avoiding Climate Change. Has there been a
whole of government approach to the CSG Industry? Have all Government Departments
been required to do their own assessments of the impacts of the CSG and similar Industries
on their Portfolios?
THE CSG INDUSTRY PROVIDES MINIMAL PUBLIC BENEFIT FOR MAXIMUM
NEGATIVE IMPACT
“Australia has significant commercially exploitable deposits of CSG, primarily located in coal
basins in New South Wales and Queensland. CSG production began in Australia in 1996
and currently accounts for more than 35 per cent of supply in Australia’s eastern gas
market.”
The figure of 35% of gas supply to Australia’s eastern seaboard would become far
lower/insignificant when calculated for all of Australia and when compared to all forms of
energy used within Australia. The renewable energy sector currently accounts for a
growing share of the Australian Energy market. There is no justification for the considerable
high risks and negative impacts of drilling/fracking for CSG when the renewable energy
sector has overwhelming public support, far less risks and far less negative impacts.
Subsidies, tax rebates etc to the CSG Industry should be redirected to the Renewable
Energy Industry.
THE CSG INDUSTRY DOES NOT BEHAVE RESPONSIBLY
“From an economic perspective, a CSG project needs to be profitable in order to be
sustainable. Profit should be generated responsibly for as long as possible by keeping costs
to a minimum while maximising revenue.”
See the findings of the Senate Inquiry headed by Bill Heffernan which documents the
terrible tactics used by the CSG Industry to get their way.
THE CSG INDUSTRY DOES NOT PROVIDE EQUITABLE BENEFITS TO ALL
STAKEHOLDERS
“CSG operations can play a significant role in maximising equitable benefits to all
stakeholders, including the community, local businesses, shareholders and government,
through its contribution to Australia’s GDP, tax revenues and job creation.”
We already have robust, diverse and thriving communities that do NOT want to include a
CSG/Mining Industry. We have seen how these Industries are NOT compatible. They
compete for all our social assets and resources. We cannot co-exist! They create marked
devaluations of all existing businesses and properties and so Council rates. This leads to
businesses closing down, people losing their local employment (especially in farming and
tourism) and general running down of social fabric, health, wellbeing and happiness.
We have also seen the CSG/Mining Industry replace once independent and flourishing
communities with a dependency for services including education, sport, recreation and
leisure, cultural. We can see how Governments may enjoy the economic savings of not
having to provide these public services by ingratiating themselves to the CSG/Mining
Industry and How they even congratulate themselves for attracting money to communities
for these services (which the Industry can then write down as a cost and promote as their
investment in social capital/responsibility). This goes to the heart of the responsibilities of
29
governments to provide these services with our taxes – not to hand this responsibility over
to the mining industry – especially when communities and their services then become
enslaved and dependent on the CSG/Industry. What will happen when this industry runs
dry in the next 15-50years as is happening with all other fossil fuel industries now?
Individuals and communities MUST have the legal right to decide NOT to become a mining
town.
Also See our comments above about Net Benefit, Balanced decision making etc..
Appendix 1 IS MISLEADING
Appendix 1 gives some figures about How much water the CSG Industry uses? It comes to
the conclusions that:

other industries currently use/extract MORE water than the CSG Industry;

the CSG Industry is expected to use MORE water as it grows; and

the CSG Industry currently “recharges” ie. “co-produces” or “returns” MORE of the
water it uses to our water basins than do other industries.
We dispute the figures contained in this Appendix. Other factual and scientific sources say
that water use by the CSG Industry is expected to be far greater than that for other
industries As well as the vast quantities of water used by the CSG Industry, the public is
concerned about the CSG Industry’s CONTAMINATION of ALL of the water it uses – which
most other uses ie. “bores for agriculture and stock and domestic uses… fruit tree and nut
growing… mushroom and vegetable growing… electricity and gas supply (and organics) do
NOT do – even though “modelling has shown there is inevitably some interconnectivity”
between the water used by the CSG Industry and these other uses.
No mention is made of the contribution that these other industries make to the Australian
society like food security or to our economy. And no mention is made of the value
contributed to our society for the level/quantity of water these other industries use when
compared to the water use of the CSG Industry or of the negative impact water
contamination by the CSG Industry poses for other Industries like our food supply. Food
producers ie. farmers, horticulturalists etc. are responsible for the quality of their product.
How will problems of food contamination and disputes between food producers and the
CSG Industry be dealt with when produce is found to be contaminated? This is also a big
issue for the “organic” sector. What responsibilities will be placed on the CSG Industry to
ensure that landholders meet our food/produce and organic standards?
COMMUNITY FACTS, INFORMATION, CONCERNS & POINTS OF CONTENTION ARE
VALID
“CSG activities will have an impact on the natural environment in which they occur.
Environmental issues, such as groundwater depletion and drawdown, land degradation,
increased pressure on marine environments and increased greenhouse gas intensity, can
be managed to minimise any impact on the environment through leading environmental
management practices. Appropriate steps should be adopted in the planning and
operational stages of CSG exploration and production to protect environmental values and
minimise long-term liabilities, in line with environmental regulation….”
Once again the public’s identification, highlighting of these problems associated with the
CSG Industry and so opposition to the CSG Industry is well informed, knowledgeable,
expert, justified, valid and a necessary contribution to monitoring and evaluation of the CSG
Industry.
30
Even when these so called global best practices are currently used by the CSG Industry,
they do NOT prevent impacts and will NOT PROTECT social and environmental values.
The CSG Industry’s way of minimizing long term liabilities is to:



take risks that are TOO HIGH – ignoring or down-playing their own risk assessments;
delay, disrupt and deny any thorough investigation; and
deny any causation, responsibility, accountability or liability for impacts that
communities have exposed.
‘Impact’ is even defined in the Report’s glossary as:
“An unintended environmental, social or economic effect on the environment as a consequence of CSG operations”
Governments and the CSG Industry are telling us to EXPECT UNINTENDED
environmental, social and economic CONSEQUENCES of the CSG Industry. They are also
admitting that they canNOT guarantee that they will be able to fix these problems as they
occur. In addition to these unforeseen/unintended problems, there are the foreseeable
ones like methane leakage from each and every well even after they are
abandoned/decommissioned by the CSG Industry, the build up of salts and other
contaminants in the water table, the lowering of our water tables, destruction of aquifers as
well as social and health problems. The Report ignores both known and unknown problems
inherent in the CSG Industry.
COMMUNITY EXPLOITATION NOT COMMUNITY DEVELOPMENT
“In the context of CSG development, the community may be defined as both the geographic
community in the operation’s area of interest, and as a network of people who are
geographically dispersed but are linked together by a shared set of interests or experiences
(DITR, 2006). The latter description of community may, for example, apply to the CSG
industry when fly-in fly-out arrangements are in place for employees of the operation…. In
determining the needs of a community, it is important to acknowledge that a community is
not a homogeneous entity and that members of a community are likely to hold diverse
opinions about a CSG project, its activities and the petroleum industry in general. It is
important that CSG companies’ engagement processes seek views on how the local
community is constituted from a broad cross-section of people and that engagement
processes are tailored accordingly (DITR, 2006)…. The CSG sector’s involvement with the
community should include both community engagement and community development: two
distinct processes to ensure that a CSG operation gains the support of its community
members, contributes to the sustainability of the community and leaves a positive legacy.
Beneficial community engagement and development could include the development of
affordable housing for both CSG companies’ employees and local residents, and
contributions to infrastructure. It could also include upfront and honest liaison and
negotiations and assurance of certainty to residents that CSG activities will contribute to,
and not jeopardise, the community’s economic, environmental and social prosperity.”
This issue stands out for the LACK of diversity in opinions amongst the public and individual
communities in regard to the following matters:
 Wanting to STOP/BAN fracking, CSG (and other unconventional gas) developments
throughout Australia
 Governments unwillingness and inability to regulate the Mining Industry; and
 The CSG/Mining Industry juggernaut that pursues its own vested interests at the
blatant expense of the public.
Most Australians, as we are continually finding out are:
31


Immediately upset about what is happening in Australia; and
Actively resisting
This IS a black and white issue NOT a grey one that governments and the CSG/Mining
Industry can muddy or split hairs about. We want New Coal and the CSG Industry
(including other unconventional gas) STOPPED & BANNED in Australia and for
governments to make the transition to RENEWABLES NOW.
The Lock the Gate Alliance represents the most broad cross-section of people engaged in
this debate possible and should not be patronized, placated, dismissed or got around by
governments or the CSG Industry.
The CSG Industry’s failed attempts at community engagement have been documented by
both the Senate Inquiry and continuously by communities across Australia.
The CSG Industry’s attempts at community development are more accurately described as
creating community dependence and repression. It does NOT “ensure that a CSG
operation gains the support of its community members, contributes to the sustainability of
the community and leaves a positive legacy…(They certainly do NOT create affordable
housing for both CSG companies’ employees and local residents, and contributions to
infrastructure…upfront and honest liaison and negotiations and assurance of certainty to
residents that CSG activities will contribute to, and not jeopardise, the community’s
economic, environmental and social prosperity.”
As stated above, the CSG/Mining Industry is renowned for being Exploitative not
Supportive! It goes to considerable lengths to create divisiveness within communities so as
to get a toehold in a community eg. Exxon Mobil employed a market research company to
conduct a random phone survey of people in the Gippsland region. The questions asked
were extremely biased in favour of the Industry. Local people soon exposed this cynical
strategy and got the company to withdraw their survey. It is also evident that these
companies pay highly for access to large areas of private land held by the first few people to
agree. These people then become (contracted?) spokespeople/promoters/posterboys for
the Industry. After that the price declines significantly. Individual contracts are confidential
– People are NOT able to talk about their agreements or anything related to the CSG
Industry on their land – even when accidents occur for fear of legal proceedings being taken
against them by the Industry. It is not a coincidence that the Industry began in Australia in
outback/regional Qld where households are kilometers apart and individuals with little
community support find it difficult to resist CSG/Mining companies.
Community development is a MISREPRESENTATION of what the CSG/Mining Industry
does to communities:









It dismantles any positive sense of community;
It gags open, honest and transparent discussion;
It secures itself from communities in order to exclude any public scrutiny,
It is NOT an equitable partner – it’s financial interests and profits far outweigh all
other social considerations
It does NOT attract residents, tourism or business investment to the existing/other
sectors;
It creates devaluation of land, homes, equipment, businesses and council rates
It makes it very difficult/impossible for people to sell their homes and businesses
It increases Governments costs ie. tax pressures for infrastructure like roads,
bridges, traffic management, ports etc.
It creates UNemployment with the associated downturn in local economies
32

It creates contamination of people’s environment (including water and soil), social
dislocation, health problems including significant decline in people’s wellbeing and
state of happiness etc.
It may contribute some money directly to local sports clubs, cultural venues, schools, roads
etc. as has happened in Roma Qld. Again, this is a pittance and is used by the Industry to
create community DEPENDENCE NOT DEVELOPMENT. Governments may be happy to
allow this transfer of funding to the Corporate sector in the name of social responsibility
BUT:


This money is tied to/conditional upon allowing the CSG Industry to develop and
grow
This money should be administered through governments’ taxes – which on one
hand the Industry is NOT happy to pay eg. Mining Resources Tax but on the other is
happy to contribute to/bribe local communities
This money creates dependency on the Mining Industry – An Industry with a maximum life
of 50years according to the Senate Inquiry. What happens when this Industry goes bust
during this time (as it will when prices moderate) and when the Industry ceases? WE are
NOT talking long term – only short to middle term. This is therefore, NOT sustainable
development of communities. The Industry continues to demonstrate how it resists any
sense of EQUITABLE tax contributions and any sense of real corporate responsibility for its
social and environmental impacts. At the same time it insists that we forego our natural
resources of water, soil and general wellbeing and amenity and pay dearly with major
changes to our lives and our taxes for roads, ports etc. that the Industry needs to be viable.
The Industry gets everything far too cheaply and at our expense:




The right to legally contaminate our water, soil and air;
The right to take high/unacceptable risks with our livelihoods and lifestyles
The right to rundown and not pay for public infrastructure that it uses eg. roads, ports
etc.
The right to our land although we do NOT want this
When & How will governments redress this INEQUITY?
MISUNDERSTANDING OF THE ROLE & BEHAVIOUR OF CSG COMPANIES
“Companies operating in the CSG sector aim to be financially profitable in the extraction of
resources to supply natural gas to the Australian domestic market and, in the future, to
international customers. There is mounting pressure on companies involved in the
extraction of non-renewable resources to embed the concept of sustainability into strategic
decision-making processes and operations. This ensures that CSG companies seek to
maximise financial returns, while also better managing their social and environmental
impacts. It is commonly viewed as simply ‘a good way to do business’ (DITR, 2006).”
Embedding the concept of sustainability into the CSG Industry’s paperwork will NOT
change how they do business. It is up to Governments to show some leadership in this
area of cultural change. We are looking to our governments to stand up to the Mining
Industry and hold them socially and environmentally responsible. We do not want to see
our governments and country continually at the behest of Mining companies.
Recent proposals to change NSW CSG Regulations (incl. 2km radius – an increase on the
100 metres)) have met with a rush of CSG Industry representatives to hastily meet with
politicians about their impact on the CSG Industry. It is impossible to see the Industry’s
33
concern for communities and the environment because it does NOT exist!
The business community constantly argues to lower compliance requirements and costs of
government regulation. They call it “Red tape” and do NOT see it as aiding their business
in any way. As with the other industries, the CSG Industry will redirect money to achieve
Accreditation and Framework Standards in addition to profits, with less money available to
lower their risks and protect social and environmental values.
CALCULATED & PERCEIVED RISKS OF THE CSG INDUSTRY
“Australian governments at all levels are focused on achieving a balance between
developing a world-class CSG industry, protecting the environment, human health and
delivering opportunities and benefits to the Australian community. It is the responsibility of
governments to understand and address both the calculated and perceived risks involved in
CSG development and adopt positions that address and respond equally to these concerns.
Governments are expected to provide a balanced response to the needs of industry and the
community. Governments should aim to provide policies and regulations that encourage the
growth of the industry, within a regime of relevant, enforced conditions and legislation to
protect the environment, human health and facilitate social development and sustainability.”
See our comments above about Balanced decision making, Net benefit, Privileged legal
treatment, Community exploitation and Sustainability.
GOVERNMENTS BIASED TOWARDS THE CSG INDUSTRY
“An environment that delivers beneficial outcomes for all participants to ensure that the
needs of participants involved in CSG development are addressed, it is necessary to
determine what environment is required to best facilitate this outcome. This environment
needs to have a focus on the principle of co-existence, where there is a shared commitment
among the resources industry, other land users and governments to: multiple and
sequential land use; better informed public discourse on resource development; merit based
land access providing certainty for industry and improved community confidence in land use
decision-making; and finally, the delivery of best possible outcomes for affected
communities.”
About “the principle of co-existence”
See our comments above about this. We do NOT accept this as a starting point for
discussions about whether/not the CSG Industry should continue, develop or grow. We
believe the starting point is a referendum asap on Australia’s Energy Future. The CSG
Industry must NOT be allowed by Governments to undermine or permanently compromise
the long term future of other sectors (especially given that it is a “relatively short-term
prospect” as stated by the Senate Inquiry).
About “shared commitment”
See our comments above about privileged legal treatment and community exploitation. We
do NOT share in the governments’ and the Industry’s commitment to the CSG Industry.
About “better informed public discourse on resource development”
See our comments above about Community facts etc are valid. As discussed above the
public is extremely well informed about this Industry, Australia’s natural resources and our
Energy needs. Attempts to downplay and dismiss these concerns are not appreciated.
About “merit based land access providing certainty for industry and improved
community confidence in land use decision making”
See our comments above about Coexistence and the MLUF. We do NOT support a
planning approach that takes away or does not institute our legal, democratic and civil rights
34
to:




Say No to any land use
OBJECT to, APPEAL and EXCLUDE any land uses/Industries either concurrently or
sequentially
Enforce our rights to stop TRESSPASS
Pursue and participate in activities to prevent land uses that individuals and
communities do not support
Planning should NOT be used as a way to introduce unwanted land uses and Industries to
any areas. This would also contribute to the decline of areas, as people would NOT be
attracted to those areas that have or could have unwanted land uses and Industries. In
Victoria these existing/possible/probable land uses/Industries would need to be disclosed in
Section 32 Statements.
About “best possible outcomes”
See our comments above about balanced decision making and net benefit. Now the phrase
becomes “best POSSIBLE outcomes”. Even in this Report, Governments and the CSG
Industry acknowledge the high risks, problems and hazards of the CSG Industry. The
Report has stated that there are impacts, not all impacts can be foreseen or predicted and
that impacts can only be mitigated. Profit is the principal concern of the Industry.
Therefore, it is easy for the Industry to demonstrate that the required protection and
prevention are not POSSIBLE. Governments are complicit in NOT carrying out their
essential role of PROTECTING our social and environmental values and of NOT requiring
decisions regarding whether/not the CSG (and other) Industry meets this criteria to enable it
to proceed or not in Australia.
About “affected communities”
The Report gives two definitions for “community”. Firstly, we are to include the Industry, it’s
employees, all of Australia and the world that needs our fossil fuel sources of energy. We
are not to limit our definition to just the people who live and work around the proposed and
existing CSG Industry. This is meant as a very wide definition to take power away from
resistant communities. However, here we are to define “community” in a very narrow sense
as only those people who are “affected” by the Industry. This is meant to minimise the
extent of the problems that the CSG Industry poses and causes to us all. They are NOT
limited to a few communities who have NOT been able to exclude the Industry despite a
groundswell of community concern, protest and resistance. It is a dishonest attempt to
misrepresent the broad reach that the problems associated with the CSG Industry have for
us all. It is another way in which Governments and the Industry try to divide community
opinion and action.
This is not a “NOT IN MY BACKYARD – OUT OF SIGHT OUT OF MIND” issue. We
understand that this Industry poses UNacceptable risks for our fresh water supplies, water
catchments, underground water supplies, aquifers, creeks, rivers, beaches and seas, for
our soils, our food supplies, our air, atmosphere, greenhouse gas emissions and climate
change as well as for our amenity, livelihoods and lifestyles.
These problems do NOT stop at borders – they affect us all. The public understanda this
and will resist these attempts by Governments and the Industry to divide and disempower
the groundswell of community concern and action that is the Lock the Gate Alliance.
THE GUIDING PRINCIPLES ARE MISGUIDED
“The development of the national Multiple Land Use Framework endorsed by the Standing
Council on Energy and Resources in 2011 will provide the foundation for a sustainable CSG
35
environment, based on guiding principles, including that of co-existence. The guiding
principles, applied by industry, other land users, the community and governments,
demonstrate a commitment to maximising the social, economic and environmental value of
land and marine environments.”
See our comments above about the MLUF, Sustainability, Net Benefit, Balanced Decision
Making and the Principle of Co-existence. Governments are responsible for PROTECTING
not MAXIMISING the social, economic and environmental value of our land and marine
environments. In it’s discussions of net benefit, the Report promotes FINANCIAL value to
the CSG/Mining Industry and to Governments OVER all other aspects of value. This is
MISGUIDED. As stated above, we do NOT accept that the MLUF is a foundation for a
sustainable CSG environment.
“The Multiple Land Use Framework will promote the use of adaptive capabilities (leadership,
partnerships, planning, engagement, education and applied learning) and technical
solutions (assessment and approvals processes underpinned by sound scientific and
engineering guidance and practice). This will improve the efficacy and workability of
interactions between industries, including the CSG sector and other significant land users.”
The Report MISREPRESENTS Adaptive Management. Adaptive Management does not
exclude Governments’ essential responsibilities for social and environmental
PROTECTION. This Report erodes our democratic institutions. As stated above, this is not
simply an issue for significant individual land users/holders. This is a public issue about
Australia’s Energy Future and our Natural Resources including water, soil and air and, as
such, should be put to Referendum.
About “Co-existence: The rights of all land users and the potential of all regulated land
uses should be acknowledged and respected, while ensuring that regulated land is not
restricted to a sole use without considering the implications or consequences for other
potential land uses, and the broader benefits to all Australians.”
See our comments above about Coexistence, the MLUF, Balanced Decision Making,
Sustainability and Net Benefit. The two halves of this definition are contradictory. The CSG
Industry is COMPETING for our private and public lands and water. We do NOT accept this
principle.
About “Best use of resources: Governments should seek to maximise the economic and
social benefits of regulated land use for all Australians and future generations through
encouraging the multiple use of regulated land, while respecting and protecting
environmental, cultural and heritage values.”
See our comments above about Balanced Decision Making, Sustainability and Net Benefit.
The two halves of this definition are contradictory. The CSG Industry is COMPETING for
our private and public lands and water. We do NOT accept this principle.
About “Coordinated preparation informed by effective planning: Governments should
coordinate planning (involving government and industry) to recognise the community’s
expectations and capacity to adapt to land use change. Effective regional-scale planning
establishes clear spatial parameters for multiple and sequential land use over time,
providing community and investor certainty while retaining the flexibility to adapt to change.”
See our comments above about the MLUF. It seems from this statement that Governments
and the CSG Industry WILL put “regional scale planning” mechanisms in place to “prepare”
the way for the CSG Industry to LEGALLY gain access to our public and private lands and
water in order to grow the CSG Industry. It seems that this will be done REGARDLESS of
the community’s opposition. It seems that it WILL become ILLEGAL for individuals and
community groups to DENY ACCESS to our lands and water by the CSG Industry.
36
This statement EXPOSES our Governments complicity with the CSG Industry AGAINST the
public it purports to REPRESENT. This strategy of Governments and the CSG Industry is
aimed directly at overcoming the success of the Lock the Gate movement. By putting up
Lock the Gate Trespass signs many people have clearly taken their own stance on this
issue. It is the only LEGAL recourse we have to notify Governments and the CSG Industry
that we do NOT want the CSG Industry to operate on our land or in and around our homes
and workplaces.
Governments and the CSG Industry can currently legally challenge each of our actions by
taking us one by one to VCAT in Victoria (and similarly in other States). But they will NOT
do this because it would be a huge public embarrassment to them. The public would be
outraged at Mining companies insisting that/bullying individual landholders to allow them
onto their land for CSG exploration and production. This is especially true now that the
Lock the Gate movement is widespread. Before landholders in QLD & NSW began
organizing to oppose the CSG Industry some similar cases were held in QLD and the CSG
Industry won. This did not get a lot of publicity however as the CSG Industry and the
movement were in their infancy and the landowners were isolated and unable to resist by
themselves. Now such challenges would cause public outcry.
The NSW Government has recently floated a 2km “clear spatial parameter (around
residential areas) for multiple and sequential land use over time”. This has met with
opposition from the public and from the CSG Industry who is rushing to meet with politicians
(see recent media reports). There can be no happy medium or balanced decision making in
this matter. Competition for our natural resources is fierce between the public and the CSG
Industry. The CSG Industry is COMPETING for our private and public lands and water. We
will not allow it. We do NOT accept this principle.
About “Tailored participation of communities and landholders in decision-making on
land use change: Participation of communities and landholders should be tailored,
targeted and timely. Genuine participation involves communities having the capacity to
shape how land use change occurs. Directly affected landholders should be meaningfully
informed and consulted in a timely way on multiple land use options and potential for coexistence to promote a greater understanding of mutual benefits and to resolve concerns.”
It seems that it has already been decided. Governments will ignore the widespread public
opposition to the CSG Industry. Governments will pave the way for the CSG Industry to
LEGALLY establish and develop on land where they are NOT wanted. ONLY “directly
affected landholders” will have ONLY the “capacity to shape HOW land use change occurs.”
In the eyes of Governments and the Industry, these landholders will come to understand the
“mutual benefits” of doing this and their concerns will be resolved. NO they will NOT! How
patronising and undemocratic! We do NOT accept this principle or the obvious complicity of
Governments and the CSG Industry. These sorts of coercive strategies by Governments
and the CSG Industry only undermine democracy and erode civil society.
Communities are already engaged in this debate. However, while Governments and the
CSG Industry put in time and money to meet together, no such opportunity is given to the
public. We have had to develop our own ways of uniting and voicing our concerns and
taking actions – All because Governments and the CSG Industry are NOT listening and do
NOT plan to listen in the future as is made obvious here and elsewhere in this Report. We
do NOT need to be manipulated by “tailored, targeted and timely” communications from
Governments & the CSG Industry. They just need to LISTEN to what the public is already
saying and will continue to say more loudly – NO CSG!
About “Engagement and education are paramount to informed debate: Open and
37
constructive debate and analysis of different multiple land use options should be informed
by facts. Stakeholders should be genuine in their willingness to listen and appreciate the
views, concerns and needs of other land use stakeholders.”
See our comments just made above. This Report takes the view that it is the public who
need to be educated and constructive. The public takes the view that it is Governments and
the CSG Industry that need educating, that need to be constructive and not destructive,
open, genuine and transparent, informed by facts, willing to listen and appreciate the
public’s views. Some communities have been treated to visits by DPI staff whose job it is to
provide information in line with Government views on the CSG Industry. Most of these visits
have been poorly attended, reflecting the public’s understanding that this is a one-way
street. No politicians have held public meetings or conferences with the public on CSG.
This is a closed door, controlled and manipulative approach to community consultation and
engagement. We do NOT accept this principle.
About “Decision-making: Evidence-based decision-making on land use should be
informed by risk-based approaches that make transparent the consequences of different
land uses. Accountabilities regarding decision-making should be clear and enduring.”
While this all sounds wonderful, the public (using this SAME evidence-based decisionmaking process) has come to a VERY different conclusion – in fact the exact OPPOSITE
conclusion – No CSG! As this Report makes obvious, we know that Governments and the
CSG Industry do NOT have all the evidence or facts (especially in regard to fracking and
chemical contamination), do not understand all the facts (there are a lot of things that
cannot be predicted or planned for), minimize the risks posed by this Industry (only to be
proved wrong by the public) and are NOT held accountable (companies argue that they are
NOT responsible for contamination and health problems and that direct causal links can not
be found). The public is of the view that the CSG Industry is COMPETING for our lands
whether they be residential, leisure, recreation, water catchments, food production, cultural,
heritage, conservation, preservation etc. Attempts by Governments and the CSG Industry
to muddy these waters will only undermine democracy and civil law.
Landholders from overseas, QLD & NSW are already advising us to not let the CSG
Industry happen in other states of Australia. This is due to the impacts they have
EXPERIENCED in their soils, air and water supplies and catchments. This is also due to
the industrialization of their landscapes that they do not want and their inability to use their
lands for their livelihoods and lifestyles. This is especially so when CSG wells are
“decommissioned” ie. Their experience has been that all the wells and pipes above and
below the ground STAY – they and their contamination are the only enduring things about
the CSG Industry and they continue to leak methane. We do NOT accept this principle.
About “Efficient processes: Governments should work towards streamlined, transparent
and consistent legislated approvals processes in which land access for multiple use is
handled in accordance with risk. This includes ensuring that processes define multiple and
sequential land use of cross-cutting issues (water, heritage and cultural values) based on
the best available evidence and sustainable development principles.”
See our comments above about MLUF, Planning mechanisms & Sustainability.
Governments proposed “legislated approvals processes” for multiple land uses including
CSG are coercive and a misuse of their powers. “Cross-cutting issues” seem to be those
things that the CSG Industry is willing to sacrifice in order to proceed eg. Water, heritage
and cultural values. The “best available evidence” again, is subjective. People’s
experiences of the CSG Industry so far would seem to be the best available evidence that
we have so far. Why are Governments and the CSG Industry NOT listening to or
acknowledging the value of these experiences, our constant monitoring and assessments of
the CSG Industry? (some of which were documented by the Senate Inquiry). We do NOT
38
accept this principle.
About “Access to relevant information: Relevant information about land and resource
capability and values, current and proposed multiple and sequential land use, and land
management performance should be accessible to all stakeholders. Figure 1.1 provides an
overview of the methods and tools in the Multiple Land Use Framework, framed by its
guiding principles.”
It all depends on who determines what is RELEVANT information and What is meant by
ACCESSIBLE information? Where is the requirement for Governments and the CSG
Industry to acknowledge all the accidents, contamination and social destruction that have
already occurred around the world and in QLD & NSW? Predictions about “resource
capability” will be overstated and not held to account – because this Industry is
COMPETING for our lands and water and infrastructure. What will happen to Government
responsibilities for social and environmental PROTECTIONS and for supporting other
business sectors like farming, horticulture, tourism, health etc? Governments are already
moving to diminish these protections and supports.
The MLUF Research Study Summary Report consists of only 3 pages including a single
page diagram withOUT any explanation of this flow chart. This is a serious fault of the
Report given that the MLUF is the over arching document to this Report. We are being
asked to comment on something that we only have in part. This is another example of
Governments lack of openness, transparency and goodwill in its CSG communications and
is unacceptable. We do NOT accept this principle.
“It is critical that the CSG environment developed and facilitated by the guiding principles
addresses the needs of each participant (community, industry, and governments) and
produces sustainable outcomes from an economic, social and environmental perspective.
Ultimately the goal to be achieved is co-existence, where the needs of each
participant are addressed through negotiation and open engagement to achieve the
greatest net benefit for Australia.”
See our comments above about the Misguided Guiding Principles, Sustainability,
Coexistence, Balanced decision making & Net benefit. We do NOT support the Report’s
GOAL of Coexistence.
GOVERNMENTS ROLE IS TO PROVIDE SOCIAL AND ENVIRONMENTAL
PROTECTIONS
The Report sees the aim of Governments’ regulatory role as “ensuring a balanced outcome”
for all participants. The Report sees Governments regulatory role as “delivering regulation
that is effective in addressing an identified problem” of the CSG Industry, of “maximising the
benefits to the community, while taking account of the costs”, of systematically evaluat(ing)
costs and benefits”. This is wrong and far too narrow. The aim of Government Regulation
is social and environmental PROTECTIONS. We do NOT accept the Report on the basis
that it significantly changes Governments roles and responsibilities.
“Governments also play a significant role as educators by providing key messages and
information to assist the general public, the CSG sector and the media. In this way, all
parties will better understand and appreciate the importance of co-existence in land use,
what governments are doing to protect the public interest, and the communities’
expectations of resource companies in working with land holders and local community
leaders. As regulators and educators, governments can address both calculated and
perceived risks of CSG development pertaining to industry, the environment and
communities, and consequently also better manage and mitigate political risk. To this end,
there is an opportunity for governments to further improve their individual and combined
efforts in tailoring participation of the community in decision-making, conducting open and
39
constructive debate with key players, and ensuring that access to factual and timely
information is available to all stakeholders.”
See our comments above about Misguided Guiding Principles, MLUF, Net benefit,
Balanced decision making & Coexistence. The Report’s aim of getting the public to “better
understand and appreciate the importance of co-existence in land use” and of “achieving
better informed public discourse” through its MLUF strategy (including changes to planning
laws, community engagement, tailoring participation of communities, key players and
leaders and promotion of the CSG Industry via key messages) and the 18 regulatory
frameworks, will fail. The public view is that Governments are NOT doing enough to
“protect the public interest” against the CSG/Mining Industry. This will remain our view until
Governments take steps to stop and rewind the development of the CSG Industry
throughout Australia – not to (attempt to) manage it and minimise impacts! The CSG
Industry is inherently UNable to provide any sense of Sustainability or Co-existence. The
only way to adequately address these issues is to BAN the CSG Industry in Australia.
Chapter 2 – Applying Leading Practices
NO amount of Leading Practices will ensure social and environmental safety by the CSG
Industry! The only way to adequately address this issue is to BAN the CSG Industry in
Australia.
“Successful implementation of leading practices in regulatory regimes will depend on the
willingness of industry to embrace social and environmental responsibility and adopt leading
practice, and the community’s readiness and openness to engage with governments and
industry.”
The CSG Industry, by its very nature, is NOT and cannot become ‘socially or
environmentally responsible’. Communities have been trying to get Governments and the
CSG Industry to listen and acknowledge the validity of their concerns to no avail. We will
wait to see the responses of Governments and the CSG Industry to individual and
community submissions.
This section repeats a lot of what has already been said in previous sections of the Report.
Again, see all our comments above.
“While regulations in all jurisdictions have evolved or can evolve to manage the
development of the CSG industry, the identification of leading practices provides a robust
basis for the development and refinement of legislation, regulations, policies and practices
that make up the elements of the Framework for CSG, and importantly provides a
consistent approach across jurisdictions to managing CSG development, ensures a level of
certainty for stakeholders and delivers consistent outcomes. The process of harmonisation
is anticipated to occur in line with each jurisdiction’s level of CSG development and
management of its CSG industry. Ultimately, the application of the leading practices by
governments through a national harmonised regulatory framework, supported by industry
practices, will help to build public confidence in the operation of the CSG industry and
deliver a balanced message about the opportunities and potential issues of CSG activities.”
The Report is full of contradictions. In other sections it has said that existing regulations are
adequate and here again it states the opposite. We do NOT accept the Report’s process of
a Harmonised Regulatory Framework or of the MLUF for the CSG Industry. The Report
only adds to our concern that the CSG Industry is NOT expert in managing the social and
environmental risks inherent in its activities and that Governments are not able to provide
adequate social and environmental protections in the face of such a (financially and
politically) powerful Industry/Lobby group. This is our position and so we will NOT comment
in any depth on the 18 leading practices except to say they are inadequate and have been
developed simply to placate growing public concern about the CSG Industry. All our
40
comments apply equally to the repetitive phrases used throughout this Report.
As far as we can tell, most of these 18 best global practices seem to have been obtained
from a search of USA CSG Industry literature and reproduced in this Report. Given that
there is also widespread public disapproval of the CSG Industry in the USA, How can our
Governments adopt the existing practices of the Industry in the USA and call them the
BEST or LEADING practices? This is UNacceptable especially when our own community
groups like EDOV, DEA, NTN, and the Greens etc. have put forward proposals that
Governments have ignored.
“A hierarchy of risk control measures is a sequence of options that offer operators a number
of ways to approach the hazard control process. Using a hierarchy of control ensures that
risks are dealt with in an order of priority, where most effective risk controls are addressed
first, with less effective options considered thereafter. The higher up the hierarchy the risk
control is, the more effective the control. In some instances, the best solution may involve
more than one control. Administrative controls must be used in combination with other
controls. Risk cannot be completely eliminated from any system, but it can be mitigated by
undertaking a formal assessment of the risks inherent in the system and determining how
they can be minimised to be as low as reasonably practicable while simultaneously meeting
community expectations.”
We appreciate that there is an element of risk in all aspects of life. However, there is a big
difference between deciding to cross the road and deciding to facilitate the development of
the CSG Industry. This Industry is in its infancy and acknowledges (especially in Chapters
5 & 6) that there are many unknowns that need to be identified and dealt with as best as
possible during exploration and production works. The environmental and social
degradation associated with the CSG Industry is clearly UNacceptable to the Australian
public. Why are Governments and the CSG Industry so reluctant to acknowledge/decide
that some risks are NOT worth taking? – especially those risks at the BOTTOM of your
“hierarchy of risk control” ie. those risks that cannot be minimised or prevented like
contamination of land, water and people’s health with chemicals used, stored in holding
ponds and mountains of salt and released by the CSG Industry.
“The primary objective of verifying key system elements is to improve the accountability of
the operator, which will improve legal enforceability by the regulator. Verification should be
undertaken by a qualified professional who is able to certify that the relevant model, plan,
construction, deployment, or other requirement is fit for purpose, has been developed by a
qualified professional, and meets work health and safety and environmental objectives. The
verifying individual may be a suitable senior in-house representative or independent thirdparty professional. The essential outcome is that the authorised person is able to meet the
primary objective of improving accountability.”
It is the Governments role to improve accountability of the CSG Industry. A literature
search will quickly show that this is an irresponsible Industry that does everything it can to
not be accountable for the problems it causes. On this basis/test alone, the CSG Industry
should not be able to develop in Australia at all. Governments’ requirements for
Environmental Impact Statements and Management Plans have already shown themselves
to be ineffective in providing the protections that are needed mainly due to the ways they
are got around by companies.
“As new problems emerge and new solutions are developed, or better solutions are devised
for existing problems, it is important that leading practice be flexible in developing solutions
that meet site-specific requirements. While recognising that companies, including CSG
operators, must meet legislative requirements, leading practice also expects them to go
beyond the minimum.”
The Report promotes applied learning on the job in response to new and unanticipated
problems that are expected with the CSG Industry. Surely, critical decision making means
that we can decide NOT to proceed with some land and water uses (ie. the CSG Industry)
41
in the interests of social and environmental protection.
“The environmental impact assessment can also be undertaken bilaterally with the
Commonwealth and, where legislation allows, can also incorporate community and
stakeholder views in the assessment and decision-making process. A key function of
bilateral agreements is to reduce duplication of environmental assessment and regulation
between the Commonwealth and the states and territories. Bilateral agreements allow the
Commonwealth to ‘accredit’ particular state or territory assessment processes and, in some
cases, state or territory approval decisions. In effect, bilateral agreements allow the
Commonwealth to delegate to the states and territories the responsibility for conducting
environmental assessments under the Commonwealth Environment Protection and
Biodiversity Conservation Act (EPBC Act) and in certain circumstances, the responsibility
for granting environmental approvals under the EPBC Act. Bilateral agreements may also
deal with various other matters, such as management plans for World Heritage properties
and cooperation on monitoring and enforcement. To be accredited, a state or territory
process will need to meet ‘best practice’ criteria. If a proposed project is covered by an
assessment bilateral, then it is assessed under the accredited state or territory process.
After assessment, the project still requires approval under the EPBC Act.”
It seems that Governments are willing to pass on their responsibilities. This is
UNacceptable and demonstrates again the lack of respect that the CSG Industries pays to
its legal regulatory requirements. This is another way in which Governments are complicit
with Industry in removing what to the public are PROTECTIONS and what to the CSG
Industry is Red Tape.
The list of weblinks at the end of our submission provides evidence of various accidents and
concerns about the CSG Industry. They demonstrate the lack of willingness and inability of
Governments and of the CSG Industry to:
 show good faith
 respect individuals, communities, non-government organisations and the Australian
public
 be honest and open about the Industry’s impact on existing land uses, water
contamination etc
 be honest about its social impacts especially UNemployment, business downturn,
property devaluations, reductions in Council rateable income etc.
 report incidents to Governments or to the public
 be honest with their self assessments, EISs, EMPs etc
 be open and transparent about the problems of the CSG Industry and its inability to
redress problems to the public’s satisfaction
 build public trust and confidence; and
 abide by the Moratorium – lots of transport infrastructure associated with the Industry
(eg. roads and ports) has continued to be built, Gina Rinehart has recently
purchased 18% of Lakes Oil and said that she ‘is happy with the location of the
resources as they are close to processing plant in Yallourn’, the Victorian
Government recently extended all Victorian Exploration Licenses for 12 months to
‘make up for’ the Moratorium, Mantle Mining has talked up its assets to shareholders
in its last Annual Report based on the number of wells it EXPECTS to have. This
shows a complete lack of good will on the part of both Governments and the CSG
Industry.
Legislation “requirements” as stated at the beginning of this report depend on the
willingness of the CSG Industry to adopt best global practice at a minimum. These
“requirements” need to be CONDITIONS of license. So much legislation will remain
ineffective if NOT backed up by a robust regulatory body with sufficient resources and
42
authorities/powers to intervene as and when needed by the public and to order stringent
compliances.
The CSG Industry builds an extensive boundary around itself to exclude community scrutiny
eg. Doubtful Creek, NSW where the State Forest has been closed to the public. Further,
the current focus of business on removing red tape etc. in this country is also a means of
avoiding regulation and so called “interference” from government on behalf of the public in
the way companies carry out and are accountable for the negative impacts of their
businesses. Reliance on practices currently in use in the CSG Industry in QLD & NSW
does not encourage confidence either, especially when they are instituted under such
names as the “(NSW) Aquifer Interference Policy, which requires applicants to address
potential water impacts (including aquifer compaction, deterioration of ambient water quality
and significant soil erosion).” This is yet another admission by Governments that these
problems are inherent with the CSG Industry. These are exactly the problems that the
public does NOT want to risk occurring.
VERIFICATION ie. A TICK THE BOX APPROACH
Verification requirements are another admission that the CSG Industry cannot be trusted.
While this paperwork approach is extensive and may be laborious and frustrating for the
CSG Industry, it is separate from what happens on site. Regulators need to be active in the
field with communities listening to their concerns and evidence and supporting the public in
its endeavours to investigate and expose the CSG Industry for its Unacceptable impacts.
Will Governments ensure this happens instead of the simple paperwork approach as
outlined in the Report eg:
“While not always expressly required in jurisdictions’ legislation, conditions may be imposed
on CSG projects, which require the certification of CSG processes. In many cases,
approvals are not granted by regulators until specific risk assessments are undertaken and
submitted to the relevant authority. By way of example, in Queensland a hydraulic
fracturing risk assessment is required which outlines key elements of the program. A
completion notice must also be lodged within ten days of finishing hydraulic fracturing
activities. Similar requirements apply in New South Wales under the Code of Practice for
Coal Seam Gas: Fracture Stimulation Activities (NSW DTI, 2012b). South Australia’s
activity notification must provide detailed activity information, including an assessment that
indicates that a facility, equipment or management system used in drilling, production or
pipeline activity is fit for purpose. The licensee must ensure the information contained in the
report is accurate. Similarly, in the Northern Territory, under the Schedule of Requirements,
the construction, alteration or reconstruction of drilling and production equipment must not
be undertaken without approval (NT, DME, 2012). Where required, a verifying body may be
required to verify the design, construction and installation of petroleum facilities.”
Chapter 3 – Well Integrity
NO amount of Regulation will ensure CSG Well integrity or make CSG Wells safe! The only
way to adequately address this issue is to BAN the CSG Industry in Australia.
We are concerned that Australia's legislative approach to well integrity seems to be solely
based on advice from mining companies (through USA Industry literature searches and
43
through Mining representatives on the IESP). This may be primarily in the interests of the
companies and secondarily in the interest of the environment and communities. This would
make enforcement of CSG regulations difficult as no completely independent assessments
of 'Best Practice' has been made. Ground water assets can only be protected by calling for
an independent, extensive inquiry into the impacts of CSG operations.
We do not believe that compliance by the industry is assured, as the qualified regulator may
not be independent from the mining company.
Gippsland, like Roma and the Hunter Valley etc. is one of the main farming areas in the
country, producing food worth more than $1.3 billion per annum. Our agricultural industry is
vast and also has a large component of organic farmers. This sector of the agribusiness is
particularly vulnerable to any impact by the CSG Industry. They will have their organic
certification revoked if contamination occurs on their farms. Similarly, other producers are
responsible for the quality of the food they sell as well as the quality/condition of their soils
and water supplies. This is now at great risk from the CSG Industry operations. The Report
states that 'impacts can be minimised'. This is another admission by Governments and the
CSG Industry that accidental contamination of the environment is likely– a risk to the
livelihoods and lifestyles of individuals and communities that we are NOT willing to take.
Given the importance of the organic producer's certification, it is imperative that proper
protocols are in place. These include wash down protocols for contractors operating on the
property. Brought in materials, vehicles and equipment must be free of contaminants. See
Guidelines for organic producers and resource development companies in Queensland,
Queensland Department of Agriculture, Fisheries and Forestry. These conditions may
seem onerous for the CSG Industry (more Red Tape) and so, unlikely to be implemented
successfully. This is another reason why we do not believe that many existing land uses,
including agriculture, can coexist with the CSG Industry. The Industry is in direct
opposition to these sorts of land uses especially when the propensity for a failure of well
integrity and so contamination of water systems, soils and food products is highly probable.
The construction and maintenance of wells is to be audited by the CSG Company and the
regulator. We do not see either of these parties as able to be impartial and /or adhere to
strict codes of practice. The mining company will try to balance 'Best Practice' with
profitability, which may compromise the quality of products and expertise used. The
regulator only does 'spot checks' and in this manner cannot guarantee the integrity of any
well.
The Report makes no mention of lateral drilling. How does lateral drilling affect well
integrity? Lateral drilling is planned for ECI Exploration and Mining in association with CFT
Energy Ltd. CFT have existing coal seam gas projects in China, where they are operating
under a joint venture with the state owned Heilongjang Longmay Coal Company. ECI have
been granted 7 exploration licences for Coal Seam Gas across South Gippsland. The EPA
took ECI to court in 2006. The company was charged with “permitting an environmental
hazard” at Campbellfield in 2004. They were ordered to pay a $15,000 sum to Merri Creek
Management Committee for the public benefit. This is NOT adequate. Why are
CSG/Mining companies with a poor track record for social and environmental impacts
allowed to continue to operate by Governments? This needs to be a test that the Industry
must pass as part of the question of whether or not the CSG Industry can operate in
Australia. WE need to identify those risks that we do NOT want to take in Australia in order
to provide our social and environmental protections.
The decommissioning of CSG wells is problematic, as it has been proven that these wells,
over time, do leak and are not checked frequently enough or at all to maintain integrity.
44
Wells remain permanently after decommissioning ie. they are abandoned. There are
examples of wells in the US decommissioned in the 1930’s that are still leaking now and of
leaking gas fields in Australia. Horizontal wells appear to leak the most. Much of the
technology for CSG mining comes from the USA, where all CSG wells, even those that
have been decommissioned/abandoned, leak methane and other gases into our
atmosphere and the industry can’t do anything about it – as is happening in Australia too.
This has devastating consequences for our greenhouse gas emissions and so climate
change. See the Documentary “The Sky is Pink” by Josh Fox.
http://www.zcommunications.org/abandoned-oil-and-gas-wells-are-leaking-by-steven-kotler.
http://www.resilience.org/stories/2013-01-10/shale-gas-how-often-do-fracked-wells-leak;
http://www.smh.com.au/environment/climate-change/methane-leaking-from-coal-seam-gasfield-testing-shows-20121114-29c9m.html; http://energysurprises.blogspot.com.au/2013/01/worried-about-gas-wells-leaking-methane.html;
Cement used to cap decommissioned wells cannot last indefinitely and consequently will
crack and break down. As a 'line of least resistance' is created on initial drilling, gas, toxic
water and chemicals will be released in an uncontrolled manner at some future date when
the cement degrades and the earth moves. This is UNacceptable.
In particular seismic activity is a major factor in destabilizing cement in capped wells.
South Gippsland, has a history of increased seismic activity, which may be attributable to
the continual expansion of massive open cut mining operations in the Latrobe Valley and
elsewhere in Australia. Seismic activity has increased in South Gippsland what affect will
this have on well integrity? The latest and biggest earthquake was in Moe 19th June 2012.
Are the increased seismic activity manmade. See ‘Hydrocarbon extraction and
Earthquakes’ at the end of our Submission.
http://www.abc.net.au/local/stories/2012/11/20/3636396.htm?site=gippsland
When referring to Coal Seam Gas induced earthquakes, Rick Beck states: “Any time
fractures in rock are generated or deformed, the existing stress state in the rock changes
and some seismic activity occurs...if the vibrations are large enough some built structures
can be damaged.” Beck Engineering Pty Ltd Sydney. In circumstances as this well
integrity would surely fail.
The micro seismic activity in CSG mining may induce larger events that could, in turn,
cause failure of structures and compromise well integrity.
Independence of the well Supervisor is crucial to the proper and safe development of the
well. Independence cannot be achieved if the Supervisor is paid by the project proponent as
profits may be balanced against the use of best quality materials causing inferior products
to be used, in particular cement quality. Critical aspects of construction may not be
sufficiently scrutinised.
A blow out of a well would be a disastrous event, not only to the CSG operators, but also
the surrounding environment and local communities. We believe that communities cannot
tolerate this risk as their income and health would be at stake.
We cannot ascertain from the Report exactly how a blow out will affect well integrity. As
the Report states ‘blow outs are a major safety hazard, Blow out preventers (BOP) are
often used, but if there is any vulnerability in the well casing and cement there can be a
failure of well integrity.” We are not told what effect the BOP will have, in a blow out, on
any sub-surface pressures.
http://www.couriermail.com.au/business/farmers-demand-coal-seam-gas-ban-after-wellblowout-near- dalby/story-e6freqmx-1226061392597
45
Self regulation by mining companies is not conducive to 'best practice' and will be of little
benefit in risk mitigation.
Much of the information has come from mining company’s Best leading practices form American
Petroleum Institute’s guidance document Hydraulic Fracturing Operations – Well Construction and
Integrity Guidelines (API 2009). Most of the 'best practices' included in the Report have been
put forward by the mining industry and the American Petroleum Institute. As such, they
have no independent scientific input.
http://www.nsw.gov.au/sites/default/files/uploads/common/CSG-wellintegrity SD v01.pdf
We feel it is incumbent on government to assess CSG well integrity in the light of
independent science.
The Report puts forward the notion that with stringent regulation, strong governance and
robust safety practices, any issues associated with well integrity will be mitigated. This
assumption is based on the expertise and experience of the well Supervisor. The draft
recommends an independent supervisor. Who pays for the supervisor? If the mining company pays
then the supervisor is not independent. Perhaps a fund that mining companies contribute to could
pay the supervisors which are randomly allocated to projects.
Chapter 4 – Water Management and Monitoring
NO amount of Regulation Management and Monitoring will keep our water resources and
supplies safe from the CSG Industry. The only way to adequately address this issue is to
BAN the CSG Industry in Australia .
Governments have recognised that the community has serious concerns about depletion
and contamination of water resources in conjunction with CSG production. In response to
this the Federal Government has established the Independent Expert Scientific
Committee (IESP) to assess Coal Seam Gas projects.
It has been revealed that four out of the six members on the committee have financial links
to CSG mining. (Australian Broadcasting Corporation: Lateline: 01/08/2012). We see a
potential conflict of interest and question the independence and expertise of this
committee.
Reinjection of co-produced water into aquifers and aquitards would be hazardous as little
research has been done on the effects of this on ground water. How are the users of
ground water affected - wild life, agricultural activities and the human population?
Co-produced water resulting from depressurisation of the coal seam is usually highly
saline, contaminated and cannot be re-used unless treated. We question what processes
would be used. Reverse osmosis? – this would leave huge residues of salt and other
contaminants. Where would this brine be dumped/disposed of? It is known in the USA
that 'frack water', with it's load of chemicals and salt can destroy filters and make this
method unreliable. How much salt are we talking about exactly?
www.keepthescenicrimscenic.com/coal-seam-gas-information.php
http://www.abc.net.au/news/specials/coal-seam-gas-by-the-numbers/ (
Regarding the diagram 4.1 showing the drop off of water used after initial fracking after gas
production diminishes, further fracking is often needed. No mention is made of this
secondary, increased use of water.
46
The concept of the beneficial use of treated co-produced water is untenable. Our food
industries ie. dairy, grazing, crop, biodynamic/organics etc. are totally reliant on our pristine
water catchments and supplies. The domestic and international market perceptions of
goods being sourced from areas that have some of the cleanest water in Australia/the
world, will be seriously damaged if water that has been HIGHLY CONTAMINATED by the
CSG Industry and then recycled/treated is to be used.
Reinjecting treated toxic wastewater into aquifers can potentially create a host of problems.
It can be a trigger for seismic activity. Gippsland and other areas are already prone to
such events.
Improperly treated reinjected water will cause lasting contamination of aquifers.
At the Senate inquiry at Narrabri 03/08/2011, it was admitted by the Australian
Petroleum Production and Exploration Association that “Drilling will, to varying degrees,
impact on adjoining aquifers. The extent of the impact and whether the impact can be
managed is the question.” This statement confirms the view that serious and
insurmountable difficulties are inherent in the management of CSG contaminated waste
water.
When the reduction of the water table occurs, due to the CSG process of dewatering,
farmers and other land users, who use this water via bores and spring fed dams, may have
insufficient water for their enterprises. They will have to pay for more dams, deeper bores or
purchase recycled water from the mining company. This is an unfair cost and imposition
on farmers and other land users. It is unfair that people, in areas of fresh, clean, natural
water, are, potentially expected to drink treated toxic water.
The Report does not mention How this toxic, ‘co-produced’ water will be treated. We know
that water brought up from a deep coal seem, through depressurisation, has varying
concentrations of heavy metals and radioactive substances. How are these to be removed?
It is unconscionable that Governments would allow populations any degree of exposure to
these carcinogenic substances resulting from contamination of our water resources by the
CSG Industry.
The National Water Commission is concerned that “CSG development represents a
substantial risk to sustainable water management.”
We agree that base line measurements must be taken. However, they must be undertaken
independently from CSG Companies. Only in this way will readings be indisputable.
We do NOT support self monitoring by CSG operators.. The public is the best and most
capable resource that we have for monitoring the CSG Industry. CSG Operators are also
required to 'immediately report' any contaminants in water sources. However, there is a lot
of evidence that mining companies are very tardy in reporting any spills. For example, a
benzene leak in Longford went unreported until locals became ill and took action.
http//www.weeklytimesnow.com.au/article/2012/12/18/553798latest-news.html benzine leak
at Longford Nov 2012
http//www.abc.net.au/news/2012-97-07/epa-fines-csg-explorer-over-polluted-water/4116404
When a complaint is made by the public, it is the practice of the EPA to advise the
CSG/Mining company of an inspection. In most instances, the problems are resolved
before the EPA arrives. However, when operators are not advised of an inspection and a
spot check is done, breaches are identified by the EPA.
47
http://www.abc.net.au/news/2011-11-24/the-promise-of-coal-seam-gas/3668268 (see who
regulates the Coal Seam Gas Industry)
So-called ‘co-produced’ water needs to be accounted for and managed. However, we
question who is responsible for taking base line readings and doing ongoing monitoring,
investigations and assessments. Again, the document does not identify an independent
body to carry this out. We believe the public is best placed to do this.
We believe that 'beneficial use' of recycled CSG water is a misnomer. There can be no
beneficial use of natural water resources that we allow to become contaminated and then
treated for social and environmental uses. What happens to the contaminants once the
water is treated? How and Where are they stored and disposed of? For example, huge
mountains of contaminated salt is a byproduct of the CSG Industry’s water usage. The
Report does NOT mention How this salt could be decontaminated, safely stored or used.
What is the situation regarding contaminated salt?
If co-produced water cannot be recycled, it can be disposed of with the approval of the
relevant body. Will this be into our soils, rivers and streams so that the treated toxic water
will drain into our water catchments and oceans?
The Report suggests Governments should look towards international leading practices such
as that applied by the USA, specifically the United States Underground Injection Control
Program. The subject of reinjection is highly controversial and requires significant
independent scientific study. We cannot allow advice from the USA CSG/Mining Industry to
be applied without carrying out our own rigorous independent and scientific research.
The CSG/Mining Industry and Governments’ Regulatory bodies like the EPA, are slow to
respond to leaks and problems reported by the community, as happened with the benzene
leak at Longford in November 2012 and Blowouts in NSW:
http://www.weeklytimesnow.com.au/article/2012/12/18/553798_latest-news.html
http://www.kateausburn.com/2011/08/10/nsw-govt-issues-agl-with-a-formal-warning-aftercoal-seam-gas-well-blow-out/#.URDEm6VJ7zp
http://www.abc.net.au/news/2011-11-24/the-promise-of-coal-seam-gas/3668268 (See Who
Regulates the Coal Seam Gas Industry)
Containment ponds – have been proven to leak and contaminate surrounding land and
surface waterways and underground water systems. Recent flooding in Queensland has
shown containment ponds merging with rivers.
Chapter 5 – Hydraulic Fracturing
NO amount of Regulation will make Hydraulic Fracturing safe! The only way to adequately
address this issue is to BAN Hydraulic Fracturing and the CSG Industry in Australia.
Governments, Regulators (like the DPI and EPA) and the CSG/Mining Industry are unable
to ensure safe operation of the older technologies of open cut Coal Mining. They will NOT
be able to Regulate the relatively newer technologies of the CSG Industry (including shale
and tight gas).
See: November 2007 the Yallourn Mine batter failure when 2 billion litres of water flooded
the Yallourn Mine due to the discontinuation of essential drainage works in the eastern
section of the mine – without the legally required permits and the subsequent Yallourn Mine
Batter Failure Inquiry report presented to Government in June 2008 - “As identified by the
48
Mining Warden, the fundamental cause of the mine batter failure was a lack of sufficient
expertise within the mining industry, both within the mine operator and external to the mine
operator, to interpret the available information to TRUenergy. Insufficient geotechnical and
hydrogeological expertise is a symptom of a global skills shortage in these professions. In
considering how to best address this problem, Governments agree with the key findings of
the Mining Warden to enhance and supplement processes and procedures to respond to
the changing environment and address the information gaps resulting from the skills
shortage in the mining sector. Such information gaps, if left unremedied, may lead to
significant adverse environmental, social or economic outcomes.”
In 2011 the Hazlewood coal mine leaked under the Princes Freeway (Australia’s main
highway) resulting in it’s closure for 7 months. Yet again, the Yallourn Mine flooded in
2012. The other regulatory body, the E.P.A. then allowed the contaminated water from both
the flooded open cut coal mine incidents to be pumped into nearby rivers.
Another incident highlighting lack of regulations is a quote from the Age newspaper on
21/2/2013 which also mentions the explosion in 1998 when 2 people were killed: “AN
INVESTIGATION has been launched after the Longford gas plant in Gippsland suffered two
serious leaks last weekend and a worker was injured. Areas of the plant, where a huge
explosion killed two workers in 1998, were evacuated after a leak in a high-pressure
underground pipe just after 6pm on November 6. Natural gas again escaped into the
atmosphere as workers dealt with the pipe rupture later that night. As a result of the leaks,
20-metre-high plumes of flame lit up the sky around Sale as excess gas was burnt off.”
Read more: http://www.theage.com.au/national/longford-plant-gas-leaks-spark-worksafeinquiry-20091114-ifo0.html#ixzz2LRsBXfwS”
Chapter 6 – Chemical Use
Again, NO amount of Regulation will make the chemicals used in Hydraulic Fracturing and
released by the CSG Industry safe! The only way to adequately address this
CONTAMINATION is to BAN the CSG Industry in Australia and at the very minimum to BAN
Hydraulic Fracturing in Australia.
The Report has a very limited discussion of chemical additives used in the CSG Industry. In
addition to this, naturally occurring, but toxic, chemicals and substances are released into
our underground and surface water systems and soils by the inherent activities of the CSG
Industry. However, these are not acknowledged or discussed.
The Report admits that the CSG Industry has NOT disclosed many of the chemical
additives it uses, their quantities or their combinations . Governments, in all the time that
the CSG Industry has existed, have been remiss in not requiring the CSG Industry to make
these disclosures. Governments and the CSG Industry are and will NOT be open,
transparent and show good faith about this in the future. They argue, and will continue to
do so, against doing this because of proprietary confidentiality. This is UNacceptable and
contradictory. How can Governments regulate something that they haven’t identified, let
alone understood?
The very limited information we have about the chemicals used and released by the CSG
Industry come from community groups. Only through public concern, investigations and
testings, have we obtained this information. However Governments and the CSG Industry
treat these activities of communities/the public as ‘interferring’ and a ‘nuisance’. This is
UNacceptable. Again, the community/public are the best resource we have to ensure
informed, educated, knowledgable, expert, scientific, experienced, factual and responsive
debate, monitoring and evaluation of the CSG Industry. Again, based on this, we have
decided that we do NOT want the CSG Industry in Australia.
49
The Senate Inquiry recommended that the Commonwealth fund a review of the chemicals
used by the CSG, shale and tight gas Industries to be completed within 2 years. Although
there is public support for this, Governments and the Report have not taken up and do not
plan to implement this review.
See our comments above about Salt, Water contamination and soil contamination. Also
See the list of Chemicals used and released by the CSG Industry at the end of our
Submission.
Other issues
The Report uses NSW and Queensland operations as examples of 'leading practice' or 'best practice'
when there is considerable evidence that NSW and Qld operators are not currently applying 'leading
practice' nor 'best practice' to the management of existing CSG wells in those states. See our weblinks at
the end of our Submission regarding accidents and community concerns.
Extreme danger of cross contamination by vehicles moving between agricultural properties. If, heaven
forbid, something like foot & mouth ever came to Australia, could CSG wells be safely closed down, at
very short notice, until danger has abated? For example, the .Perth Basin is now experiencing a
contagious fungal disease 'phytophthora cinnamomi' (dieback) - single cause - vehicle movement between
tight gas sites.
Who pays carbon tax on leaking CSG wells?
Methane is currently leaking from 50% of wells in WA.
Abandoned CSG wells - integrity of bore casing cannot be guaranteed into the future - corrodes in saline
water and can have a lifespan of only 8 years. Who is responsible for monitoring, making good, repairing
natural damage (ie. caused over time, during earthquakes/seismic activity, during bushfires, floods,
cyclones, twisters or storms) to abandoned CSG wells and paying carbon tax on leaking abandoned CSG
wells? Who monitors robustness of CSG well cores during seismic activity?
Land clearance for easements for vehicle access can fragment eco systems to point of collapse. Clearance
of native vegetation - fauna habitat. Carbon released from destroyed trees. NOISE
If government regulators accept Industry reports will the legal liability shift to the government ie. the
public for any problems? What resources will the regulating body have to ensure that all matters are
investigated thoroughly and immediately? What penalties will the Industry be faced with in the event of
problems? A distinction is made between the Licensee and the drilling contractor. Who is responsible for
problems that occur? There is a shift in responsibility/blame from the Industry to Government Regulators
and to Contractors. This will not help. The Industry will self monitor in the main with some
responsibilities being moved to a 3rd party who is independent and qualified. This will shift the
legal/liability responsibility/onus/blame to this 3rd party.
Will best global practice prevent these problems from occurring
The answer is No! The report acknowledges that problems will still occur. These problems will be
addressed by “continuous improvements”, applied learning”. The community is being asked to agree to
an industry which is in its infancy and whose technology and methods are still in their infancy and may
have various impacts at different locations.
CSG Industry’s carbon footprint
50
The CSG/Mining/APPEA Industry recently attempted to lower Australia’s Renewable Energy Target
(RET) of 20% by 2020 on the basis that we have almost achieved that target already;
CONCLUSION
By its omissions, limitations, misrepresentations and regulatory approach, the Report has tried
to shape and direct community input to support Governments’ management of the CSG
Industry. We do NOT support the MLUF or the Regulatory Framework. As Bob Wilson has
reported, the Senate Inquiry criticised Governments handling of the CSG Industry. It says that
Governments’ approvals for CSG Industry developments were “given prematurely”, and that ‘the
pace of the CSG Industry’s development is too far ahead of scientific investigation into its lasting
impacts’. It also says that ‘attempts by Governments to regulate the CSG Industry are not
keeping pace with the Industry’s development’. In fact the CSG Industry continues to operate
without a full and comprehensive understanding of its impacts while the Moratorium is in place
for only NEW licenses.
The CSG Industry is inherently UNable to be socially or environmentally safe. It represents
UNacceptable social and environmental risks. The only way to adequately address this matter
is to BAN the CSG Industry in Australia.
We believe that it is now up to our Governments to reject and ban the CSG (and other
unconventional gas) Industries as well as New Coal Mining. At the very minimum, Governments
should ban all fracking due to its UNacceptable high social and environmental risks/costs and
stop all means of legal privileged treatment of the CSG/Mining Industry over individuals and the
public (as per the EDOV’s recommended legislative changes).
The SCER and Governments now have an opportunity to make the difficult but necessary
decision to abandon the CSG Industry in Australia. Governments have previously made similar
decisions about other out dated industries like Petroleum (to remove lead), Refrigeration and Air
Conditioners (to remove CFCs), Asbestos (to stop its use), Tobacco (to stop promotion of
smoking and harmful additives).
We are still suffering the social, environmental and economic consequences of having endured
the development and growth of these harmful Industries/Industrial processes. Let’s act now to
avoid making the same mistake with the CSG (including shale and tight gas) and New Coal
Mining Industries. We do not want or need another story of toxic contamination for generations
to come.
This is also an opportunity for Governments to institute widespread Energy Conservation and to
transition to Renewable Sources of Energy Supply. Germany, with its large manufacturing
economy, has already done this – so, why can’t we?
We would very much like to see some goodwill on the part of our Governments regarding this
consultation process. We are hopeful that the public submissions of individuals and groups to
the MLUF and SCER Framework Report will NOT be ignored for financial or any other reasons,
as has happened with other community consultation processes like the Greenfield Report.
We do not want any more empty reassurances from Governments. We look forward to the
SCER’s and Governments response.
OTHER QUESTIONS THAT WE ARE CURRENTLY INVESTIGATING
The Industry keeps saying that CSG etc. is NOT Mining. Is this a tactic to exclude these
Industries from paying the new Mining Tax?
Can our current civil rights to prevent Trespass on our land be planned out of existence under
the MLUF?
Are there current Section 32 responsibilities in Victoria (and in other State’s Regulations) to
51
declare that your property is under a Coal and/or CSG Exploration Licence when attempting to
sell?
WEBLINKS to some of our reputable sources of information and advice
http://coalseamgasnews.org/wp-content/uploads/2012/10/Contaminated-sites-and-accidents-relatedspecifically-to-CSG-in-Australia.pdf (See this Report at the end of our Submission)
Media
http://www.hotspotting.com.au/article/2269-csg-sparks-biggest-land-rights-debate-since-mabo
http://www.centraltelegraph.com.au/news/farmers-make-stand/607589/
http://echonetdaily.echo.net.au/csg-health-study-critical
http://echonetdaily.echo.net.au/warning-csg-bad-for-health/
http://www.theage.com.au/environment/climate-change/the-top-of-the-world-is-melting20121127-2a5ne.html
http://www.abc.net.au/news/2012-12-21/esso-under-investigation-over-longford-oilspill/4439606?section=business
Calls for Higher Scrutiny, Rural News, The Gippsland Farmer, Louis Nelson, November 2012 p3
http://indymedia.org.au/2012/11/16/climate-change-implications-of-new-study-on-methaneemissions-in-coal-seam-gas-field
http://www.greenleft.org.au/node/53313
National Toxics Network
http://www.ntn.org.au/wp/wp-content/uploads/2013/02/NTN-Toxics-in-UG-Activities-Briefing.pdf
(See this Report at the end of our Submission)
http://www.ntn.org.au/featured/global-chemicals-outlook-urgent-action-needed
http://www.ntn.org.au/stop-csg/coalition-rejects-fracking
http://www.ntn.org.au/stop-csg/why-donate-to-us (Article - Natural gas not so Natural After all)
http://www.ntn.org.au/stop-csg/call-for-moratorium-as-report-finds-fracking-chemicals-havenever-been-tested-for-safety-2
http://www.ntn.org.au/
Doctors for the Environment, Australia
http://dea.org.au/
http://dea.org.au/news/article/fight-for-the-tarkine
http://dea.org.au/news/article/shell-breaks-its-10-year-promise-not-to-develop-world-heritagesites
http://dea.org.au/images/general/Unconventional_%28CSG-Shale%29_Gas_DEA.pdf (See this
Report at the end of our Submission)
http://dea.org.au/images/general/viewpoint_issue_8_CSG.pdf (See this Report at the end of our
Submission)
http://dea.org.au/topics/article/briefing_paper_on_the_health_aspects_of_coal_and_renewables
(See this Report at the end of our Submission)
http://dea.org.au/topics/article/unconventional-gas-csg-shale-gas-mining-and-health-information
http://dea.org.au/images/general/DEA_CSG_Draft_Policy_-_7-2-12.pdf (Draft Policy Statement
on Coal Seam Gas Extraction and Health (Feb 2012)
http://dea.org.au/images/general/Gas_and_Health_Report_01-2012.pdf (Gas a a replacement
fossil fuel – Discussion Paper on the health aspects of gas (Jan 2012)
http://dea.org.au/news/article/media-release-dea-ntn-15-11-2012-coal-seam-gas-pollution
http://dea.org.au/resources/file/csg_undermining_our_food_bowls_dr_helen_redmond
http://dea.org.au/resources/file/dea_at_gas_forum_in_sydney_dr_helen_redmond
http://dea.org.au/resources/file/dr_helen_redmond_on_health_and_coal_seam_gas_extraction
http://dea.org.au/images/general/Gas_and_Health_Report_01-2012.pdf (Gas as a
Replacement fuel – Discussion paper on the healts aspects of gas)
52
Environmental Defenders Office Victoria
http://edovic.org.au
http://edovic.org.au/news/time-protect-environment-and-communities-from-fossil-fuel-mining
http://edovic.org.au/downloads/files/law_reform/EDO_Reforming_Mining_Law_in_Victoria.pdf
http://edovic.org.au/news/new-victorian-red-tape-commissioner
http://edovic.org.au/in-the-media/coags-green-tape-agenda-undemocratic
http://edovic.org.au/in-the-media/urgent-intervention-lawyers-halt-gillards-weakeningenvironment-laws
http://edovic.org.au/in-the-media/hypocrisy-baillieus-green-vision
http://edovic.org.au/in-the-media/concern-over-coal-seam-gas-grows
http://edovic.org.au/news/pressure-builds-coal-and-coal-seam-gas
http://edovic.org.au/news/vic-government-shakes-up-planning-zones
http://edovic.org.au/in-the-media/dpi-urged-come-clean-csg
http://edovic.org.au/in-the-media/south-gippsland-community-determined-lock-gate-csg
http://edovic.org.au/news/bill-strip-back-planning-rights-hits-parliament
http://edovic.org.au/in-the-media/please-explain-urged-over-csg-impacts
http://edovic.org.au/in-the-media/mining-laws-too-lax-environment-report
http://edovic.org.au/news/report-finds-victorian-government-ignoring-key-environmental-laws
http://edovic.org.au/blog/audit-general-strongly-critical-government-oversight-environmentallaws
http://edovic.org.au/blog/defend-environmental-laws
http://www.edovic.org.au/coal-and-coal-seam-gas-mining-victoria
Community over Mining
http://www.communityovermining.org/index.html See the CSG - What’s at Risk leaflet
http://www.communityovermining.org/CSG-total-fire-bans.html
http://www.communityovermining.org/Esso-Longford-Incidents.html
http://www.communityovermining.org/Esso.html
GetUP
http://www.getup.org.au/campaigns/coal-seam-gas/csg-ad-petition/dont-risk-coal-seam-gas
Lock the Gate Gippsland
www.lockthegategippsland.com
Lock the Gate Alliance
www.lockthegate.org.au
Friends of the Earth - Quit Coal campaign
www.foe.org.au
www.quitcoal.org.au
DPI – Earth Resources
(for Maps of CSG, shale and tight gas and New Coal Mining Licenses)
http://www.dpi.vic.gov.au/earth-resources
Senate Inquiry, Bill Heffernan
http://www.parliament.nsw.gov.au/Prod/parlment/committee.nsf/0/318a94f2301a0b2fca2579f10
01419e5/$FILE/120501%20Media%20release.pdf
http://www.reuters.com/article/2011/11/30/australia-gas-inquiry-idUSL4E7MU0CK20111130
http://www.theaustralian.com.au/national-affairs/mps-demand-controls-on-coal-seam-gasrush/story-fnaxx2sv-1226210700952
53
NSW Inquiry
http://www.parliament.nsw.gov.au/Prod/parlment/committee.nsf/0/1a5ec21b249c5e49ca25791f0
0045cee/$FILE/Submission%200642.pdf
http://www.parliament.nsw.gov.au/Prod/parlment/committee.nsf/0/29AE48525CFAEA7CCA2578
E3001ABD1C
http://www.parliament.nsw.gov.au/Prod/parlment/committee.nsf/0/318a94f2301a0b2fca2579f10
01419e5/$FILE/120501%20Media%20release.pdf (The NSW Inquiry Report)
APPEA
www.appea.com.au
Mantle Mining
www.mantleming.com
Lakes Oil
www.lakesoil.com.au
ARTICLE 1
CONTAMINATED SITES AND ACCIDENTS RELATED SPECIFICALLY TO CSG/LNG
IN AUSTRALIA
1|Page
1. September 12, 2012 – Gas Company illegally emitting acid rain compounds for 3 years - AGL
http://au.news.yahoo.com/video/national/watch/26473248
AGL found for 3 years have been pumping 30% more Sulphur Oxide into air than environmental limits allow. Also
found to be exceeding limits for hazardous waste stored on site.
2. September 4, 2012 – Farmers and environmental groups blast new gas industry ad that claims coal seam gas
is safe for groundwater - APPEA
http://www.couriermail.com.au/news/farmers-and-environmental-groups-blast-new-gas-industry-ad-thatclaims-coal-seam-gas-is-safe-for-groundwater/story-e6freon6-1226464606972
http://www.news.com.au/breaking-news/national/csg-ad-criticised-for-false-claims/story-e6frfku91226464941206
Deceptive advertising by APPEA claims that CSG is safe for groundwater. A PRO-COAL seam gas (CSG) television
advertisement has falsely claimed Australia's national science agency believed groundwater was safe from
contamination by CSG mining, CSIRO says. The Australian Petroleum Production and Exploration Association
(APPEA) authorised the television ad that aired on Network Nine at the weekend. The ad claimed CSIRO believed
groundwater was "safe from coal seam gas" activities. CSIRO has rejected the claims. "At no time has CSIRO made
such a statement, and nor do the results of CSIRO research support such a statement," a spokesman said in a
statement.
September 4, 2012 - CSIRO wants ads pulled as coal seam gas industry claims rejected
http://www.coastaltimes.com.au/news/national/national/general/csiro-wants-ads-pulled-as-coal-seam-gasindustry-claims-rejected/2658104.aspx
3. August 20, 2012 – Dalby gas fire denial - Arrow
http://www.brisbanetimes.com.au/queensland/dalby-gas-fire-not-csg-related-arrow-energy-2012082024h5s.html
Arrow Energy says a gas fire burning on one of its properties in Queensland is under control and is not linked to
the company’s coal seam gas activities. Fire fighters were called to a grass fire at the site of Arrow’s Daandine
CSG project, west of Dalby, on the weekend. The grass fire has been put out. Arrow Energy says the gas fire is
centred on an old coal mine well, and is continuing to burn, but in a controlled, secure way.
4. July 20, 2012 - CHINCHILLA beef producer David Hubbard has seen his property impacted four times by QGC
54
spillages this year - GGC
http://qcl.farmonline.com.au/news/state/agribusiness-and-general/general/qgc-should-spill-details-not-justgas/2614696.aspx CONTAMINATED
SITES AND ACCIDENTS RELATED SPECIFICALLY
TO CSG/LNG IN AUSTRALIA
2|Page
“Drilling fluid from a QGC mining rig had twice spilled into the Condamine River, a few hundred metres from
where he accessed water for stock, and fluid also had spilled twice across a boundary fence into his paddock, he
said. The accidents, which had occurred at a neighbouring property, had taken place over a single month. While
he expressed his annoyance these incidents were occurring in the first place - a familiar story for many across
rural Queensland - Mr Hubbard said his ongoing frustration was that he was not being adequately informed by
the company about the discovery of the incidents and the follow-up investigations into the impacts. He said he
had only learnt about two of the incidents following his own initiative and questions.”
5. May 24, 2012 - Varanus gas explosion report slams Apache Energy – LNG/Apache
http://www.abc.net.au/news/2012-05-24/varanus-gas-explosion-report-released/4031146/?site=northwestwa
The report is critical of Apache, saying the company had ultimate responsibility for maintaining the site and should
have identified the risk that corrosion posed to the affected pipeline. It has described Apache's safety culture as
'middle-rank'.
6. July 20, 2012 - Corybas leak sparks alarm – Geraldton - AWE
http://au.news.yahoo.com/thewest/regional/gascoyne/a/-/news/14280202/corybas-leak-sparks-alarm/
Gas bubbling at the surface of a fracking well on The Grange farm, south of Dongara, has raised new concerns
about the environmental safety of the process. Nearby growers expressed fears about contamination of
groundwater supplies when a leak was discovered at AWE’s Corybas wellhead. AWE managing director Bruce
Clement this week confirmed the company found a gas leak on the valve of Corybas 1, which was bubbling up
through rainwater in the cellar trap. Mr Clement said the leak at the well, which was fracked at 2.51km in 2009,
was picked up during routine maintenance checks and was being fixed now.
7. July 6, 2012 – Coal seam gas blamed for health problems
http://www.abc.net.au/local/stories/2012/07/06/3540381.htm
The Australian Medical Association's incoming president in Queensland has confirmed several of its member
doctors have raised concerns that residents living near coal seam gas mining operations may be showing
symptoms of gas exposure.
8. June 19, 2012 – Metgasco fined for failure to comply - Metgasco
http://www.northernstar.com.au/story/2012/06/19/metgascos-wastewater-fine/
METGASCO has been fined $5000 by the State Government for failing to provide information about its plans to
dispose of wastewater produced by the coal seam gas extraction process. The fines were revealed on a
government web site which listed cases of "non-compliance" with the Mining Act and Petroleum (Onshore) Act. A
COAL seam gas company has disposed of more than a CONTAMINATED
SITES AND ACCIDENTS
RELATED SPECIFICALLY TO CSG/LNG IN AUSTRALIA
3|Page
million litres of dirty water at a sewage treatment plant in northern NSW, breaching the plant's licence
conditions, the NSW Environment Protection Authority says
9. June 12, 2012 - Coal seam effluent salts sewerage - Metgasco
http://www.smh.com.au/environment/coal-seam-effluent-salts-sewerage-20120611-2060v.html#ixzz1xWyBfdZU
10. May 28, 2012 - Methane Migration Affects 5 km stretch of Condamine River - Origin
http://www.abc.net.au/news/2012-05-30/claim-csg-river-leak-caught-on-video/4041298
Gas is bubbling to the surface on a five-kilometre stretch of the Condamine River near Chinchilla on the Western
55
Downs. The Queensland Government's LNG Enforcement Unit says it is investigating the claims. Mr Hutton says
while he cannot rule out naturally occurring methane, the incident is unprecedented. "The landowners say
they've never seen this happen before," he said. 'It's along quite a lengthy stretch of the river - there's very strong
bubbles coming to the surface. "This is a new phenomenon for this section of the river." Mr Hutton says the river
is close to CSG wells operated by Origin Energy.
11. May 12, 2012 – Gas leak forces suspension at QGC rig at Surat Basin - QGC
http://www.couriermail.com.au/business/gas-leak-forces-suspension-at-queensland-gas-company-rig-atsurat-basin/story-fn7kjcme-1226347929202
Gas leak forces suspension at Queensland Gas Company rig at Surat Basin-QGC. THE Queensland Gas Company
has suspended operations at one of its drilling rigs on the western Darling Downs after detecting a gas leak. A 150metre exclusion zone was established around the Surat Basin rig as a precaution late on Saturday night. The
incident occurred during drilling of the Argyle 162 well, about 25km southwest of Chinchilla, on a QGC-owned
property.
12. April 28, 2012 - CSG company spills fluid into river - QGC
http://www.smh.com.au/environment/water-issues/csg-company-spills-fluid-into-river-20120428-1xr4k.html
Drilling fluid linked to a CSG project has leaked into a Queensland river that is part of the Murray-Darling Basin.
The leak occurred when contractors for coal seam gas company QGC were drilling to run a pipeline underneath
the Condamine River in Queensland's southwest.
13. Apr 4, 2012 - Queensland reveals Condamine water quality report
http://www.abc.net.au/news/2011-11-24/chinchilla-condamine-water-quality-report/3677838
The Queensland Government has confirmed the toxicity of coal seam gas water to aquatic organisms is
assessed against environmental standards after it is released into rivers and not prior to discharge. This
approach appears to stand at odds with the approach taken by the Queensland co-ordinator-general in his
approach to contaminant guidelines when he approved the Australia Pacific Liquid Natural Gas (APLNG) project.
Environmental protection standards are set through ANZECC aquatic ecosystem guidelines. In June 2010, the
Queensland Government CONTAMINATED
SITES AND ACCIDENTS RELATED
SPECIFICALLY TO CSG/LNG IN AUSTRALIA
4|Page
granted an environmental approval allowing APLNG to discharge the equivalent of eight Olympic swimming
pools of treated coal seam gas water per day into the Condamine River south of Chinchilla. The water comes
from the company's desalination plant on the Walloons gasfield, which is part of Origin Energy and
ConocoPhillips' $35 billion coal seam gas and liquefied natural gas plant near Gladstone.
14. February 10, 2012 - Arsenic and lead found in contaminated water leak at coal seam gas drill site - Santos
http://www.smh.com.au/environment/water-issues/arsenic-and-lead-found-in-contaminated-water-leak-at-coalseam-gas-drill-site-20120209-1rx7s.html
FOUR separate leaks of polluted water have now taken place at a coal seam gas drilling site near Narrabri in
northern NSW since June, the resources company Santos confirmed. The spills of contaminated water led to the
detection last month of toxic heavy metals, including arsenic, lead and chromium, plus traces of petrochemicals
in water and earth samples taken in the Pilliga forest area. Tests last year also showed elevated levels of metals
and chemicals, though these were initially blamed on the use of chemical fertilisers on farms. The company then
conceded that an unreported spill of 10,000 litres of polluted water had taken place in June. But Santos has now
reported a series of leaks that occurred since it took over the site from Eastern Star Gas late last year. ''There have
been three subsequent, smaller leaks of water from coal seams within Eastern Star's Pilliga operations in the
weeks immediately following Santos' acquisition of the company,'' a spokesman said.
15. February 2012 – APPEA Report: LNG tank gas release – Woodside
http://www.appea.com.au/images/stories/Safety/71%20 %20lng%20tank%20gas%20release.pdf
During the installation of an LNG loading pump a significant amount of hydrocarbon gas was generated and
released to the atmosphere when the loading pump at 300C came into contact with the -1620C LNG product
within the pump well. The resultant vapour cloud engulfed the work party located on the scaffold above the LNG
56
tank. The scaffold had only one “intended” means of escape which was blocked by the vapour cloud due to the
prevailing wind direction. The work group left the scaffold and waited for the gas release to dissipate. After initial
contact and subsequent gas release the pump was lowered to normal position. There were no injuries or
immediate damage associated with this incident
16. January 14, 2012 - Coal-seam gas pollution spill went unreported - Santos
http://www.theaustralian.com.au/national-affairs/coal-seam-gas-pollution-spill-went-unreported/story-fn59niix1226244002610
COAL-SEAM gas giant Santos has admitted a company it now owns last year spilled 10,000 l of polluted waste
water in the Pilliga State Forest, in northern NSW, potentially contaminating 1.2ha of bushland.
CONTAMINATED SITES AND ACCIDENTS RELATED SPECIFICALLY TO CSG/LNG
IN AUSTRALIA
5|Page
17. Dec, 2011 – Report - AGL
http://2011.aglsustainability.com.au/index.html#/76/zoomed
A total of 53 environmental incidents at AGL operated sites were recorded in AGL’s corporate incident reporting
systems during FY2011, compared with 15 incidents recorded in FY2010. One of the incidents was rated as having
a high potential risk (the overtopping of a dam at the Downlands Facility during the Queensland floods in
December 2010). Other incidents included minor spills and leaks, administrative non-compliances and
noncompliant air emissions. In addition to environmental incidents at AGL operated sites, during FY2011, a
number of incidents occurred at the AGL-Arrow Energy Moranbah Gas Project joint venture, where Arrow
Energy is the operator. Further information can be found in the 2011 Annual Report available at
2011annualreport.agk.com.au.
18. Dec, 2011 – Qld Gov. CSG (6 monthly) Compliance Report
http://www.ehp.qld.gov.au/management/coal-seam-gas/pdf/csg-compliance-report-jan.pdf
The Queensland government reported that in only the first six months of 2011 there were forty-five CSG
compliance related incidents, including twenty-three spills of CSG water during operations, four uncontrolled
discharges of CSG water, three exceedances of discharge limits, three overflows of storage ponds, and other
incidents relating to vegetation clearing and BTEX contamination (see “Drilling Down – link on final page)
19. October 2011 – APPEA Report: LNG Pressure Vacuum breaker loss of containment – gas release
http://www.appea.com.au/images/stories/Policy_-_Safety_and_Health/incident_alerts/60__Pressure_Vacuum_breaker_loss_of_containment.pdf
A gas cloud was observed emanating from the hydrocarbon Pressure Vacuum (PV) breaker on-board a GPSO. The
PV breaker released at a lower pressure than the expected design pressure, resulting in the release of about
28,000kg of hydrocarbon gas. The cargo tanks took approximately 1.5 hours to depressurise via the PV breaker.
20. September 17, 2011 - Academics warn of looming seam-gas 'mess'
http://www.theaustralian.com.au/national-affairs/academics-warn-of-looming-seam-gas-mess/story-fn59niix1226139356296
"Dr Mudd said one of his students had recently conducted such a study of a CSG well, and found while one nearby
water bore was unaffected by the operations another 5km away suffered a "very major impact". "If a an
undergraduate student can do that in three weeks of full-time work why the hell hasn't the government done
that?" he said. A LEADING resource economist has called for restrictions on the booming coal-seam gas industry
until proper water quality and technology monitoring systems can be implemented. CONTAMINATED
SITES AND ACCIDENTS RELATED SPECIFICALLY TO CSG/LNG IN AUSTRALIA
6|Page
21. September 14 , 2011 - QLD gas well leaking - QGC
57
Gas is leaking from a five-centimetre crack in a pipe on a Queensland coal seam gas development. Queensland
Gas Company senior vice-president Jim Knudsen said the leak was not dangerous and an exclusion zone had been
set up while workers fixed the problem. The pipe was damaged on Monday near the well head at QGC's
Berwyndale South gas field
September 13, 2011 - Crews work to fix leaking gas well - QGC
http://www.thechronicle.com.au/story/2011/09/13/crews-work-fix-leaking-gas-well-toowoomba/ A SAFETY zone
has been established around a Darling Downs gas well which has been leaking since last night.
September 13, 2011 - Gas mine leaking in southern Queensland – QGC
http://www.smh.com.au/environment/gas-mine-leaking-in-southern-queensland-201109131k7do.html#ixzz1Y9QBEyFG
22. August 22, 2011 - Santos fined over outback gas blast – Santos (Ethane- not CSG but worth noting as it was
a lack of maintenance which caused this issue)
http://www.abc.net.au/news/2011-08-22/santos-fined-moomba-explosion/2850122
Oil and gas producer Santos has been fined for breaching workplace safety laws over an explosion at its Moomba
natural gas plant in South Australia.
23. August 10, 2011 - NSW Gov’t issues AGL with a formal warning after coal seam gas well blow-out - AGL
http://www.kateausburn.com/2011/08/10/nsw-govt-issues-agl-with-a-formal-warning-after-coal-seam-gas-wellblow-out/
The NSW Government has issued AGL with an official warning following an incident during maintenance of a coal
seam gas well at a site in Camden on 17 May 2011.
August 10, 2011 - AGL warned over coal seam well leak - AGL
http://www.northernstar.com.au/story/2011/08/10/agl-warned-over-coal-seam-well-leak/
ENERGY firm AGL has been formally warned by the NSW government after a leak at one of its coal seam gas wells
in southwest Sydney.
24. August 3, 2011 - Coal seam damage to water inevitable - APPEA
http://www.eco-business.com/news/coal-seam-damage-to-water-inevitable/
“Coal seam damage to water table inevitable” APPEA
25. July 21, 2011 - Leaking, bubbling coal seam gas well - Pilliga State Forest NSW -Santos
Video from the Pilliga: http://www.youtube.com/watch?v=qf5Rj3vfQPc CONTAMINATED
SITES AND
ACCIDENTS RELATED SPECIFICALLY TO CSG/LNG IN AUSTRALIA
7|Page
26. June 21, 2011 – Arrow fined $40,000 for Breach – Arrow & QGC
http://www.couriermail.com.au/ipad/arrow-hit-with-40000-fine-for-breach/story-fn6ck2gb-1226078776279
ARROW Energy has been hit with a $40,000 fine - Queensland's biggest penalty to date against a coal seam gas
company - for five breaches of the petroleum and gas laws at the Daandine Homestead property near Dalby.
The fine does not include any penalty for the blowout of Arrow's well on the same property, which is still under
investigation by the State Government. Arrow was fined in this instance over breaching access laws that state a
landowner must be given 10 days' notice before a company can enter private property. Another breach related to
a technical issue over a pipeline. The fines followed more than a year of controversy for the emerging industry.
Rival company Queensland Gas was also fined almost $20,000 in April for illegally clearing trees at its project
near Tara.
27. June 13, 2011 - Gas chief admits company at fault - Metgasco
http://www.northernstar.com.au/story/2011/06/13/gas-chief-admits-company-at-fault-over-storage-pon/
METGASCO CEO Peter Henderson has conceded the gas company was remiss in not cleaning up two ponds after
drilling at a site at Dyraaba was abandoned.
28. June 7, 2011 - Coal seam gas leaks posed fire threat: report
58
http://www.abc.net.au/news/video/2011/06/07/3238112.htm?site=southqld
A new report has revealed five coal seam gas wells in Queensland could have ignited after they developed leaks.
29. June 5, 2011 - Coal Seam Gas Pond Toxic water storage leaking and overflowing -Metgasco
http://www.youtube.com/watch?v=smP9tL_e3U8 - Dobie's Bight Rd
30. May 23, 2011 – Qld farmer worried about gas leak on land - Arrow
http://news.smh.com.au/breaking-news-national/qld-farmer-worried-about-gas-leak-on-land-201105231f063.html
Mr O'Connor told AAP it was the fourth gas incident on his property in two years. "We've had three gas leaks
prior to this but none as big as this," he said. "The other incidents didn't come from the wells. One was from a
leaking pipe." Mr O'Connor has 12 wells on his 1847-hectare property after Arrow Energy gained access in 2006.
31. May 23, 2011 – Queensland coal seam gas leak plugged – Arrow
http://mines.industry.qld.gov.au/assets/mines-safety-health/Safety_Alert_Well_48.pdf CONTAMINATED
SITES AND ACCIDENTS RELATED SPECIFICALLY TO CSG/LNG IN AUSTRALIA
8|Page
http://www.theaustralian.com.au/news/nation/queensland-coal-seam-gas-well-blows-its-top/story-e6frg6nf1226061049085
A LEAKING coal seam gas well west of Brisbane has been plugged. The gas well, west of Dalby, began leaking
yesterday while Arrow Energy, the company which operates the well, was preparing it for gas production. The
well was uncapped to install a pump when water and gas burst to the surface. Greens spokeswoman Libby
Connors said water and gas exploded up to 100 metres high. Contractors at the scene were not hurt and a 100m
exclusion zone was established around the well on a farmer's property off Kogan-Condamine Road
32. March 3, 2011 - CSG concerns bubble to surface - Metgasco
http://www.echonews.com.au/story/2011/03/03/csg-concerns-bubble-to-surface-locals-csg-concerns/
Northern Rivers residents continue to be alarmed by the practices involved in coal seam gas exploration, with
revelations that a tailing pond (where water used in the test bore is kept until it can be trucked away) is poorly
maintained. The pond at Dyraaba has a lining made of builder’s plastic that is ripped in places and overflowed in
the January rains. Reports of a possible third leaking test well, at the same site at Dyraaba
33. March 1, 2011 - Leaking coal seam gas concerns - Metgasco
http://www.northernstar.com.au/story/2011/03/01/leaking-coal-seam-gas-concerns/
STATE Greens candidates Sue Stock and Janet Cavanaugh say they have been alerted about a potential leaking
coal seam gas site at Lower Dyraaba, west of Casino. This leaking drill site is north- west of Casino at Lower
Dyraaba, close to Dyraaba Creek which forms the boundary between the Clarence and Lismore electorates. I was
contacted by a concerned resident downstream of the well,” Ms Cavanaugh said. “This is one of Metgasco’s
exploratory drill sites. It is the third of their sites that has been found to be leaking by members of the public.
According to Metgasco’s own Review of Environmental Factors, on completion of the 10 to 20 days spent drilling
at the site the bore should have been abandoned to the satisfaction of the relevant Government department,
namely Industry and Investment NSW.
34. March 2011 – QGC contractor breaches environmental laws
http://www.pnronline.com.au/article.php/212/1670
March 2011 - QGC suspended work in its major pipeline in Queensland after admitting one of its contractors may
have breached Federal and State environmental conditions in clearing a 6 km long, 40 m-wide route for the
pipeline near Dalby. Knudson said at the time that the lack of approved plans for soil and species management
may have resulted in the breach, but said QGC does not believe the clearing had an adverse impact on protected
plants and animals. CONTAMINATED
TO CSG/LNG IN AUSTRALIA
9|Page
SITES AND ACCIDENTS RELATED SPECIFICALLY
59
35. February 24, 2011 - Call to hold off on gas drilling – Metgasco
http://www.northernstar.com.au/story/2011/02/24/call-hold-gas-drilling/
The Northern Star revealed at least two sites on the Northern Rivers were leaking. The Star yesterday revealed
there were more than 50 drill sites in place or approved across the region. It revealed two supposedly sealed drill
sites near Bentley were leaking methane gas through the soil. Metgasco, which is responsible for the sites, insists
the leaking gas is not entering underground water reservoirs around the drill sites.
36. February 24, 2011 - Gas wells leaking methane - Metgasco
http://www.northernstar.com.au/story/2011/02/24/local-gas-wells-found-leaking-metgasco-lismore/
METGASCO has confirmed methane gas has escaped from two of its drilling wells, prompting calls that the
industry regulator immediately inspects all coal seam wells in the region to discover if more are leaking.
Metgasco's chief operations officer, Mick O'Brien, said yesterday methane was found to be leaking from sealed
wells near Bentley and north-west of Casino. “These were small gas leaks from the piping connections at the top
of the ground,” he said, adding they have both since been re-sealed. “At Bentley we couldn't detect any methane,
but I heard someone managed to light it and from the piping you would expect it to be methane.”
37. February 2011 –QGC fraccing causes interconnectivity between aquifers and leaking wells not rectified in a
timely manner
http://www.abc.net.au/4corners/special_eds/20110221/gas/docs/QGC_Response.pdf
Myrtle 3 – Anne Bridle: About six weeks after the fracturing process in mid-2009, QGC’s monitoring indicated that
the Walloons and the Springbok formations were connected where the Myrtle 3 well had been drilled.
Argyle 2 & 5 – Scott and Kate Lloyd: The Argyle 2 well, about 1km from the Lloyd’s homestead and the Argyle 5
well, about 1.4km from the Lloyd’s homestead, were leaking gas for 5 years before QGC decided to rectify the
matter after being exposed by the ABC.
Lauren and Cody: Leaks identified but not deemed a problem by QGC
38. November 19, 2010 -Toxins found at third site as fracking fears build – Arrow & Metgasco
http://www.smh.com.au/environment/toxins-found-at-third-site-as-fracking-fears-build-2010111817zfv.html#ixzz1ViDujTwr
TRACES of toxic chemicals have been found at a ''fracking'' operation to extract coal seam gas - the third time this
year that gas producers have detected contamination at a drill site. Arrow Energy confirmed that benzene,
toluene, ethylene and xylene - together known as BTEX - had CONTAMINATED
SITES AND
ACCIDENTS RELATED SPECIFICALLY TO CSG/LNG IN AUSTRALIA
10 | P a g e
been found in wells at a gas site east of Mackay, Queensland. In NSW documents obtained from the Department
of Industry and Investment show that a coal seam gas drilling site near Lismore, run by the Sydney company,
Metgasco, was permitted to use fracking after supplying a generic list of hazardous materials safety guidelines.
Emails [between department staff and Metgasco] show that testing for coal seam gas using fracking can go ahead
without approval being sought, or required, from the Environment Department.
39. October 21, 2010 - Origin stops coal seam gas drilling after chemicals found in water around 8 wells –
Admits contaminating water - Origin
http://www.smh.com.au/environment/energy-smart/origin-stops-coal-seam-gas-drilling-after-chemicals-foundin-water-20101020-16ud7.html#ixzz1ViEpErIH
Farmers near a coal seam gas ''fracking'' site in Queensland will have their water supplies tested for toxic benzene
and other chemicals today after Origin Energy found contaminated water near drilling sites. The discovery of
BTEX - a mixture of benzene, toluene, ethylbenzene and xylene - around eight coal seam gas wells near Miles,
west of Brisbane, marks the first time a resources company has admitted to contaminating water at a fracking
site. Origin detected the chemicals a week ago and told the Queensland government - which is legislating to ban
the use of BTEX chemicals during coal seam gas drilling - on Friday. Most landholders in the area have been
notified of the contamination. There is no known impact on drinking water in the gas field. Origin has shut down
60
all 17 of its drilling rigs across a 40-kilometre-wide area while an investigation is carried out.
40. September 2010 – APPEA Report: Significant spill of produced water – QGC
http://www.appea.com.au/images/stories/Policy_-_Safety_and_Health/32_-_High_Potential_Incident_Alert__Water_Trunk_Line_Strike.pdf
During excavation of a new trench along an existing right off way the bucket of an excavator struck and ruptured a
buried 315mm water line resulting in a significant spill of produced water. The water trunk line was immediately
adjacent to a gas gathering system pipeline. ‘As Built’ information was not available for the buried pipelines but
their approximate location was indicated on alignment drawings and the contractor being aware of the
Brownfield nature of the site, had also sought to locate and mark these pipelines prior to excavation via the use of
Pot Holing and or Metro Tech devices. The incident occurred when the excavator struck a roping bend in the
buried pipeline that had not been properly located. The Company did not ensure the contractor had located all
underground services prior to commencing the physical work program. The activity was covered by a Permit to
Work but relevant controls were not checked prior to issue of the Permit.
41. September 2010 - Bogged Grader Pipeline Strike & Gas Release – Santos
http://www.appea.com.au/images/stories/Policy_-_Safety_and_Health/36_-_High_Potential_Incident_Alert__Bogged_Grader_Pipeline_Strike__Gas_Release.pdf CONTAMINATED
SITES AND ACCIDENTS
RELATED SPECIFICALLY TO CSG/LNG IN AUSTRALIA
11 | P a g e
A grader operator bogged over a live gas pipeline attempted to use the blade to recover the grader. The
blade struck and ruptured the HDPE line, releasing gas to atmosphere.
42. March 2010 – APPEA Report: LNG Loss of Containment incident – Gas release – Woodside
http://www.appea.com.au/images/stories/Policy_-_Safety_and_Health/41_-_High_Potential_Incident_Alert__LNG_Loss_of_Containment_Incident.pdf
During an LNG carrier’s routine cool-down operations, the shore terminal loading arm emergency release coupling
(ERC) separated close to the vessel cargo manifold. The separation did not close the ERC dry break arrangement,
resulting in LNG loss of containment. Cargo operations were immediately stopped with the activation of an
emergency shutdown, ship and shore staff mustered, and area secured until gas free. The release size was
classified as Major using the RIDDOR system. The officer of the watch on board the LNG carrier suffered LNG coldburn injuries.
43. February 2010 – APPEA Report: Uncontrolled Gas Release – Arrow
http://www.appea.com.au/images/stories/Safety/11_-_High_Potential_Incident_Alert__Uncontrolled_Gas_Release.pdf
Incident summary - A 1/2” ball valve was attached to the pressure test points to enable diagnostics to be
conducted. The nipple on the ball valve failed resulting in the release of methane gas. Personnel advised not to
enter the plant in the event of a gas release, due to the potential for explosion.
44. September 21, 2009 - Broken leg from coal seam gas sampling incident involving high pressure
http://mines.industry.qld.gov.au/assets/petroleum-pdf/safety_alert043.pdf
45. August 29, 2009 - Crushing fatality – pipe racks load shift
http://mines.industry.qld.gov.au/assets/petroleum-pdf/safety_alert042.pdf
A 24-year-old man was struck and crushed by pipe racks which came off a truck that was being unloaded at a drill
site. The rig worker did not survive his injuries.
46. June 25, 2009 - Drill Rig Walkway - Toe amputated when securing walkway
http://mines.industry.qld.gov.au/assets/petroleum-pdf/safety_alert041.pdf
47. Jan 10, 2004 – Big Stink in gasland – Santos (Ethane – not CSG**)
http://www.smh.com.au/articles/2004/01/09/1073437472720.html CONTAMINATED
SITES AND
61
ACCIDENTS RELATED SPECIFICALLY TO CSG/LNG IN AUSTRALIA
12 | P a g e
NSW is the largest energy market in Australia but imports all of its energy except electricity, which is generated
from coal to the north and west of the city. Minor volumes of methane from coal seams are being tapped around
Camden, with plans to tap into the coal reserves of the Hunter Valley. A small gas field near Narrabri is also being
developed. But NSW is yet to find an oil or gas field large enough to reduce its reliance on Moomba in South
Australia, which is becoming increasingly unreliable with three incidents over the past two years - and declining
reserves, to boot. Exploration of the acreage off the NSW coast begins in earnest this month, with seismic
mapping of the most likely section - a huge underground structure called Biggus, which lies about 12 kilometres
off Terrigal - to start on Monday week, and an exploration well to be drilled 2 kilometres into the earth's crust
later this year. The structure is around 30km long and 7km wide, and large enough to hold 1 trillion cubic feet of
gas, according to estimates of former holders of the acreage.
48. March 2003 – Fatality on CSG Drill Rig
http://mines.industry.qld.gov.au/assets/petroleum-pdf/safety_alert012.pdf
A drill rig operator suffered fatal injuries when he was crushed between a length of drill collar and an adjacent
“mousehole” during stacking pipe on an unstable foundation. It appears that the ground gave way between the
position where the pipe was being stacked and the hole excavated to locate the “mousehole”.
49. 21 September 2009 - A crushing incident involving drill collars and selection of lifting elevators
http://mines.industry.qld.gov.au/assets/petroleum-pdf/safety_alert044.pdf
50. September 6, 2002 – Injury
http://mines.industry.qld.gov.au/assets/petroleum-pdf/safety_alert010.pdf
A floorman was removing the covers from casing when two stands fell on him resulting in a broken leg and
evacuation by the Royal Flying Doctor. Stoppers were not in place and the activity was being carried out in poor
light conditions. The injured person was working alone at the time of the accident.
51. January 5, 1998 – Drill rig Serious leg injury
http://mines.industry.qld.gov.au/assets/petroleum-pdf/safety_alert002.pdf
Repairs to a rig at night involved electric welding and the rig was shut down while work was carried out. The
electric welder cables were coiled on the deck and draped across an exposed drive shaft. When the clutch was
engaged to test the repair, cables which were thought to have been removed were caught up in the drive shaft.
The cables wrapped up the leg of an operator standing on the coil and dragged him into the shaft. The young
operator suffered serious injuries to his leg. CONTAMINATED
SITES AND ACCIDENTS
RELATED SPECIFICALLY TO CSG/LNG IN AUSTRALIA
13 | P a g e
Accidents and Safety – Critical Reports
http://www.appea.com.au/oil-a-gas-in-australia/safety-and-health.html
http://mines.industry.qld.gov.au/safety-and-health/accident-incidentreports.htm (NB: Gas industry incident reports appear to be unavailable)
Other Information
http://www.jeremybuckingham.org/?p=967
“The depth of the Wyoming gas wells blamed for the contamination is very similar to the depth that many
Australian coal seam gas will operate, and much shallower than typical North American East Coast shale gas wells.
This is a direct warning for the Australian situation.
“The NSW Government should make public a list of all coal seam gas wells in NSW that have been fracked and
their location, and initiate an investigation to see if there has been any contamination of adjoining aquifers.”
“We heard evidence in the coal seam gas inquiry yesterday that AGL had fracked 117 wells at its Camden Gas
Project but also heard that no groundwater monitoring has been conducted by the company of surrounding
ground water,” he said.
62
https://www.youtube.com/watch?feature=player_embedded&v=NQ6_Uvs_vxE
This paper mentions some Australian CSG incidents (page 37 & 38):
“Drilling Down - Coal Seam Gas - A background paper”
Queensland: Jan ‐ June 2011 (6 months) there were:
- Releases of CSG water during operations account for the largest incident type. These spills typically
occurred during drilling activities or resulted from opened/faulty valves within pipework.
- These incidents involved the controlled or uncontrolled release of coal seam gas water or
permeate to the environment.
- Overflow (flooding) During the January 2011 floods, several CSG water storage dams breached the
dam banks and discharged directly into the environment.
- Discharge limits are set on environmental authorities and these limits were
exceeded on several occasions.
- There was one incident relating to BTEX contamination and one
incident of excessive vegetation clearing.
http://www.cityofsydney.nsw.gov.au/environment/EnergyAndEmissions/documents/CoSCSMReportfinalv4pdf.pd
f
CONTAMINATED SITES AND ACCIDENTS RELATED SPECIFICALLY TO CSG/LNG
IN AUSTRALIA
14 | P a g e
http://www.cityofsydney.nsw.gov.au/environment/EnergyAndEmissions/documents/CoSCSMReportfinalv4pdf
.p
ARTICLE 2
Toxic Chemicals in Unconventional Gas Exploration and Production 1 by the National
Toxics Network
‘UG exploitation and production may have unavoidable environmental impacts. Some risks
result if the technology is not used adequately, but others will occur despite proper use of
technology. UG production has the potential to generate considerable GHG emissions, can
strain water resources, result in water contamination, may have negative impacts on public
health (through air and soil contaminants; noise pollution), on biodiversity (through land
clearance), food supply (through competition for land and water resources), as well as on soil
(pollution, crusting).’2
- UNEP Global Environmental Alert System 2012
Unconventional Gas (UG) refers to natural gas from unconventional sources such as shale
deposits, coal seams, tight sandstones and methane hydrates. Natural gas consists primarily
of methane with other hydrocarbons, carbon dioxide, nitrogen and hydrogen sulfide.
Shale gas is found in natural shale fractures and in the pore spaces. Shale has
low permeability and must be hydraulically fractured to release the gas. Approximately 7.7 38 megalitres (2-10 million gallons) of water mixed with various chemical and physical
additives is needed to complete each fracturing of a horizontal well.
Coal seam gas or coal bed methane is natural gas adsorbed into the coal. To release the
gas, the coal seam must be depressurised by pumping the water to the surface. As the
pressure within the coal seam declines hydraulic fracturing is used. The US EPA estimate 0.2
- 1.3 megalitres (50,000 to 350,000 gallons) of water is required for each hydraulic fracturing
of a CSG well. Shale gas reservoirs are typically found at 2,000 to 2,300 metres below
ground, deeper than coal bed methane reservoirs, which are situated at 800 to 1,200 metres.
The closer the gas reservoirs are to ground water aquifers the greater the chance of hydraulic
communication with that aquifer and resultant water contamination.
Chemical Use - Unconventional gas activities use large quantities of chemical additives in
63
drilling and hydraulic fracturing fluids. The mixtures are unassessed for toxicity or persistence
and can also form new compounds when exposed to sunlight, water, air, radioactive elements
or other natural chemical catalysts.
Hydraulic fracturing (fracking) involves injecting wells at high pressure with water,
proppants, radioactive tracers and large quantities (eg 18,500 kilograms3) of chemical
additives to fracture the formation and produce new cracks and pathways to help extract the
gas. Up to 40% of the chemical additives may not be recovered.4 A well can be ‘fracked’ a
number of times. The US House of Representatives Committee on Energy and Commerce5
identified over 750 chemical products, with 650 containing hazardous substances and 279
products including trade secrets were identified. These include carcinogens (eg naphthalene),
1 Adapted from NTN presentation Unconventional Gas: Shared Environmental Health Concerns
presented to the OECD Focus Session on Chemicals Used and Released in Hydraulic
Fracturing, Paris,
November 2012 by Dr Mariann Lloyd-Smith, Senior Advisor, National Toxics Network Inc. /
IPEN
2 UNEP Global Environmental Alert system Gas fracking: can we safely squeeze the rocks?
http://na.unep.net/api/geas/articles/getArticleHtmlWithArticleIDScript.php?article_id=93
3 Coal Seam Hydraulic Fracturing Fluid Risk Assessment. Response to the CoordinatorGeneral
Requirements for Coal Seam Gas Operations in the Surat and Bowen Basins, Queensland.
Golder
Associates 21 October 2010
4 ibid
5 United States House of Representatives Committee on Energy and Commerce, Minority Staff,
April
2011 Chemicals Used In Hydraulic Fracturing.
http://democrats.energycommerce.house.gov/sites/default/files/documents/Hydraulic%20Fractur
ing%20
Report%204.18.11.pdf
2
neurotoxins (eg isopropanol), irritants/sensitisers (eg sodium persulfate), reproductive toxins
(eg ethylene glycol) and endocrine disruptors (eg nonylphenol).
Industry self-reporting on 9,310 individual fracking operations conducted in the US between
January 2011 and September 2012, noted cancer causing chemicals were used in one out of
every three hydraulic fracturing operations. While not all companies report and not all
chemicals used in the process are disclosed because of ‘trade secret’ exemptions, industry
did report that known carcinogens like naphthalene, benzyl chloride and formaldehyde were
used in 34 percent of all fracking operations.6 In Australia, the vast majority of fracking
chemicals have not been formerly assessed. Of the 23 identified as commonly used ‘fracking’
chemicals, only 2 had been assessed by the national regulator, National Industrial Chemicals
Notification and Assessment Scheme (NICNAS) and neither was for their use in CSG.7
Proppants (eg 40-50,000 kg) consisting of silica or manufactured ceramic polymer spheres
based on alumino-silicates) are injected as part of the fracturing fluid mixture and remain in
the formation to hold open the fractures once the pressure is released. Breathing silica can
cause silicosis, and exposure to silica dust is a known cause of lung cancer and a suspected
contributor to autoimmune diseases, chronic obstructive pulmonary disease and chronic
kidney disease.8 According to Haliburton’s patent9 acrylic polymers consisting of 85%
acrylonitrile, a human carcinogen are used for proppant spheres. Acrylonitrile has been
detected in US air sampling of gas sites at high levels.
Flowback refers to the 15 - 80% of the hydraulic fluid mixture that returns to the surface. It
contains some of the chemicals injected, plus contaminants from the coal seam like BTEX,
PAHs, naturally occurring radioactive materials (NORMs), heavy metals and other volatile
organic compounds (VOCs). Samples taken from the top of the well-head, a day after the well
had been ‘fracked’, demonstrated the presence of the VOCs; bromodichloromethane,
64
bromoform, chloroform and dibromochloromethane, as well as benzene and chromium,
copper, nickel, zinc.10
Produced water is the term used by the industry to describe the waste water produced along
with the gas. Produced water from both CSG and shale gas is contaminated with heavy
metals, NORMs, fracking or drilling chemicals, volatile and semi volatile organic compounds
and high concentrations of salts. For a typical shale gas well, daily produced water volumes
range from 300 – 4,500 litres (80 to 1,200 gallons). The amount of produced water from a
CSG well varies between 0.1 - 0.8 ML per day. Produced water is either re-injected into
aquifer formations, used for dust suppression on roads, reused for brick making, sent to
holding ponds or partially ‘treated’ and released into waterways. The treatments to remove
contaminants from produced water are limited by the chemicals they can remove, the energy
needed and their economic costs. Reverse osmosis filtration has significant limitations and
cannot remove many of the organic chemicals used in UG activities.11 Low molecular weight,
non polar, water soluble solutes such as the methanol and ethylene glycol are poorly
rejected.12
6 http://ecowatch.org/2013/cancer-causing-chemicals-fracking-operations/
7 Lloyd-Smith, M.M & Senjen, Rye, Hydraulic Fracturing in Coal Seam Gas Mining: The Risks to
Our
Health, Communities, Environment and Climate, National Toxics Network September 2011
Available
www.ntn.org.au
8 NIOSH Hazard Review, Health Effects of Occupational Exposure to Respirable Crystalline
Silica.
National Toxicology Program [2012]. Report on carcinogens 12th ed. U.S. Department of Health
and
Human Services, Public Health Service. See
http://www.osha.gov/dts/hazardalerts/hydraulic_frac_hazard_alert.htm
9 Halliburton Patent 7799744, Polymer-Coated-Particulates,
www.docstoc.com/docs/58860687/Polymer-Coated-Particulates---Patent-7799744
10 Halogenated Contaminants From Coal Seam Gas Activities Lloyd-Smith M 1*, Senjen, R
Proceedings
of the Dioxin 2012 Conference, Cairns, Australia.
11 www.industry.qld.gov.au/documents/LNG/csg-water-beneficial-use-approval.pdf. Also see
Stuart J.
Khan Quantitative chemical exposure assessment for water recycling schemes, Waterlines
Report
Series No 27, March 2010 Commissioned by the National Water Commission. Chemicals
unable to be
treated successfully include bromoform, chloroform, naphthalene, nonylphenol, octylphenol,
dichloroacetic acid, trichloroethylene.
12 http://www.aquatechnology.net/reverse_osmosis.html
3
Benzene, Toluene, Ethylbenzene, Xylene or BTEX are natural volatile compounds (VOCs)
released from the coal seam. Their short term health effects include skin, eye / nose irritation,
dizziness, headache, loss of coordination and impacts to respiratory system. Chronic
exposure can result in damage to kidneys, liver and blood system. Benzene is strongly linked
with leukemia13 and diseases such non hodgkins non-Hodgkin's lymphoma (NHL).
Other Volatile Organic compounds can also be toxic. Some are known to cause cancer in
animals (eg methylene chloride), or in humans (eg formaldehyde) or are suspected human
carcinogens (eg chloroform and bromodichloromethane). VOCs are also key ingredients in
forming ozone (smog), which is linked to asthma attacks, and other serious health effects.
VOCs help form fine particle pollution (PM2.5). VOC exposure may result in eye, nose, and
throat irritation; headaches, visual disorders, memory impairment, loss of coordination,
nausea, damage to liver, kidney, and central nervous system.14
65
Contamination risks to ground and surface water include leakage of drilling fluids from the
well bore into near surface aquifers; poor cement jobs on well bore casing, fracking pressure
resulting in cracks in the well casing allowing leakage of fluids; contamination from flow back
fluid; accidental spills of fluids or solids at the surface; surface and subsurface blow outs;
chemicals remaining in the underground from repeated fracking or naturally occurring
contaminants finding their way from the producing zone to shallow or drinking water aquifers
through fractures in the rock; and/or discharge of insufficiently treated waste water into
surface water or underground.15
US EPA investigation of water contamination in 23 drinking water wells near a natural gas
extraction site in Wyoming concluded that both inorganic and organic compounds associated
with hydraulic fracturing have contaminated the aquifer at or below the depths used for
domestic water supply in the Pavillion area.16 In Australia, BTEX chemicals have been found
in monitoring wells associated with CSG activities; for example, in five of 14 bores at Arrow
Energy’s gas fields, near Dalby. Benzene was detected at levels between 6 to 15 times the
Australian drinking water standard (0.001 milligram per litre /1ppb).17 Toluene and methane
have been detected in a private drinking water bore in Queensland. 18
Methane Water Contamination
An analysis of 60 water wells near active gas wells in the US19 found most were contaminated
with methane at levels well above US federal safety guidelines for methane. The majority of
water wells situated one kilometre or less from a gas well, contained water contaminated with
19 to 64 parts per million of methane. Wells more than a kilometre from active gas had only a
few parts per million of methane in their water. The study used chemical and isotopic
analyses to identify the high levels of methane in well water as being produced in the deep
shale, released by gas drilling activities. Sampling of CSG released water from Bohena Creek
in the Pilliga Forest NSW detected methane at the Eastern Star Gas discharge site at 68
micrograms per litre (ug/l), whereas it was not detected in the upstream control sample.20
Drilling muds, which are produced in large quantities due to well numbers, include toxic
drilling additives, salt compounds, heavy metals, NORMs and hydrocarbons.21 They are often
disposed of in landfill and more recently, in land-spraying on agricultural or rural lands.
13 Rinsky, R.A Benzene and leukemia: an epidemiologic risk assessment. Environ Health
Perspect.
1989 July; 82: 189–191.
14 http://www.epa.gov/iaq/voc.html
15 Potential Risks for the Environment and Human Health Arising from Hydrocarbons
Operations
Involving Hydraulic Fracturing in Europe.
http://ec.europa.eu/environment/integration/energy/pdf/fracking%20study.pdf
16 http://www.epa.gov/region8/superfund/wy/pavillion/EPA_ReportOnPavillion_Dec-8-2011.pdf
17 Media Release ‘Arrow advises of monitoring results’ 26 August 2011
18 Simtars Investigation of Kogn Water Bore (RN147705) -16 October 2012
19 Osborn, SG, A Vengosh, NR Warner, RB Jackson. 2011. Methane contamination of drinking
water
accompanying gas-well drilling and hydraulic fracturing. Proceedings of the National Academy
of
Sciences, U.S.A. doi: 10.1073/pnas.1100682108.
http://www.nicholas.duke.edu/cgc/pnas2011.pdf
20 Water sampling results supplied by East West Enviroag as Project No. EW 110647.
21 Origin’s Environmental Management Plan Landspraying While Drilling (LWD) Trial Program
OEUPQ8200PLN-ENV-002
4
Radioactive Materials, Naturally Occurring Radioactive Materials (NORMs) are found in coal
seams and shale, eg uranium, thorium, radium-228 and radium-226.22 The radioactive
material can be released through the drilling process in drill cuttings/muds and flowback
66
water. Radium is a known carcinogen23 and exposure can result in increased incidence of
bone, liver and breast cancer. Radon, a decay product of radium can cause lung cancer.
Air pollution has been demonstrated in a 2012 study,24 where 44 hazardous air pollutants
were detected at gas drilling sites. The 12 month study found a wide range of air toxics
including methane, methylene chloride, ethane, methanol, ethanol, acetone, and propane,
formaldehyde, acetaldehyde, PAHs / naphthalene. They noted a great deal of variability
across sampling dates in the numbers and concentrations of chemicals detected. Notably, the
highest percentage of detections occurred during the initial drilling phase, prior to hydraulic
fracturing on the well pad. Air toxics can cause cancer and other serious, irreversible health
effects, such as neurological problems and birth defects.25
Flaring (the burning off of natural gas from a new well) releases hydrogen sulfide, methane
and BTEX chemicals (benzene, toluene, ethylbenzene, and xylene) into the air,26 as well as
metals such as mercury, arsenic and chromium. The US EPA has banned flaring after
January 2015. 27
Gas Processing is required to remove impurities before natural gas can be used as a fuel.
The by-products include ethane, propane, butanes, pentanes and higher molecular weight
hydrocarbons, hydrogen sulphide, carbon dioxide, water vapor and sometimes helium and
nitrogen.
Human exposure can occur through direct skin contact with the chemicals or wastes;
drinking or bathing in contaminated water; by breathing in vapors from flowback, evaporation
ponds or stored wastes; and through contaminated dust particulates. There are many
incidents of communities reporting adverse human and animal health impacts.
A Human Health Risk Assessment of air emissions around US UG activities,28 concluded
that residents closest to well pads i.e., living less that 1/2 mile from wells, have higher risks
for respiratory and neurological effects based on their exposure to air pollutants; and a higher
excess lifetime risk for cancer. The study took 163 measurements from fixed monitoring
station, 24 samples from perimeter of well pads (130-500 feet from center) undergoing well
completion and measured ambient air hydrocarbon emissions. Emissions measured by the
fenceline at well completion were statistically higher (p ≤ 0.05) than emissions at the fixed
location station (inc. benzene, toluene, and several alkanes.) The assessment was based on
the US EPA guidance to estimate non-cancer and cancer risks for residents living greater 1/2
mile from wells and residents living equal to or less than a 1/2 mile from wells. The study may
have underestimated risks to human health as it did not measure ozone or particulates.
USEPA methods may also underestimate health risks of mixed exposures.
US Health Survey 29 investigated the extent and types of health symptoms experienced by
people living near UG in Pennsylvania. Environmental testing was conducted on the
properties of a subset of survey participants (70 people in total) to identify the presence of
pollutants that might be linked to both gas development and health symptoms. Test locations
22 Fact Sheet FS-163-97 October, 1997 Radioactive Elements in Coal and Fly Ash:
Abundance, Forms,
and Environmental Significance, USGShttp://pubs.usgs.gov/fs/1997/fs163-97/FS-163-97.html
23 http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=790&tid=154
24 Colborn T, Schultz K, Herrick L, and Kwiatkowski C. 2012 (in press). An exploratory study of
air
quality near natural gas operations. Hum Ecol Risk Assess
25 http://www.epa.gov/airquality/oilandgas/pdfs/20120417presentation.pdf
26 http://www.hsph.harvard.edu/research/niehs/files/penning_marcellusshale.pdf
27 http://www.epa.gov/airquality/oilandgas/pdfs/20120417presentation.pdf
28 Lisa M. Mckenzie, Roxana Z. Witter, Lee S. Newman and John L. Adgate, Human health risk
assessment of air emissions from development of unconventional natural gas resources.”
Science of the
Total Environment March 21, 2012
29 Gas Patch Roulette: How Shale Gas Development Risks Public Health In Pennsylvania,
October
67
2012 Earthworks’ Oil & Gas Accountability Project • www.earthworksaction.org
5
were selected based on household interest, the severity of symptoms reported, and proximity
to gas facilities and activities. In total, 34 air tests and 9 water tests were conducted at 35
households in 9 counties. VOCs were detected in air including 2-Butanone Acetone,
Chloromethane, Carbon tetrachloride, Trichlorofluoromethane, Toluene, Methylene Chloride,
Dichlorodifluoromethane, n-Hexane, Benzene, Tetrachloroethylene , 1,2,4-Trimethylbenzene,
Ethylbenzene, Trichloroethylene, Xylene and 1,2-Dichloroethane. A range of symptoms were
reported in the 108 surveys including nasal & throat irritation (60%), sinus problems (58%),
eyes burning (53%), shortness of breath (52%), difficulty breathing (41%), severe headaches
(51%), sleep disturbance (51%), frequent nausea (39%), skin irritation (38%), skin rashes
(37%), dizziness (34%). While the study did not prove that living closer to an oil and gas
facility causes health problems, they did suggest a strong association, as in general, the
closer to gas facilities respondents lived, the higher the rates of symptoms they reported.
Residents of Tara Queensland have reported similar symptoms including severe
headaches, nausea, vomiting, nose bleeds, rashes, eye and throat irritations and severe skin
irritations. Single grab samples of ambient air taken in communities around UG activities have
detected VOCs, including ethanol, acetone, benzene, toluene, xylene, ethylbenzene,
dichlorodifluoromethane, 1,2,4-trimethylbenzene, naphthalene, phenylmaleic anhydride,
methyl ethyl ketone, phenol, butane, pentane, hexane.
Annex 1
Hydraulic fracturing fluids usually include:
• Gelling agents to hold the proppant in suspension (eg mixtures of industrial guar gum,
diesel, alkanes/alkenes);
• Gel stabilisers (eg sodium thiosulphate) and gel breakers (eg Ammonium persulfate,
sodium persulfate);
• Friction reducers to ease pumping and evacuation of fluid (eg polyacrylamide, mixtures
of methanol, ethylene glycol, surfactants /fluorocarbon surfactants);
• Diluted acid to dissolve minerals (eg hydrochloric acid, muriatic acid);
• Biocides to prevent bacterial action underground (eg glutaraldehyde, Tetrakis
• hydoxymethyl phosphonium sulfate / THPS, 2-Bromo-2-nitro-1,3-propanediol (Bronopol),
2,2-Dibromo-3-nitrilopropionamide (DBNPA);
• Clay stabilisers to prevent clay expanding on contact with water and plugging the
reservoir (eg tetramethyl ammonium chloride); and
• Buffer fluids and crosslinking agents.
Fracking may also use:
• Corrosion inhibitors (eg formamide, methanol, naphthalene, naptha, nonyl phenols,
acetaldhyde);
• Scale inhibitors (eg ethylene glycols);
• Iron control (eg citric acid, thioglycolic acid);
• pH adjusting agents (sodium or potassium carbonate); and
• various surfactants to affect fluid viscosity (eg isopropanol, 2-Butoxyethanol /2-BE.)
Drilling fluid components include:
• Viscosifiers to increase viscosity of mud to suspend cuttings (eg bentonite,
polyacrylamide)
• Weighting agent (eg barium sulphate)
• Bactericides/biocides to prevent biodegradation of organic additives (eg
glutaraldehyde)
• Corrosion inhibitors to prevent corrosion of drill string by acids and acid gases (eg zinc
carbonate, sodium polyacrylate, ammonium bisulphate)
• Defoamers to reduce mud foaming (eg glycol blends, light aromatic and aliphatic oil,
naptha)
• Emulsifiers and deemulsifiers to help the formation of stable dispersion of insoluble
liquids in water phase of mud.
68
• Lubricants to reduce torque and drag on the drill string (eg chlorinated paraffins)
• Shale control inhibitors to control hydration of shales that causes swelling and
dispersion of shale, collapsing the wellbore wall (eg anionic polyacrylamide, acrylamide
copolymer, petroleum distillates)
6
• Polymer stabilisers to prevent degradation of polymers to maintain fluid properties (eg
Sodium sulfite).
• Breakers to reduce the viscosity of the drilling mud by breaking down long chain
emulsifier molecules into shorter molecules
• Salts (eg potassium chloride, sodium chloride, calcium chloride)
The Persistent Organic Pollutant, perfluorooctane sulfonate (PFOS) is permitted in
hydraulic fracturing fluids under an exemption to the Stockholm Convention on POPs 2001.30
Chlorinated paraffins are also used in drilling fluids, with POPs chemicals, short chain
chlorinated paraffins (SCCPs) listed in drilling fluid patents. POPs are recognised as the most
dangerous of all man made chemicals.
Annex 2
Examples of UG Chemicals and their Environmental Health Effects
Ethylene Glycol, a known human respiratory toxicant and associated with increased risks of
spontaneous abortion and sub-fertility in female workers;
2-Butoxyethanol, a highly mobile and persistent contaminant of groundwater, which can
cause reproductive problems and birth defects in animals, and destruction of red blood cells;
Ethoxylated 4-nonylphenol, a persistent, bioaccumulative, endocrine disruptor, very toxic to
aquatic organisms and causing sexual deformities in exposed oyster larvae, found to increase
the incidence of breast cancer in lab animals;
Methanol, a volatile organic compound, highly toxic to humans (most commonly used
chemical)31;
Isopropanol, central nervous system depressant capable of causing degenerative changes in
the brains of lab animals;
Formamide, a teratogen with the potential to affect the unborn child, which can be absorbed
into the body by inhalation and through the skin;
Naphthalene, causes nasal and lung tumours and is listed by International Agency for
Research into Cancer (IARC) as possible human carcinogen’. The US Department of Health
and Humans Service found it to be ‘reasonably anticipated to be a human carcinogen’.
Chemicals used by the Australian UG industry have found to be ‘dangerous at concentrations
near or below chemical detection limits by the State University of New York. 32 These include
glutaraldehyde, brominated biocides (DBNPA, DBAN), propargyl alcohol, 2-butoxyethanol (2BE) and heavy naphtha.
30 http://www.pops.int
31 Methanol was used in 342 of the 750 hydraulic fracturing products used in the US. It is a
hazardous
air pollutant and on the candidate list for potential regulation under the US Safe Drinking Water
Act due
to its risks to human health. See United States House of Representatives Committee on Energy
and
Commerce, Minority Staff, April 2011 Chemicals Used In Hydraulic Fracturing.
http://democrats.energycommerce.house.gov/sites/default/files/documents/Hydraulic%20Fractur
ing%20
Report%204.18.11.pdf
32 Chemical and Biological Risk Assessment for Natural Gas Extraction in New York. Ronald E.
Bishop,
Ph.D., CHO, Chemistry & Biochemistry Department, State University of New York, College at
Oneonta,
Sustainable Otsego March 28, 2011.
www.sustainableotsego.org/Risk%20Assessment%20Natural%20Gas%20Extraction-1.htm
69
ARTICLE 3
Unconventional Gas (CSG/Shale Gas) Mining and
Health Information by Doctors for the Environment
DEA has presented evidence to two parliamentary committees that it considers
the current level of assessment, monitoring and regulation of CSG
exploration and mining activities to be inadequate to protect the health of
current and future generations of Australians. There is the potential for
public health to be affected directly and indirectly through CSG, shale and tight
gas operations.
Please read DEA’s Senate and NSW Government submissions at
http://dea.org.au/images/uploads/submissions/MDB_CSG_Senate_submission_Ju
ne_2011.pdf and
http://www.parliament.nsw.gov.au/prod/parlment/committee.nsf/0/f96d07673222
5603ca25791b00102098/$FILE/Submission%200412.pdf
Unconventional gas is ‘natural gas’ that requires mining procedures over
significant areas of land. It is extracted from coal deposits that are too deep to
mine economically by the traditional methods.
The usual types of unconventional gas resources are
• Coal seam gas (CSG), which is trapped in coal seams. This is the
predominant form in NSW and Queensland. (There are also extensive coal bed
methane reserves in the USA)
• Shale gas, where the gas is trapped in shale formations. This accounts for
most of the recent US unconventional gas development. Large shale reserves also
exist across Australia and are being actively explored in WA and Qld.
• Tight sands gas. This gas is trapped in a rock/sandstone/limestone formation
that is particularly “tight”. This refers to the very small pore spaces and/or low
permeability in the rock.
Hydraulic fracturing or "fracking" is used in CSG, shale and tight gas extraction.
This process involves pumping a mixture of water, sand and other chemical
additives at high pressure into the coal seam or shale rock via the well, fracturing
these seams and providing a pathway for gas to flow back. In coal seams the gas
is released through depressurization, where the underground water in the seams is
released to the surface as a by-product. This can potentially affect interconnected
aquifers above or below the coal seam.
Shale seams occur at much deeper levels and due to their nature, hydraulic
fracturing, involving large volumes of water with chemical additives, is required to
extract the gas.
2
DEA has written extensively on the health issues of unconventional gas and health.
DEA’s “Gas as a replacement fuel: Discussion paper on the health aspects
of gas” can be found at
http://dea.org.au/images/general/Gas_and_Health_Report_01-2012.pdf
An article in Viewpoint magazine by DEA member Dr Marion Carey (Victorian
Public Health Physician) is an excellent summary of the issues we are concerned
about http://dea.org.au/images/general/viewpoint_issue_8_CSG.pdf and a video
clip of Dr Helen Redmond (NSW Physician who has spoken extensively at public
forums over the last few years on CSG’s potential health implications) can be
viewed
http://dea.org.au/resources/file/csg_undermining_our_food_bowls_dr_helen_red
70
mond
Other DEA media articles that may be of interest:
http://dea.org.au/news/article/behind_the_seams_whos_asking_questions_about_
coal_seam_gas_and_health
http://dea.org.au/news/article/coal_seam_gas_health_effects_need_more_scrutin
y
http://theconversation.edu.au/coal-seam-gas-could-be-a-fracking-disaster-forourhealth-1493
Further media articles:
http://theconversation.edu.au/food-or-fuel-how-will-governments-solve-thecoalseamgas-dilemma-2887 and http://theconversation.edu.au/bubbling-to-thesurfacecsg-impacts-and-the-condamine-7384
Of particular interest to Victoria, where the industry is yet to expand but plans for
exploration are well under way, is an article by Samantha Hepburn (Assoc
Professor, School of Law at Deakin University)
http://dea.org.au/news/article/coal_seam_gas_is_coming_to_victoria_and_were_
nowhere_near_ready
External links:
The ABC CSG website http://www.abc.net.au/news/specials/coal-seam-gas-bythenumbers/
The 2011 Interim Senate report “Impact of mining CSG on the management of the
Murray Darling Basin”
http://www.google.com.au/url?sa=t&rct=j&q=&esrc=s&frm=1&source=web&cd=2
&ved=0CFEQFjAB&url=http%3A%2F%2Fwww.aph.gov.au%2FParliamentary_Busin
ess%2FCommittees%2FSenate_Committees%3Furl%3Drrat_ctte%2Fmdb%2Finter
im_report%2Freport.pdf&ei=qTMbUOSqGeZiAf50IG4CA&
usg=AFQjCNHMthEYzpNnxT7MEegqOHRC1t8HVw
DEA has worked extensively to raise awareness surrounding the potential health
hazards of our coal industry. The “DEA Position Paper On The Health Impacts
of Coal” is accessible at
http://dea.org.au/images/general/Briefing_paper_on_coal_2011.pdf
August, 2012
ARTICLE 4
26 | viewpointmagazine.com.au
• peer reviewed
Coal Seam Gas: future bonanza
or toxic legacy?
John Muir
was a writer
and scientist
who believed that
protecting nature was vital to
Man’s physical and spiritual
health and well-being.1 He
71
seems to have understood
that by tampering with natural
systems without fully
understanding them,
we may cause
unintended
consequences
in other natural
systems.
The rapid expansion of coal
seam gas (CSG) mining in
Australia, has the potential
for unintended consequences
which could put at risk other
important natural resources
such as safe long-term
water supplies, clean fertile
agricultural land and a
countryside in which people
are happy to live.
Industry and state
governments have been
assuring us that this rapidly
expanding technology is
safe for people and the
environment and can deliver
huge economic returns. But
what is their evidence?
Disturbing information has
been trickling through from
the gas fields in the USA,
where some observers have
called the global gas drilling
boom “an uncontrolled health
experiment on an enormous
scale”.2 In Australia, there
has been an unprecedented
groundswell of opposition
to the expansion of the CSG
industry, with opponents right
across the political spectrum.
A recent federal Senate Inquiry
into this issue suggests
there are many unanswered
questions. It is appropriate
to question whether the legal
and administrative protections
are adequate to ensure public
health is not harmed and
that environmental damage
does not leave a legacy for
generations.
by Dr.
Marion
Carey
72
Dr Marion Carey is a public health physician who
specialises in Environmental Health. She is currently the
VicHealth Senior Research Fellow at Monash Sustainability
Institute, a multi-disciplinary institute of Monash
University, that seeks solutions to key sustainability
challenges. She was previously Senior Medical Adviser
in Environmental Health to the Chief Health Officer
of Victoria. Her current areas of interest include the
importance of biodiversity to human health, how primary
health care and services to the homeless can adapt to
increasingly extreme weather, how rural communities are
affected by water insecurity, and the health impacts of
wind farms and coal seam gas mining. She is a member
of the national executive of Doctors for the Environment
Australia, a voluntary organisation of medical doctors
working to prevent and reduce illness caused by damage
to the natural environment.
viewpointmagazine.com.au | 27
What is CSG and how is it extracted?
Coal Seam Gas (CSG) is primarily
methane, trapped by water and
ground pressure in the pores of
underground coal seams. It is
extracted from coal deposits that are
too deep to mine economically in the
traditional fashion. Steel-cased wells
are drilled into the coal seams to
release the gas.
Where coal seams are deep and of
low permeability, the use of hydraulic
fracturing or ‘fraccing’ may be used.
This involves pumping a mixture of
water, sand and other additives at
high pressure down the well and into
the coal seam, fracturing the coal
seam and providing a track for gas to
flow back.
In releasing the gas, coal seams
are depressurised and underground
water in the coal seams is released
to the surface as a by-product of
the extraction process. This can
potentially affect interconnected
aquifers above or below the coal
seam. An aquifer is a seam of
permeable rock such as sandstone
that holds water.3
Much of CSG development
activity is above the Great Artesian
Basin (GAB), one of the largest
underground water reservoirs in
the world, covering about 22% of
Australia’s land mass. This Basin is
potentially a source of potable water
for generations to come, but studies
of its sustainability suggest that its
renewal is limited, perhaps nonexistent.
3,4
Much of our experience with
gas extraction comes from North
America, where sources are both
shale gas and coalbed methane. CSG
reservoirs tend to be shallower and
have a higher concentration of gas
than shale reservoirs. While shale
reservoirs may all require fraccing,
coal seam gas •
73
Large scale coal seam gas development
poses poorly assessed, yet potentially
serious health risks to the community
There is the potential for public health to
be affected directly and indirectly by CSG
operations through contamination of water,
air and soil, as well as long-term impacts on
rural communities
Current assessment, regulation and
monitoring of CSG impacts on the
environment, public health and vulnerable
communities is insufficient to provide
confidence of adequate safeguards
SUMMARY
perhaps half of CSG reservoirs require
fraccing.5 While it is convenient for
industry to deny the relevance of the
US experience, there are similarities
in techniques and chemicals used,
and therefore risks and impacts of
operation.
What do we know about CSG mining
in Australia?
CSG is a multi-billion dollar industry,
with mining exploration and
production licences covering large
sections of Australia.6 CSG has been
produced in Queensland from the
Bowen Basin since 1996, but volumes
were initially small. There has been
a recent rapid expansion in the
industry, with it now encroaching
on urban settlements and prime
agricultural areas. In the five years
to 2008 CSG production in Australia
increased by 32 % per year 7 and
governments have struggled to keep
up with the rapid development.
Most activity is in Queensland
and NSW. Major CSG companies in
Queensland include Arrow Energy
NL, Bow Energy Ltd, Origin Energy,
Queensland Gas Company (BG
Group) and Santos. LNG plants
are owned by Origin and Conoco
Phillips, Santos and Petronas, Arrow
Energy and Shell, Queensland Gas
Company and BG Group.8
Huge investments are underway
developing liquefied natural gas
(LNG) plants and export facilities to
exploit CSG reserves.5 Some of this
development is impacting on World
Heritage listed areas on the Great
“…gas may be an
obstacle rather than a
bridge to a cleaner energy
future”
28 | viewpointmagazine.com.au
Barrier Reef. 9
The main CSG projects in NSW
are the Camden and Gloucester Gas
74
Projects, the Casino Gas Project in
the Clarence-Moreton Basin and
the Narrabri CSG Project in the
Gunnedah Basin. In NSW, major
players are AGL, Metgasco, Arrow,
and Eastern Star Gas, whose
operations at Narrabri have now
been taken over by Santos.7
The Australian Petroleum
Production & Exploration Association
Ltd (APPEA) is the peak national
body representing more than 80
companies in Australia’s oil and gas
exploration and production industry.
The CSG industry extracts
very large volumes of water and
produces huge amounts of waste
salt. Some estimates are that there
will be 40,000 coal seam gas wells
in Australia, with withdrawal of 300
gigalitres of water from the ground
each year, producing 31 million
tonnes of waste salt over the next 30
years. The industry has not yet come
up with a solution for this major
waste disposal problem. 10
(A gigalitre is 1,000,000,000
litres).
CSG has been widely promoted
as a cleaner alternative to coal, with
less greenhouse gas emissions and
risk of climate change. However
recent research has cast doubt on
this: gas may be an obstacle rather
than a bridge to a cleaner energy
future.11, 12
Are CSG mining methods safe?
It would be at present difficult to
undertake adequate health risk
assessments of CSG operations as
insufficient information has been
gathered on the nature and doses
of chemicals entering water and air
and the exposures of people to these
chemicals. However concerns about
long-term effects of some chemicals
used in or generated by CSG mining
include hormonal system disruption,
fertility and reproductive effects and
development of cancer.
APPEA has listed about 45
compounds used during fraccing
in Australia 13 but as there is no
national requirement for public
disclosure of all chemicals used,
we cannot be sure others are not
used. CSG companies frequently
infer safety of these products due
to the fact some are components of
household products. However just
because we may have hair bleach or
antifreeze in the cupboard does not
mean it is safe to drink it.
A range of hazardous chemicals
are reported to be used in Australian
75
fraccing operations, including
ethylene glycol, glutaraldehyde,
fumaric acid and 2-butoxyethanol.
Ethylene glycol, for example, is
used to make anti-freeze. When it
breaks down in the body, it forms
chemicals that crystallize and collect
in the kidneys and can affect kidney
function. It can also form acidic
chemicals in the body, affecting the
nervous system, lungs and heart.14
The BTEX group of chemicals
(Benzene, Toluene, Ethyl benzene
and Xylene) are volatile organic
compounds and found in petroleum
compounds. Long-term exposure to
benzene can affect the bone marrow,
causing anaemia, and increasing the
risk of leukaemia.15 BTEX chemicals
have been used as fraccing fluids,
even though this practice is now
banned in Queensland and NSW.
However, the fraccing process itself
may release BTEX from sediments
into surrounding air or water.16
APPEA assures us “ Some of
the chemicals used in fraccing may
have some toxic characteristics…;
however, when diluted such as
in fraccing gels, they present
minimal to no human or ecological
risks”13. It would be interesting
to know how this statement can
be made in light of the dearth
of any properly designed studies
of human populations exposed to
fraccing activities. When we look
for published scientific studies
demonstrating such safety or in
fact health impact assessments by
government or other bodies we find
virtually nothing. Some US authors
have said “Communities living near
hydrocarbon gas drilling operations
have become de facto laboratories
for the study of environmental
toxicology”. 2
There has been no comprehensive
hazard assessment of the chemical
mixtures used and their impacts on
the environment or human health.
Only two of the twenty-three most
commonly used fraccing chemicals
have been assessed by the national
regulator (NICNAS), and neither of
these has been specifically assessed
for use in fraccing.16
A report on one of the two
fraccing chemicals that have been
assessed for use in other situations
- the persulfate salts used in hair
bleaching preparations - state they
are “hazardous chemicals and
...harmful if swallowed, irritant to
the skin and eyes and able to cause
76
allergic responses”.17
The companies argue that only
a very small percentage of fraccing
fluids consist of these chemicals, but
because of the huge volumes of fluids
used, cumulatively these chemicals
may still constitute literally truckloads
in volume. 18
Additionally, some compounds
such as benzene can present a risk to
health even in minute quantities (as
indicated by the Australian drinking
water guidelines for benzene of 1ppb,
the equivalent of a drop of water in a
swimming pool).19
What is the impact of CSG on water
supplies?
Chief amongst the potential threats
to health is contamination of surface
and ground waters, particularly
drinking water sources. The chemical
additives used in fraccing, their
“Communities living
near hydrocarbon gas
drilling operations
have become de facto
laboratories for the
study of environmental
toxicology”
• peer reviewed
viewpointmagazine.com.au | 29
coal seam gas •
degradation products, and compounds
mobilised from sediments during the
process can pose a risk to animal and
human health by contaminating water
used for drinking, washing, stock
watering and food production. These
can include toxic, allergenic, mutagenic
and carcinogenic substances as well
as methane. Waste water coming to the
surface may contain volatile organic
compounds, high concentrations of
ions, heavy metals and radioactive
substances.
The CSG industry uses enormous
quantities of water, with predicted
extractions of around 7,500 gigalitres
from groundwater systems over
the next 25 years. The National
Water Commission is concerned
that “CSG development represents a
substantial risk to sustainable water
management.“20
The Australian Senate interim report
noted concern about the potential
impact of the extraction of large
volumes of water on the pressure within
adjacent aquifers, and the possibility of
contamination of water. 21A recent report
by JP Morgan indicated a range of risks
77
to water supplies from CSG operations.3
The industry continues to assure
us that there can be no contamination
of aquifers, despite growing evidence
to the contrary. “CSG wells are
constructed in a way that ensures
there can be no migration of gas to
neighbouring bores and aquifers.”13
Research in the US has found
systematic evidence for methane
contamination of drinking water
associated with shale-gas extraction.
22 Methane in drinking water is a
concern for human health and is
an indicator of the potential for
contamination with other compounds.
For nearly a decade, the residents
of Pavillion, in Wyoming USA,
complained about drinking water
from their wells and a range of health
complaints. This area has been drilled
extensively for natural gas but the
company denied any responsibility,
so the US EPA investigated. The
draft report released last month
indicates that ground water in the
aquifer contains compounds likely to
be associated with gas production
practices, including hydraulic
fracturing.
“Chemicals detected…
include methane, other petroleum
hydrocarbons and other chemical
compounds. The presence of
these compounds is consistent
with migration from areas of gas
production.” “Residents of the town
have been advised to use alternate
sources of water for drinking
and cooking, and have adequate
ventilation when showering.” 23, 24
Accumulation of contaminants in
aquifers can have long-term impacts.
Studies on the transport and fate of
volatile organic compounds have
found they can persist in aquifers for
more than 50 years and can travel
long distances, exceeding 10 km.25
Will CSG operators be monitoring
aquifers and accountable in 50
years?
The Senate interim report noted
“there is a risk that residues of
chemicals used in fraccing may
contaminate groundwater and
aquifers used for human or stock
consumption or irrigation…. It is
acknowledged that in one case in
Australia, fraccing resulted in damage
to the Walloon Coal Measures,
causing leakage between that and the
Springbok aquifer.” 21 The Walloon
Coal Measures are part of the GAB,
and government and even industry
assessments acknowledge the reality
78
of impacts on groundwater here by
CSG operations, with reductions in
water in landholder bores and interaquifer
transfer of poorer quality
water.26,27,28,29,30,31
Aerial view of Coal Seam Gas wells dotting the landscape on the Darling
Downs, Queensland.
Department of Environment. The opinions in the article
are not necessarily the opinions of the Department.
30 | viewpointmagazine.com.au
CSG waste water may be stored
in tanks or pits at the well site,
where spillage can occur, injected
into underground storage wells,
discharged into nearby surface water,
or transported to wastewater treatment
facilities.32 Increasingly, large volumes
will need to be treated to remove
salt and other contaminants, with
associated energy costs, and removal
methods are not 100% effective.33
There are already examples
of produced CSG water legally
discharged into waterways with
contaminants of concern to the
environment.10
Is CSG mining a threat to food
production?
The Senate interim report noted
“Exploration for, or production of, gas
has the potential to severely disrupt
virtually every aspect of agricultural
production on cropping lands and, in
extreme circumstances, remove the
land from production.” 21
Sustainable food production in
Australia and food security may
be threatened by CSG activities in
number of ways, including:
impacts on rivers, groundwater
systems and aquifers, with impacts
on the ecosystems that support
food production
reductions in water quantity and
quality with increases in a range
of contaminants and salinity
loss of land area to CSG infrastructure
and related activities
such as waste disposal
contamination of land and damage
to soils through increasing
salinity, chemical contamination,
changing pH, altered soil structure
potential for contamination of food
products through chemical traces
in crop irrigation or livestock water
lowered farming efficiency and
quality of life in rural areas
CSG development involves
progressive industrialisation of rural
areas. As gas in coal seam wells
dries up relatively quickly, new ones
continually need to be developed.
The huge problem of disposal of salt
and brine has not been solved and
79
presents risks to water and land.
The Senate Inquiry estimated that
the industry will be handling some
750,000 tonnes of salt per annum. 21
Food that is chemically
• peer reviewed
contaminated is not secure food.
Australia needs to keep its
reputation as a clean green food
producer. Only one instance of
failure in water treatment which
is used to produce food could be
disastrous for the food production
industry. There are a number of
reports of increased death rates
and health problems in animals
exposed to gas drilling operations
in the US, with some needing to be
quarantined from the food chain. 2,34
In the words of an Australian
farmer:
”It is critical that any chemicals
used in drilling and CSG well
stimulation activities do not migrate
to the bores of groundwater users. It
is critical also that natural occurring
chemicals and compounds in coal
seams and strata formations are
not mobilised to water aquifers
tapped by water bores. Many homes
use bore water, the livestock we
eventually eat as steak, chicken,
lamb and pork from supermarkets
more often than not drink it, and
the plants we grow for grain and
vegetables soak up bore water
through their roots and foliage
systems under irrigation.” 35
The Senate report states
“The coal seam gas industry is a
relatively short lived industry. It
may have a life of only 25 to 30
years in most regions. However,
if it is not properly regulated, that
period of time is sufficient to do
serious damage to agricultural
productivity on some of the best
farmland in Australia... In some
areas intensive CSG production may
be incompatible with agriculture”.21
How else might CSG mining affect
our health?
CSG operations can also cause
health impacts through air
contamination. Volatile organic
compounds (VOCs) can be released
during drilling, methane separation,
and by compressors and other
equipment. Fraccing chemicals and
waste water held in evaporation
ponds can evaporate into the local
atmosphere and be inhaled. In
addition to direct effects, VOCs
A homeowner holds up a glass of water from a now unusable well. The well’s
contents turned into a methane slurry after coal bed methane development began
80
nearby.
viewpointmagazine.com.au | 31
can contribute to the production
of ground-level ozone, a known
respiratory irritant that causes lung
inflammation and impaired lung
function.36
The cumulative impacts of water
and air pollution, degradation
of agricultural land and loss of
amenity and landscape, all have
mental health consequences for
communities living in a gas field. The
CSG process can divide previously
close-knit rural communities, and
it seems the traditional Australian
“fair go” doesn’t apply. Farmers do
not have the right to veto a CSG
operation on their land which may
have been nurtured by their family
for generations. This can lead to
anger, anxiety and powerlessness.
Miners can legally force their way
onto farmers’ land with a court order
if they don’t comply. One CSG
company recently served a court
order on a blind Hunter Valley farmer
who refused access because he was
concerned about damage to his water
supply, and needed to preserve the
physical integrity of his land to be
able to farm without normal vision 37,38
A Hunter Valley psychiatrist
has documented the mental health
impacts of CSG extraction he has
witnessed. 39 “Exploration is
when the psychological stresses
are first noticed in the community.
… uncertainty starts to generate
community anxiety…. The community
starts to divide between the few
who see it as an opportunity for an
additional income and the larger
number who hear the risks and
see little in the way of benefits. ….
Seismic surveys come and go with
some damage to paddocks, heavy
vehicle traffic ruining country roads,
and noise. Drilling occurs with the
same complications. The town takes
on a different look…Lifetime plans are
put on hold or cancelled. Property
development in the area declines as
a result of the general uncertainty.
Rental property is more expensive…
The gas company employs very few
locals.
Exploration wells are fracked
to optimize the flow and the wells
are flared for months. There is
no explanation of the risks and
precautions taken in these fracking
and flaring operations. There is no
publicity given to any air or water
testing. There have been at least
81
two separate unpredicted explosions
locally due to gas migration known
to the community from just a dozen
exploration wells…This results
in understandable anxiety about
safety risks. In Gloucester this first
phase has taken 5 years so far and
production has yet to commence”.
Are there adequate safeguards for our
health?
Overseas there have been bans or
moratoriums on shale gas mining
in France and parts of the USA and
South Africa, with the European
Parliament calling for comprehensive
regulation.40
The US EPA has begun a study
to investigate the potential adverse
impacts that hydraulic fracturing may
have on water quality and public
health.32
Our own governments’
reassurances appear less convincing
once publicly available data start to
emerge. The Queensland government
reported that in only the first six
months of 2011 there were forty-five
CSG compliance related incidents,
including twenty-three spills of
CSG water during operations,
four uncontrolled discharges of
CSG water, three exceedances of
discharge limits, three overflows of
storage ponds, and other incidents
relating to vegetation clearing and
BTEX contamination.41
Recently 10,000 litres of saline
water leaked at the Narrabri CSG
Project, now operated by Santos.
The incident was not reported at the
time despite an obligation to do so
under the conditions of the petroleum
exploration licence. 42
And yet people concerned about
their water supplies and asking
for testing of water before CSG
operations begin may be forced
to protest publicly and risk being
arrested. 43
The NSW Ombudsman has raised
serious issues about conflicts of
interest in the assessment of CSG
developments and under resourcing
of compliance and enforcement
activities. The same government
department is responsible for both
promoting investment in the CSG
industry and regulating it.44
A number of Australian health
experts, including one of our Nobel
Laureates, are sounding alarm bells.45
Some US public health experts say
that claims of safety lack credibility
in the face of a growing litany
of accidents and contamination
82
problems. 46They are advocating the
need for the precautionary principle
to be observed in the absence of
health data. 47While the industry calls
for definite proof of health effects, as
with tobacco and asbestos, by the
time evidence is iron-clad, damage
may be well underway. We need to
act to prevent serious impacts.
Conclusion
In the words of one analyst:48 “ in
the rush to supply CSG to China,
Australia could forfeit its water
security, and consequently its food
security….It seems clear that every
Australian has good reason to be
concerned about whether Australian
CSG mining will impair the
Australian way of life.”
Human health relies on
the maintenance of a healthy
environment, clean drinking
water, secure food production, and
supporting community and family
life. Any major new development
should ensure human health is
protected. Adequate information is
needed to support risk assessment
and health protection. Greater
transparency, improved monitoring
and enforcement, and high quality
research would start to fill this gap.
There is a strong case for a uniform
national regulatory framework
incorporating the need for health
impact assessment. Meanwhile the
precautionary principle should be
exercised with any CSG development.
The new CSG gold rush should not
be allowed to endanger the health of
generations of Australians.
coal seam gas •
references
44 | viewpointmagazine.com.au
Coal Seam Gas: Future Bonanza or Toxic Legacy?
1. John Muir http://en.wikiquote.org/wiki/John_Muir
2. Bamberger M, Oswald R. Impacts of gas drilling on human
and animal health. New Solutions 2012;22:51-77
http://baywood.metapress.com/media/6p8qdjyylk5tucvkybrl/cont
ributions/6/6/1/4/661442p346j5387t.pdf
3. JP Morgan Securities Australia Ltd. ESG and the energy
sector. Water concerns: Queensland Coal Seam Gas
Developments Report Summary. http://lockthegate.org.au/
documents/doc-268-jpm-csg1.pdf
4. On-line opinion. Australia’s Artesian Basin http://www.
onlineopinion.com.au/view.asp?article=993&page=0
5. Cook D. Explainer: coal seam gas, shale gas and fracking
in Australia http://theconversation.edu.au/explainer-coal-seamgasshale-gas-and-fracking-in-australia-2585
6. The Canberra Times. Poor report card for oil and gas sector.
http://www.canberratimes.com.au/news/national/national/
general/poor-report-card-for-oil-and-gas-sector/2426651.aspx
7. Roth L. Regulation of the Coal Seam Gas Industry in NSW.
83
NSW Parliamentary Library Research Service Jan 2011.
http://www.parliament.nsw.gov.au/prod/parlment/publications.
nsf/key/RegulationofthecoalseamgasindustryinNSW/$File/ebrief.
coal+seam+gas.pdf
8. Queensland DERM. Queensland’s coal seam gas overview
February 2011
http://mines.industry.qld.gov.au/assets/coal-pdf/new_csg_cc.pdf
9. David Shearman. Killing the Great Barrier Reef for
short-term profit. The Drum opinion. http://www.abc.net.au/
unleashed/3776784.html
10. ABC online. CSG by numbers. The Coal Seam Gas Rush
http://www.abc.net.au/news/specials/coal-seam-gas-by-thenumbers/
11. Manning P. Sydney Morning Herald Coal seam gas may not
help climate fight
http://www.smh.com.au/business/coal-seam-gas-may-not-helpclimatefight-20111118-1nn5f.html
12. Heard D. Merril Lynch. Green Gas debate. Who is hiding the
fugitives? http://xa.yimg.com/kq/groups/15154881/1302454069/
name/111115-BAML-who_is_hiding_the_fugitives.pdf
13. APPEA website. http://www.appea.com.au
14. ATSDR. Ethylene glycol http://www.atsdr.cdc.gov/tfacts96.
pdf
15. ATSDR Benzene http://www.atsdr.cdc.gov/tfacts3.pdf
16. Lloyd-Smith M, Senjen R. Hydraulic Fracturing in Coal Seam
Gas Mining:The Risks to Our Health, Communities,Environment
and Climate. National Toxics Network. September 2011 http://
frackingfreeireland.org/wp-content/uploads/2011/08/NTN-CSGReportSep-2011.pdf
17. NICNAS. Ammonium, Potassium and Sodium Persulfate.
Priority Existing Chemical Report No 18. Commonwealth of
Australia 2001. http://www.nicnas.gov.au/Publications/CAR/
PEC/PEC18/PEC_18_Full_Report_PDF.pdf
18. United States House of Representatives Committee
on Energy and Commerce. Chemicals Used in Hydraulic
Fracturing 2011. http://democrats.energycommerce.house.
gov/sites/default/files/documents/Hydraulic%20Fracturing%20
Report%204.18.11.pdf
19. NHMRC Australian Drinking Water Guidelines 2004 http://
www.nhmrc.gov.au/_files_nhmrc/publications/attachments/
eh34_adwg_11_06.pdf
20. National Water Commission. Position Statement on Coal
Seam Gas and Water.
http://www.nwc.gov.au/__data/assets/pdf_file/0003/9723/
Coal_Seam_Gas.pdf
21. Senate Standing Committee on Rural Affairs & Transport
Interim report: the impact of mining coal seam gas on the
management of the Murray Darling Basin Commonwealth of
Australia Nov 2011
http://www.aph.gov.au/senate/Committee/rat_ctte/mdb/interim_
report/report.pdf
22. Osborn SG et al. Methane contamination of drinking water
accompanying gas-well drilling and hydraulic fracturing. April 14,
2011. Available at:
http://www.propublica.org/documents/item/methanecontaminationof-drinking-water-accompanying-gas-well-drilling
23. US EPA News release http://yosemite.epa.gov/opa/
admpress.nsf/20ed1dfa1751192c8525735900400c30/ef35bd26
a80d6ce3852579600065c94e!OpenDocument
24. EPA finds fracking chemicals in Wyoming Gas Drilling
Town’s Aquifer HTTP://INSIDECLIMATENEWS.ORG/
NEWS/20111110/EPA-FRACKING-WYOMING-AQUIFERDRINKINGWATER-NATURAL-GAS-WELLS
84
25. Diaz-Cruz M, Barcelo D. Trace organic chemical
contamination in ground water recharge. Chemosphere
2088;72:333-342.
26. Groundwater (Deep Aquifer Modelling) for Santos GLNG
Project - Environmental Impact Statement 31/3/2009, http://
www.glng.com.au/library/EIS/Appendices/P2_Groundwater%20
(Deep)%20FINAL%20PUBLIC.pdf appendix P2 section 3.4.2.
27. Queensland DERM. http://www.derm.qld.gov.au/
environmental_management/coal-seam-gas/transcriptprotectinggab.html
28. Basin Sustainability Alliance factsheet July 2010.
http://www.basinsustainabilityalliance.org/factsheets/
factsheet1bsageneraloverviewjuly2010.pdf
29. Cubby B. Sydney Morning Herald. Coal seam damage
to water inevitable. 3 August 2011. http://www.smh.com.
au/environment/water-issues/coal-seam-damage-to-waterinevitable20110802-1ia00.html
30. Australian Geographic. Mining could drain Queensland
aquifer. 3 September 2010. http://www.australiangeographic.
com.au/journal/mining-risks-draining-queensland-aquifer.htm#.
Tx-Eo10pCFs.email
31. The Great Artesian Basin and Coal Seam Gas. CSIRO
November 2011 http://www.csiro.au/news/~/media/CSIROau/
Files/PDF/Coal%20seam%20gas%20PDFs/The%20Great%20
Artesian%20Basin%20and%20coal%20seam%20gas.pdf
32. US EPA. Draft Plan to study the potential impacts of
hydraulic fracturing on drinking water resources Feb 2011. http://
water.epa.gov/type/groundwater/uic/class2/hydraulicfracturing/
• references
viewpointmagazine.com.au | 45
upload/HFStudyPlanDraft_SAB_020711-08.pdf
33. Khan SJ. Quantitative chemical exposure assessment for
water recycling schemes, Waterlines report. National Water
Commission Canberra 2010.
34. Department of Environmental Protection Pennsylvania
http://www.portal.state.pa.us/portal/server.pt/community/newsr
oom/14287?id=12588&typeid=1
35. Bridle A. Submission 328 to Senate Standing Committee
on Rural Affairs & Transport Inquiry into management of the
Murray Darling Basin – impact of mining coal seam gas.http://
www.aph.gov.au/senate/committee/rat_ctte/mdb/submissions.
htm
36. Brown V. Putting the heat on gas. Environ Health Perspect
2007;115:a76.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1817691/pdf/
ehp0115-a00076.pdf
37. Hepburn S. Not quite the Castle: why miners have a right
to what is under your land. The Conversation. 15 November
2011. http://theconversation.edu.au/not-quite-the-castle-whyminershave-a-right-to-whats-under-your-land-4176
38. Wright M. Losing farmland to fossil fuels. Climate
Spectator. 23 Jan 2012. http://www.climatespectator.com.
au/commentary/losing-farmland-fossil-fuels?utm_source=Cl
imate%2BSpectator%2Bdaily&utm_medium=email&utm_ca
mpaign=Climate%2BSpectator%2Bdaily&utm_
source=Climate+Spectator&utm_campaign=d392133b83CSPEC_DAILY&utm_medium=email
39. NSW Parliament Inquiry into Coal Seam Gas. Dr Steve
Robinson submission
http://www.parliament.nsw.gov.au/prod/parlment/committee.
nsf/0/ba6e0623d71d072aca25790d000ac77c/$FILE/
Submission%200098.pdf
85
40. European Parliament. Impacts of shale gas and shale oil
extraction on the environment and on human health 2011
http://www.europarl.europa.eu/document/activities/cont/20110
7/20110715ATT24183/20110715ATT24183EN.pdf
41. Queensland DERM http://www.derm.qld.gov.au/
environmental_management/coal-seam-gas/pdf/csg-lngcomplianceupdate1.pdf
42. Northern Daily Leader .Prosecution possible over
leak at Narrabri coal seam gas mine site http://www.
northerndailyleader.com.au/news/local/news/general/
prosecution-possible-over-leak-at-narrabri-coal-seam-gasminesite/2419653.aspx
43. Nine news. Qld tourism group backs CSG blockaders
http://news.ninemsn.com.au/national/8405718/qld-tourismgroupbacks-csg-blockaders
44. NSW Parliament Inquiry into Coal Seam
Gas. NSW Ombudsman submission http://www.
parliament.nsw.gov.au/prod/parlment/committee.nsf/0/
AD721DC3EB00C54ECA25791B00115C73
45. Carey M, Doherty P, McMichael AJ, Redmond H,
Shearman D, Sheridan J. Submission to the Rural Affairs and
Transport References Committee Inquiry into management
of the Murray Darling Basin– impact of mining coal seam gas
June 2011. Doctors for the Environment Australia.
http://dea.org.au/images/uploads/submissions/MDB_CSG_
Senate_submission_June_2011.pdf
46. Schmidt CW 2011. Blind Rush? Shale Gas Boom
Proceeds Amid Human Health Questions. Environ Health
Perspect 119:a348-a353. http://ehp03.niehs.nih.gov/article/
info%3Adoi%2F10.1289%2Fehp.119-a348
47. Finkel M L, Law A. The Rush to drill for Natural Gas: A
Public Health Cautionary Tale. American Journal of Public
Health 2011;101:784-785. http://ajph.aphapublications.org/cgi/
content/abstract/101/5/784
48. Hansen B. Regulatory Analysis and Response to Potential
Coal Seam Gas Groundwater Contamination in Queensland
Australia :Senate Inquiry into Potential CSG Contamination
of Queensland Groundwater. TBD. Sep 2011. Available at:
http://works.bepress.com.ezproxy.lib.monash.edu.au/barrie_
hansen/9
Energy Solution: Driving Down Emissions
1. www.publications.parliament.uk/pa/cm201012/cmselect/
cmenergy/795/795.pdf
2. Environmental Protection Agency, June 2004, “Evaluation
of Impacts to Underground Sources of Drinking Water by Hydraulic
Fracturing of Coalbed Methane Reservoirs; National
Study Final Report”
3. http://www.planning.nsw.gov.au/LinkClick.
aspx?fileticket=WcE09-xBfjI%3D&tabid=495&language=enAU
ARTICLE 5
86
Briefing from Doctors for the Environment Australia on the health impacts
of coal mining and pollution
Governments are rightly concerned about the delivery of health services through
hospitals and clinics. Equally important is the prevention of ill health (preventative
medicine) through such measures as vaccination, cessation of smoking, healthy life
style and removal of carcinogens and pollutants from our environment.
Doctors use the term co-benefit when we can have a health win, commensurate
with a government decision on another need. For example development of good
public transport has been shown to improve health because people get out of their
cars and walk to the bus. There is less pollution of cities and greenhouse
emissions. There are cost savings to health which can be offset against the cost of
public transport infrastructure.
The greatest co-benefit for global and national health would be a reduction
in the mining of coal and in its use for power generation.
For information about the use of energy in Australia go to
http://www.abare.gov.au/publications_html/energy/energy_10/energyAUS2010.pdf
The costs (externalities) of coal
Taking all externalities into account, including the health burden of coal in Australia
estimated by the Australian Academy of Technological Sciences and Engineering to
be $2.6 billion per annum, it is likely that coal is the most expensive fuel. Yet
under our present accounting system it is the cheapest, and an unfair competitor
for renewable energy.
http://www.atse.org.au/resource-centre/func-startdown/63/
Research from the influential Harvard Medical School has determined that the
externalities of coal combustion double the cost of electricity in the US bringing it
into parity with some renewable energy sources.
These externalities are mainly the human morbidity and mortality from particulate
pollution. It seems likely that Australian externalities will have a similar cost and in
any socially responsible society there must be a limit to what is a huge public health
impost.
http://onlinelibrary.wiley.com/doi/10.1111/j.1749-6632.2010.05890.x/full
The externality costs of coal are calculated to add 18c/kWh to the price of electricity
in the USA and this cost may be as high as 27c/kWh.
The estimated costs in $US billions are as follows
Land disturbance; release of carbon and methane
Public health burden in mining communities
Fatalities in the public due to transport by rail
Air pollution from combustion
Mercury impacts
3
75
2
188
6
87
Subsidies
Abandoned mines
Climate contribution from combustion
3
9
62
Epstein lists these figures as “best”. He also has a “high” calculation in which the
climate contribution rises from $62 to $206.
The international costs of coal were estimated by Greenpeace to be €360 billion in
2007. http://www.greenpeace.org/international/en/publications/reports/true-costof-coal/
Coal as a Health Hazard
Pollution from coal affects all major body organ systems and contributes to the
leading causes of morbidity and mortality in the U.S. heart disease, cancer, stroke,
and chronic lower respiratory tract disease and asthma. It interferes with lung
development, and increases the risk of heart attacks and some neurological
diseases.
http://www.psr.org/resources/coals-assault-on-human-health.html
The risk of death for people living within 30 miles of coal-burning plants is three-tofour times that of people living at a distance.
http://www.kftc.org/blog/archive/2010/02/linkeddocuments/documents/Epstein%20Testimony.doc
Similar US data are reported in a 25 page overview: Death, Disease & Dirty
Power: Mortality and Health Damage Due to Air Pollution from Power Plants.
http://www.mainegreenpower.org/tools/CATF-Death_Disease_Dirty_Power-1000.pdf
In the USA, most air pollution arises from coal-fired power stations accounting for
5% of male cancer deaths and 3% of female cancer deaths between 1970-1994.
(Grant WB. Air pollution in relation to U.S. cancer mortality rates: an ecological study. Anticancer Res 2009;
29:3537-3545).
Each step of the coal lifecycle—mining, transportation, washing, combustion, and
disposing of post-combustion wastes— have additional impacts on human health.
In Australia there has been limited research into the impacts of air pollution from
coal, compared to Europe and the USA. However, current evidence suggests that
the health impacts of air pollution are similar to those reported from other
developed countries. We do know from the Australian National Pollutant Inventory
that there is considerable pollution from coal-related sources. For example in NSW
http://www.smh.com.au/environment/pollution-index-reveals-the-hidden-costs-ofelectricity-20100402-rjy0.html
Particulate pollution
Read “Airbourne particles and health”
http://eprints.qut.edu.au/38685/1/c38685.pdf
There are a number of air pollutants arising from power generation which have
been identified as injurious to humans. Some of these such as sulphur dioxide, a
strong respiratory irritant, have been reduced over time. Of great concern among
harmful pollutants are the fine PM2.5 particles (particles with a diameter less than
88
2.5µm) and coal combustion contributes to these. They are inhaled deep into the
lungs to cause inflammation and damage and large quantities are being produced in
mining and power generation. In the US, exposure to these particles, some of
which originate from coal combustion, has been shown to reduce life expectancy
and in Canada they are estimated to contribute to 5,000 deaths each year.
http://www.ncbi.nlm.nih.gov/pubmed/19667146
In the US, exposure to these particles has been shown to reduce life expectancy;
with 50,000 deaths each year being attributed to pollution from power plants
http://www.psr.org/assets/pdfs/psr-coal-fullreport.pdf
The fact that neurological diseases result from particulate pollution suggests that
the particles are inhaled and circulate to all parts of the body where they cause
inflammation
http://dea.org.au/news/article/air_pollution_mechanisms_of_neuroinflammation_cn
s_disease
Health studies in Australia are sparse. A 1993 study reported an increase in
symptoms of childhood wheeze and asthma-like breathing difficulties from a
community near a coal-fired power station (Halliday JA et al. Increased wheeze but
not bronchial hyper-reactivity near power stations, J Epidemiol Community Health
1993; 47:282-286.)
Other toxic substances
Many potentially toxic elements are released with coal combustion - arsenic,
mercury, fluorine, cadmium, lead, selenium and zinc. Of these mercury is perhaps
of greatest concern. It enters the environment and is transformed into toxic forms
which can accumulate up the food chain, particularly in fish, and affect the human
nervous system. Exposure during pregnancy is of most concern, because it may
harm the development of the unborn child’s brain. Over one third of all humanreleased mercury comes from coal-fired power stations.
http://www.psr.org/assets/pdfs/psr-coal-fullreport.pdf
Other environmental impacts of coal which affect health






Water is diverted from drinking, agricultural and ecological uses. This
has become detrimental in areas which are mixed mining and
agricultural. For example, in the Latrobe Basin over 50% of total
surface water is extracted annually by brown coal electricity generators
Water is polluted from mining, coal washing and combustion
Land is degraded from mining, pollution from combustion and the
disposal of solid wastes. For example the coal ash heaps around
Australia are sleeping hazards
http://dea.org.au/news/article/coal_ash_and_mercury_why_coal_is_a_
health_hazard
Open cast mining is consuming fertile agricultural land. With a
projected world crisis in food production, the continued approval of
open cast mining of productive agricultural land is madness
Coal mining is still one of the most dangerous occupations, even in
industrialized countries
Coal mining and coal-fired electricity foster centralized energy
production and use, thus supporting a system that is vulnerable to

89
disruption from natural causes, electrical instabilities and sabotage
The industry is losing jobs rapidly and, in particular, local jobs in
regional centres and rural areas.
Community impact of coal mining
http://www.sciencedirect.com/science/article/pii/S1353829209001105
Environmental injustice and air pollution in coal affected communities, Hunter
Valley, Australia
The authors describe environmental injustice from air pollution in the Upper Hunter,
Australia, and analyse the inaction of state authorities in addressing residents’
health concerns. Obstacles blocking a public-requested health study and air
monitoring include: the interdependence of state government and corporations in
reaping the economic benefits of coal production; lack of political will, regulatory
inertia and procedural injustice; and study design and measurement issues. We
analyse mining- and coal-related air pollution in a contested socio-political arena,
where residents, civil society and local government groups struggle with
corporations and state government over the burden of imposed health risk caused
by air pollution.
Coal combustion is a major source of greenhouse gases; it causes climate
change and threatens the foundations of good health.
According to the World Health Organization, climate change is one of the greatest
threats to public health and it will affect, in profoundly adverse ways, some of the
most fundamental pre-requisites for good health: clean air and water, sufficient
food, adequate shelter and freedom from disease. Combustion of coal pays a large
part in the total burden of emissions
The rise in green house emissions is a key factor in climate change which, according
to a WHO research project, carried out during 2000-2002, climate change due to
green house emissions was responsible for an additional 150,000 deaths per
annum, mainly in developing or poor countries. These deaths were due to impaired
food yields and consequent malnutrition; diarrhoeal diseases associated with
freshwater shortages (especially in poorer and unhygienic settings); increased
ranges and rates of some infectious diseases; and heightened exposures to storms
and floods. Today, taking into account increased population sized exposure and
increasing climate change it has been estimated that this figure may be 300,000 to
400,000.
http://www.canberratimes.com.au/news/opinion/editorial/general/folly-to-ignoreclimatechange-dangers-on-health/2169741.aspx?storypage=0
The elderly, the very young, the poor and the chronically ill are the most vulnerable
to the impacts of climate change. Recent events such as the unprecedented
heatwave and bushfires in Victoria suggest health impacts are beginning to be seen
in Australia. In the January 2009 heatwave in Victoria which had temperatures 12–
15°C above normal the Chief Health Officer’s reported a 62% increase in mortality
above expected, a 25% increase in metropolitan emergency cases for Ambulance
Victoria, and a 12% increase in hospital presentations with an 8 fold increase in
direct heat-related presentations.
90
http://www.health.vic.gov.au/chiefhealthofficer/publications/heatwave.htm
Farming communities, particularly in the Murray Darling Basin, are suffering from
stress, social disruption and depression. In the future if no action is taken, we can
expect more extreme weather events, threats to food and water security, sea level
rises, changes in vector-borne, food and water borne disease, exacerbation of air
pollution, increases in aeroallergens, mental health and refugee health impacts.
David Shearman
13. 7. 2011
Articles on coal from DEA which indicate the position that DEA is taking
Health, coal and climate change. David Shearman Climate Spectator June 16
2011
http://www.climatespectator.com.au/commentary/health-coal-and-climate-change
Giving climate change the right health treatment David Shearman & George
Crisp & David King Climate Spectator May 20, 2011
http://www.climatespectator.com.au/commentary/giving-climate-change-righthealth-treatment
Time to clear the air David Shearman Climate Spectator April 19 2011
http://www.climatespectator.com.au/commentary/time-clear-air
Too many questions about open cut coal Eugenie Kayak Geelong Advertiser
May 12 2011
http://dea.org.au/news/article/too_many_questions_about_open_cut_coal
Big Coal: A burning economic and health issue 17 March 2011
http://www.thepunch.com.au/articles/big-coal-a-burning-issue/
Coal Ash and Mercury: why coal is a health hazard David Shearman The Drum
(ABC) Dec 22 2010
http://www.abc.net.au/unleashed/42476.html
Coal-fired power stations are death factories David Shearman 18 Feb 2011
http://www.thepunch.com.au/search/3e5c9fc5523f643637450897494dccfb/
The mining and burning of coal: its effects on health and the environment
William M Castleden, Philip Finch, David Shearman, George Crisp MJA to be
published August
91
92