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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.