Great submission guide with THANKS from Nimbin Enviro Centre SUBMISSION GUIDE - Dewhurst Gas Exploration Pilot Expansion SSD 13_5934 Due: 9 November 2013 Coal seam gas giant Santos have yet more plans for dangerous multi-lateral drilling in the Pilliga Forest. The new coal seam gas wells known as triple-stacked horizontal wells have inherent risks involved due to the re-drilling of wells and the inability to seal off the groundwater from contamination. Santos have stated publically that this exploration project is just the beginning and that they plan to drill 400 wells across the pristine Pilliga Forest, the largest inland forest left in NSW. Santos already have approval to build two enormous 300 million litre wastewater holding ponds, drill eight new wells without adequate groundwater monitoring or modeling, and bulldoze extensive areas for pipelines and roads. This is all taking place in a critical recharge zone for the Great Artesian Basin! Please write a submission to let the Department of Planning and Infrastructure know that the Pilliga Forest is a national icon and no place for a coal seam gas field. Did you already write a submission objecting to another Santos coal seam gas EIS only a few weeks ago and are experiencing Deja Vu? That is because the Santos is applying for approval well by well to hide the cumulative impacts that this exploration will have on the Pilliga Forest! Please use your points in that submission to also object to this new and damaging proposal. Please make a submission here, just scroll down the page to make your submission online: majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=6038 We have until the 9th of December to let the Department of Planning know that Santos has failed to meet the Director General Requirements for this project! Feel free to copy and paste the points below into the online submission box or write your own reasons why the beautiful Pilliga Forest, a refuge for so many threatened birds, marsupials and wildflowers, is important to you: RESPONSE TO THE DIRECTOR GENERAL REQUIREMENTS: TRIPLE-STACKED HORIZONTAL WELLS – •The ‘Triple Stacked’ drilling of horizontal coal seam gas wells through the casing of the existing wells, at Dewhurst 13-18H and 31 poses great danger to the Great Artesian Basin and other aquifers as it is very difficult, if not impossible, to seal the junction between the casing and the lateral. •When questioned about sealing these junctions in July this year, NSW Chief Scientist Professor Mary O’Kane said she had been told by Santos that they had difficulty sealing these junctions known as Kick Off Points (KOPs). It is clear that Santos hold little concern for the pollution of aquifers by either drill fluids or gas escapes and the down draining of aquifers. ECONOMICS - •The assessment that has been done doesnt take into account any costs of the project, only claimed benefits. This approach has been labelled as biased, abused and deficient by the ABS, Productivity Commission and Land and Environment Court respectively and doesnt comply with DGRs. •DGRs call for a demonstration of net benefit to the NSW community. To an economist, this is a clear call for cost benefit analysis. There is no cost benefit analysis in the EIS. NSW Treasury and Department of Planning put out guidelines in Nov last year specifically to guide cost benefit analysis of mining and CSG projects. These have not been followed. WATER – •The drilling of these wells will produce an additional 331 and 413 megalitres over three years for the operation of Dewhurst 13-18H and Dewhurst 26-31 pilots, respectively of highly saline water containing heavy-metals and petrochemicals. Santos still do not have approval for any long-term sustainable management of this toxic produced water that poses a huge threat to the local creeks and groundwater from spills. •In addition despite the risks posed by the new tri-lateral wells there is no established baseline data for the important groundwater systems underlying the Pilliga such as the recharge zone for the Great Artesian Basin. The aquifer monitoring bores required to do this have not yet been constructed. •In addition, the cumulative water model used by Santos lacks the basic data required to assess the impacts of drilling for coal seam gas on groundwater in the future. BIODIVERSITY – •The further drilling required for these wells could be death by a thousand cuts for the Federal and State listed threatened species that live in the Pilliga Forest. These include the Pilliga Mouse (found only in the Pilliga), Koala’s, the Black Striped Wallaby, Eastern Pygmy Possum and many more. The Pilliga is also a haven for birdlife, including the internationally protected Rainbow Bee-eater. •Santos have admitted that their CSG exploration will destroy habitat for the Pilliga Mouse. The breeding status and population dynamics of the threatened species in the Pilliga are very poorly understood. There must be baseline ecological surveys to assess the population dynamics and status of the Pilliga Mouse and other threatened species. AIR QUALITY – The baseline atmospheric methane data collection against which to assess any future potential fugitive emissions and Independent Health Impact Assessment of north-west NSW to establish baseline health data and air quality information has not yet been conducted. GREEN-HOUSE GASES – The latest studies of unconventional gas drilling from Harvard University have suggest gas emissions from drilling and fracking are 50% worse than previously though. A 2012 study by researchers at the Southern Cross University found significant amounts of methane appeared to be leaking from the countrys largest coal-seam field, near Condamine on Queenslands Western Downs. HAZARDS – The Pilliga is highly susceptible to fires, largely due to the high incidence of ironstone attracting lightning strikes. It is not unusual for the Rural Fire Service to record up to 1000 over a 24 hour period in the Pilliga region. Santos does not appear to have a clear bushfire strategy, especially for gas flaring which cannot be shut down on catastrophic fire days. HERITAGE – It is extremely disappointing that Aboriginal Heritage requirements for were taken out of the Director General Requirements. The Gomeroi Traditional Owners of the Pilliga Forest have an ongoing connection to the Pilliga Forest through ‘song-lines’, sacred sites, bush-medicine and cultural practices. To not include an Aboriginal Cultural Heritage assessment is denying the rights of the Gomeroi Nation to have their traditional knowledge considered as part of this Planning proposal. majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=6038 From the Santos EIS Santos Project description - Santos NSW (Eastern) Pty Ltd (Santos), as the coal seam gas (CSG) operator of Petroleum Exploration Licence 238 (PEL 238), is seeking consent to expand operations at the Dewhurst 13-18H and Dewhurst 26-31 pilots, and operate both expanded pilots for up to three years (the proposed activity). The Dewhurst 13-18H Pilot is an existing pilot well set that comprises three vertical wells (Dewhurst 13, 14 and 15) and three single horizontal wells (16H, 17H and 18H). The proposed activity includes drilling an additional two horizontal wells at each of the Dewhurst 16H, 17H and 18H pilot wells to target additional coal seams, installing surface infrastructure (including a flare at Dewhurst 14) and operating the whole pilot set for up to three years. Dewhurst 26-29 is a four well pilot approved under Part 5 of the EP&A Act and is scheduled to be drilled in the fourth quarter of 2013. It is proposed to add two additional wells, Dewhurst 30 and 31, to this pilot which are proposed to be drilled in the second or third quarter of 2014 should approval be granted. The proposed activity includes drilling the two additional pilot wells (Dewhurst 30 and 31), installing surface infrastructure (including a flare at Dewhurst 28) and operating the six pilot well set for up to three years. The proposed activity includes: •construction: site preparation activities at existing and new well lease areas; establishment of necessary •equipment, temporary structures and facilities on the lease areas to enable drilling; re-entering three •existing wells to convert single horizontal wells to triple-stacked horizontal wells at Dewhurst 13-18H; •drilling one vertical well (Dewhurst 30) and one triple-stacked horizontal well (Dewhurst 31); •construction of a flare at Dewhurst 14 and 28; and construction of associated surface facilities and gathering systems operation: operating the expanded Dewhurst 13-18H and Dewhurst 26-31 pilots for a period of up to three Dewhurst Gas Exploration Pilot Expansion •Environmental Impact Statement (EIS) years, management of the water and gas produced during operation and general maintenance activities •post operation and rehabilitation: decommissioning and rehabilitation of pilot wells and ancillary infrastructure or suspension of wells for potential future use. •Additional clearing - Approximately 2.2 hectares of vegetation will be cleared from within the construction footprint at Dewhurst 26-31 as part of the proposed activity.
Posted on: Sat, 30 Nov 2013 23:20:43 +0000
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