Download La Trobe Valley Sustainability Group

Public Consultation Submission – First Exposure Draft of the National Harmonised
Regulatory Framework for Coal Seam Gas.
This table provides a template for stakeholders to make comments on the Draft National
Harmonised Regulatory Framework for Coal Seam Gas.
Name and Position:
Address:
Telephone/Fax:
Email address:
Organisation authorised level:
Confidentiality of submission:
Daniel Caffrey
PO Box 1355, Traralgon 3844
0439011512
[email protected]
Latrobe Valley Sustainability Group (Secretary)
Confidentiality Not Requested
Stakeholder Comments:
Draft National Harmonised Regulatory Framework
Part 1 – Preface
Comment
Governments need to listen to stakeholders. Especially farmers as it is their land,
which the CSG operators need to operate on. Scientists also need to be consulted.
Does the greater community want CSG if it means that farming families are adversely
affected health-wise and land and the food produced on it could be contaminated with
hydrocarbons, radioactive nucleotides that are released from the coal seams as well
as by fracking chemicals, many of which are not identified – presumably because they
are dangerous to health or the environment – hidden from the public by the excuse of
commercial confidentiality
Part 2 – Executive Summary
Comment
Disagree that coexistence is possible in more closely settled areas. There have been
too many instances of people living near to the wells becoming sick, having
respiratory problems, endocrine and nervous system abnormalities and because
many of these chemicals are carcinogenic, there is the very real probability that
heightened levels of cancers will be recorded in the near and more distant future.
These cases were highlighted in the February 4th issue of Woman’s Day magazine
with the story titled “Aussie Heroine’s Fracking Crusade” where a woman from Tara in
Queensland was compared to Erin Brokovich.
The Executive summary talks about social licence. The public has never been given
accurate information about the real impacts of CSG mining. It has arrived in
Australia as if it fell from space and has been forced on unprepared and ill-informed
local communities. Now that the real affects have been made clear in QLD and
northern NSW, people are naturally going to object to this industry coming into their
area including this area of Gippsland. The lack of reliable and scientifically conducted
studies has only given oxygen to these objecting communities as soon as they hear of
a CSG proposal coming to their district. There needs to be a moratorium on all future
CSG developments till proper science has been done on the levels of fugitive
emissions, the expected levels of and types of more complex hydrocarbons, volatile
organic chemicals, heavy metals and radioactive nucleotides. Also on the long term
effects of these on the health of people and the environment, on water supplies,
groundwater and surface water pollution, salinity issues, the integrity of the wells over
their expected working life and after they have finished production, the effects of
fracking and the leakage to the surface via cracks in the ground and into water
courses such as that which bubbled into the Condamine R. last year.
Also, the process of CSG approvals is a classic study in community disempowerment.
The protocols for community consultation have basically been a fact whiteout in
regards to affected communities, with the mining happening irrespective of the wishes
of the community. The mining companies have shown a real arrogance and bullying
disposition which will continue to enrage the population till something is done about
them.
As well, it needs to be on the public record what CSG developments have done to
land prices in the affected areas. Real estate agents cannot sell farms in areas where
CSG has taken hold.
Chapter 1 – Towards Sustainability and Co-existence
Comment
In survey after survey, Australians have said they would welcome the introduction of
Renewable Energy – or in other words Greenhouse Gas Free energy. ( See !00%
Renewable Campaign – 100% renewable.org.au) It is true that when burnt, methane
produces 50% less GHG emissions than burning coal to produce the same amount of
energy. However, fugitive emissions at every step of the CSG production and delivery
process, negates this advantage. This is because methane has 21 times the heat
trapping ability of carbon dioxide once released into the atmosphere. Trying to label
CSG as the Panacea to the problem of Global Warming is simply wrong. Renewable
energy, especially large scale solar thermal is widely popular with the Australian
public and we now expect a move away from fossil fuels as quickly as we can.
As for coexistence of CSG with farming, there have been many examples where
farmers have been forced to stop farming for reasons of unprofitability, health, loss of
water resource, water and soil contamination, air pollution and all of these together
causing sickness in stock. On most farms, 25% of the land has become unusable for
the CSG affected farms. This means farmers with small acreages are most vulnerable
and many have had to leave the farm and take off farm employment.
The sustainability of small town businesses has been severely impacted by CSG
developments, because the CSG companies get most of their supplies including food
from the cities and the dwindling farming population has seen their clientele decline.
Chapter 2 – Applying Leading Practices
Comment
Leading practice seems to be only considered to reduce costs and become more
profitable. Leading practice in providing for our energy needs means following Italy,
Spain, Germany, Denmark and Scotland to become 100% renewable with their
energy production in the very near future.
Chapter 3 – Well Integrity
Comment
According to a leaked report from the American unconventional gas industry and
made public by Josh Fox, the filmmaker who made “Gaslands”, 6 % of wells fail in
their first year of use. In order to prevent contamination of the aquifers that they are
drilled through, these wells have to last forever. The wells fail because of concrete
corrosion in the casing. We are all aware of the effects of these failures as gas and
associated pollutants get into the water table, which in some cases has been used for
human consumption – drinking and washing water. The truth about the rate of failure
has to be made public. The EPA must be empowered to give impartial and accurate
and truthful reports on this moist serious health issue and real stinging power to
impose large fines for serious breaches of the environmental laws.
Chapter 4 – Water Management and Monitoring
Comment
Very important. There have been many instances of water contamination. The history
of all these contamination events must be detailed and the results of follow up studies
to ascertain the long term impacts need to be made public. Transparency at all levels
is the way to integrity.
Chapter 5 – Hydraulic Fracturing
Comment
This process is absolutely fraught with hazards. Up to 900 chemicals, many of them
not described or named (hidden behind commercial confidentiality), with no idea of
their potency as a pollutant or cancer causing ability or for causing other health
problems. To allow the use of unknown chemicals that could become a long lived
biohazard in our groundwater supply is just negligence on the part of our
Governments.
Chapter 6 – Chemical Use
Comment
As for Ch 5
Other issues
Comment Community
Farmers and people in farming communities are not
Disempowerment benefiting from CSG development. It destroys the
lifestyles and the profitability of farming operations
which has impoverished most of the CSG afflicted
areas of QLD and NSW. No matter how many
blockades, protests and arrests that take place,
governments of all persuasions seem to side with the
CSG companies. The CSG developers march on
unless blockaded by local action.
Health of People In many CSG affected communities, people,
especially children have become sick for no other
reason apart from poisoning. At Tara, there are
reports, including those in the Woman’s Day
magazine,that children have bled from the nose and
ears after playing outside, near gas wells.
It seems odd that wells can be only a few hundred
metres from peoples homes, but in Victoria, wind
turbines, which have been exonerated from causing
sickness have to be at least 2 km from homes and 5
km from towns.
Liveability
The extraction of gas from the coal seam is an
In Conclusion
industrial process. The “produced” water is often
salty, requiring desalination. The desal plants run 24
hours a day and create high levels of noise.
The salt is kept on site or put into settling ponds to
evaporate off.
The substantial earth works creates mud when wet
and dust in dry weather
The pumping digging, desalination and flaring creates
industrial level noise around the clock
A flaring pipe which burns unwanted combustible
chemicals is required for every cluster of well heads.
These flaring pipes must burn 24 hours a day in all
weather conditions, creating noxious gas emissions
and light pollution at night time. They evn have to
burn on Total Fire Ban days, creating a serious bush
fire threat.
CSG is not the right technology for these times. It
won’t prevent increased global warming.
It is affecting the profitability of farmers, with the
smaller farming operations most vulnerable because
of loss of land and the ever-present contamination
issues.
Before CSG is acceptable, it needs to be studied
thoroughly to check for contamination, long term build
up of toxins in the environment and the health
impacts for people and stock as well as what these
can do to the eco-systems of the area.
We have no confidence that any accurate studies
have ever been done anywhere, and as we don’t
know whether this technology is safe enough, then
why should we be subjected to the possibility that it
will adversely affect our well-being, from a health
perspective, community perspective, real estate price
and farming profitability perspectives.
Please ban further CSG mining from all areas until it
can be proven 100 % safe and it has no adverse
effects for the local population.