Address
for Correspondence
Jacinta Green
Sydney Residents against Coal Seam Gas
79 Church St
St Peters, NSW 2044
Sydney Residents against Coal Seam Gas (SRACSG) appreciate the opportunity to comment on the NSW Coal and Gas Strategy Scoping Paper. We would specifically like to address issues surrounding the Coal Seam Gas (CSG) issue.
Coal Seam Gas
We have particular issue with the following introductory statements.
‘Gas has a critical role to play in NSW moving to a low carbon economy. It is
the only conventional energy source that can underpin this transition....’
The statement is based on several false or misleading assumptions:
1) Coal seam gas has a significantly lower carbon footprint than coal.
2) The mining companies are interested in extracting gas primarily for the domestic /local market.
3) CSG mining is ‘conventional’.
4) That the NSW Government is only looking at ‘conventional’ (I assume to be read as ‘traditional’) energy sources when there a several non-conventional energy sources that have been proven to provide base line power.
No one argues that the burning of gas is more efficient and releases less carbon into the atmosphere than burning of coal. However simply looking at the carbon effects of usage is misleading. New research on the life cycle carbon cost of CSG which includes fugitive emissions of methane conservatively estimates that in a 20 year timeframe approximately 36 grams of carbon are produced per MJ of energy produced, while coal estimates for the same timeframe range between 30 and 32 grams carbon per MJ. The high estimate for CSG is over 60 grams of carbon per MJ. (Howarth, 2011). This is not fringe or discredited science. The Coal industry itself uses Howarth’s research to point out that over a hundred year timeframe CSG produces fewer grams of carbon per MJ of energy produced then coal (although only marginally). Given the need to address climate change sooner rather than later, and that the NSW Government is promoting CSG as a transitional energy source (as opposed to a final solution) we feel that 20 year timeframe data is more apposite.
It is also important to note that while carbon dioxide is the dominant greenhouse gas, methane is the second most dominant. The Global Warming Potential (GWP) of methane is at least 21 (IPCC, 2007) and thus has 21 times worse per molecule, and as such we need to be careful that in our haste to tackle the more popular carbon dioxide issue, that we don’t substitute carbon dioxide emissions with methane emissions.
While the NSW Government is interested in the extraction of CSG for the domestic market, the NSW Government does not own the mining companies. Current domestic gas consumption is about 1000 petajoules (PJ) annually and is estimated to increase to 1150PJ, while gas companies are looking to export over twice this amount (AIG, 2011). Linking domestic gas production to world export markets will also dramatically increase the price of domestic gas (AIG, 2011). If the NSW Government is, as stated, looking for CSG to be an interim transitional energy source to a low carbon economy, then export of CSG must be restricted.
Additionally the government (past and present) has well publicised concerns about the cost of living. Allowing large scale export of CSG will result in higher local gas prices (AIG, 2011), adding further weight to the argument to restrict export of CSG.
This scoping paper states that gas is the ‘only conventional energy source....’ (p 4) while gas in itself is a conventional energy source. Coal Seam Gas mining is ‘unconventional ‘, and is recognised as such by the industry (see Shale Gas and Unconventional Gas Summit 2011).
Therefore by considering CSG mining, the NSW Government should also look at other ‘unconventional’ power generation options. There are a range of new, not so new, and emerging technologies that can provide base load power (Beyond Zero, 2010). These technologies are proven and can provide base load power. For example Concentrated Solar-Thermal Power (CST) projects are in development around the world, and Spain currently produces 150 MWe via CST (NTGR8, 2010). A CST power plant is being planned in Kalgoorlie-Boulder, WA. Local lobbyists not only see the plant as a means of “carbon-free energy” but are excited about the prospect of attracting “high energy using industry” to the area (Wynne, 2011).
By investing in other ‘unconventional ‘ technologies now, (rather than flogging a dead horse) the NSW Government can eliminate the need for a transitional energy source and position NSW as a strategic player in new global carbon economy.
In addition to the pure economic and climate change concerns, CSG mining has a range of documented environmental and health issues. This scoping paper recognizes that these are concerns. We would argue that the environmental and health issues are not just concerns, but actual threats to the health and safety of the Australian peoples. Environmentally, the CSG industry is far more destructive and potentially destructive than coal mining, but unlike coal mining, there are no easy rehabilitation measures.
Health Impacts
CSG mining has a range of direct and indirect health impacts. Doctors for
the Environment Australia (DEA), is a voluntary organisation of doctors from
around Australia, concerned with the relationship between health and the environment.
Dr Helen Redmond recently presented a seminar ‘Health impacts of open-cut coal
mining and coal seam gas mining’ (Redmond, 2011). Chemicals and compounds used
can be generally classified into three groups: 1) standard drilling compounds,
2) compounds used in the fraccing process, and 3)
compounds found naturally within the coal seam that are bought to the surface whatever
the extraction method. Many compounds and chemicals are found in all three
groups. Of the compounds that we know are present and that we know the effects
of include endocrine disruptors, carcinogens, heavy metals and radioactive
isotopes (NTN, 2011).
Impacts from these compounds on physical health include skin, eye and sensory organs issues, respiratory illnesses, gastrointestinal and liver problems, brain and nervous systems, immune disorders, kidney malfunction, cardiovascular and blood issues, cancer, mutagens, the list goes on(NTN, 2011).
The carcinogenic BTEX group (benzene, toluene, ethyl benzene and xylene) that have received recent publicity are not only used in the drilling/fraccing process but occur natural within the coal seam. The banning of BTEX chemicals in the drilling process will not stop these compounds coming to the surface, seeping into the ground water or from accidently contaminating surrounding areas through spillages of produced water. The pH of the produced water needs to be considered as increased acidity can result in increased mobility of the heavy metals and other compounds brought up from the coal seam.
Indirect impacts on health are predominantly related to the environmental impacts.
Environmental
Impacts
The scoping document recognises concerns about subsidence,
water supply, water use, aquifers, waste water. Any impact on our water supply
directly impacts on our basic human rights to clean drinking water as
recognized by the United Nations (United Nations, 2010).
There are a myriad of threats to water, which as the driest country in the world, we should be trying to conserve and treasure. A large amount of water is used in the mining process itself, whether this is sourced from the local water authorities or from local ground water, the net result is a loss of usable water for other industries and communities in the area. Once extraction commences, a large amount of ‘produced’ water is brought up from the coal seam. This produced water, as well as bringing up methane, brings up toxic, carcinogenic, radioactive compounds and heavy metals found naturally in the coal seam (see Health above). The current practice of treating produced water in evaporative ponds is recognised by the industry (Glynn, 2009) as very problematic, with permeation of salt and compounds into ground water or overflow into surrounding environments, streams and rivers etc. at the top of the list of concerns. The recent flooding of these ponds in the Queensland floods demonstrates that these effects may not be limited to a local area.
Contamination of food producing regions by produced water cannot be easily remediated and can render the land unusable for generations.
Often downplayed by the industry is the physical geological interplay between coal seams, overlying geology and groundwater. Many coal seams are ideal for gas extraction purely because they exist in a high pressure state. Releasing of this pressure through extraction has a twofold effect. Firstly, it can result in subsidence which can in turn change the connectivity between the coal seam, any local aquifers and ground water thus contaminating the ground water. The contamination can be from the compounds found naturally in the coal seam, or from fraccing chemicals. Secondly, removing the pressure in the coal seam may result in a drop in ground/bore water, leaving it inaccessible to current bore water users. The most graphic demonstration of what can happen when drilling results in a drop of pressure can be found in Indonesia with the mud volcano (Davies et.al. 2011) whereby 3 square miles of land is now 65 feet under a pool of mud.
Contamination of the aquifer (unanticipated or otherwise) can have far reaching effects. The National Water Commission (2009) recognises that “ground water and surface water are intimately linked”, and that “we are still unclear as the extent of these interconnections”. Extraction of CSG cannot continue until we can be certain of the extent of any impacts from the operation. Indeed the National Water Commission (2010) recognizes that the industry “risks having significant, long-term and adverse impacts on adjacent surface and groundwater systems”.
The most likely result of drilling into this high pressure environment is most likely leakage of methane and coal seam substances. Despite industry reassurances to the otherwise the wells do leak and the leaks are detectable at the surface. A recent QLD Government report (QLD , 2010) found that over 50% of the wells tested were leaking – although they only consider it to be a leak when it becomes measurable compared to the Lethal Explosive Limit (LEL) of methane and thus only report a small percentage of actual leaking wells. Over 250 toxins have been identified in air pollution associated with gas flares (see NTN 2011, and references contained within).
Environmental impacts not mentioned in the scoping document are noise, dust and sound pollution, vibration, increased traffic, habitat fragmentation and protection of stygofauna. As CSG extraction moves into urban environments (e.g. St Peters, Sydney and surrounding areas) noise, dust and sound pollution, and cumulative traffic are of increasing importance and need consideration. The fact that St Peters is located under a flight path and suffers from extensive noise pollution between the hours of 6am and 11pm does not mean that the 24 hour a day drilling, extraction and truck noise will blend in with the existing noise pollution (Macquarie Energy , 2010) and should not be considered acceptable. We suggest that that the 200m metre legislated distance from dwellings is not enough to mitigate the impacts and risks associated with CSG extraction. We suggest that CSG wells are incompatible with an urban context.
As the frequency, duration and intensity of vibration are not discussed within Macquarie Energy (2010) we have no idea on the effect or impact this will have on surrounding residents and the local environment.
Similarly estimated numbers of associated truck movements are not discussed within Macquarie Energy (2010), so impacts are unknown, but we suggest that the current approval requirements lack the level of detail required for an accurate assessment of impacts, both local councils and state traffic bodies should be involved in the approval process.
Not considered at all in the NSW Government Scoping Paper or in any of the publicity around the CSG industry is the problem of habitat fragmentation and the threat to stygofauna. Habitat fragmentation is one of the major threats to biodiversity (Lindenmayer, 2006) a well documented critical threat, more so in the rural areas, while the threat to stygofauna is universal.
Unlike a coal mine, CSG fields cover large areas and are networks connected by pipes and roads. The resultant habitat fragmentation can be easily seen in any of the more developed CSG fields. While this causes visual pollution, and obvious obstacles to cropping and grazing practices by farmers it also impacts on the local, surrounding and migrating fauna, and does so in a manner much greater than the impact of a coal mine. It is well known that habitats need to be connected to maintain biodiversity and much good work has been done on a large scale within Australia. For example the Australian Alps connectivity initiatives (Andersen and Atkins, 2010) has been recognised globally. On a smaller scale, many species will not even cross a small road, and the ones that do are subject to increased risk of traffic injury (Randgaard, 1999).
Fragmentation also effects ecosystem function and the network of roads can provide the means for feral animals and weeds to spread throughout the landscape.
Stygofauna are members of the rich biota found in underground water including but not limited to potential important chemosynthetic microbes and distinctive and specialised (and often geographically specialised) fauna. Stygofaunal communities on the eastern coast of Australia are hardly ever recognised and are poorly understood. Recognised at a federal level (National Groundwater Commitee, , there is an increasing awareness of these communities and of their importance to the Australian ecosystems in Western Australia (DEC, WA) Internationally Stygofauna are recognised in The RAMSAR Convention on Wetlands.
More recently the NSW Land and Environment Court in [2010]NSWLEC 104 and [2010] NSWLEC 48 recognised the likely occurrence of stygofauna in ground water and required continual sampling and monitoring of the project on basis of the Precautionary Principle.
Cumulative
Health and Environmental Effects
The scoping paper recognises concerns about the cumulative health and
environmental impacts of mining (principally in the Hunter Valley and the
Liverpool plains), we suggest that the cumulative health and environmental
effects are more widespread. There is constant media coverage about the need
for a ‘Big Australia’, while Australia as a whole bounces between long dry
droughts and destructive floods. Internationally food and water security is
becoming a global concern. While meat accounts for 30% of our exports (DFAT 2011), the national fresh fruit and
vegetable market is much more sensitive to local impacts (e.g. bananas, post
cyclone, post flooding) (Verrender, 2011). As
Australia grows in population it will become increasingly important to ensure
that our water is drinkable and that we have enough arable land to not only to
supply fresh food at peak production, but be flexible enough to cope with other
environmental disasters. The absence of fresh food will impact on the health of
the population (Redmond, 2010), as will contamination of water supply and
impact on downstream communities.
We would like to address some specific issues addresses within the scoping document.
Clean Coal – we appreciate the thought behind research into carbon sequestration, however globally, there is less and less conviction that carbon sequestration - or clean coal - will do the job its proponents say it will. In the US, just 3% of the US$4.4 billion of funds for CCS has been deployed. Several European countries have shelved plans for CCS projects. The Qld government has also scrapped a project. If research into carbon sequestration is to continue, it should be aimed at reducing current levels of carbon in the atmosphere - not to allow the continual release of carbon from underground coal seams, it should be considered as a remediation measure not a facilitation measure. We suggest if the Clean Coal Council is to continue, then funding should not come from the NSW Government, but from the Coal Industry - as they are the beneficiaries of profits related to any clean coal developments. However, it should be run by the Department of Environment, rather than the Department of Mineral resources to ensure that the emphasis is on “clean” rather than “coal”. We also note that a visionary government would be looking beyond non-renewable energy sources. Redirecting money spent on the Clean Coal Council into renewable energy research – will not only have immediate benefit, but the cost benefit will extend far into the foreseeable future, and far beyond the initial investment.
Part
3A
We
welcome the recent announcement by the O’Farrell government to repeal Part 3A.
We feel this is a positive step in the right direction. But for the Coalition to do more than pay lip service to the
notion of "community control" it must ensure that local communities
have a real say in infrastructure developments, including in mining and exploration
operations, by regulating a transparent, consultative and democratic process
which involves affected communities and not just the private stake holders. We also need to ensure that the right to appeal decisions is
reinstated.
Rehabilitation
of coal mines
We recognise and appreciate the work undertaken to
rehabilitate coal mines, however we suggest that the rehabilitation of Coal
Seam Gas fields is not so simple. The area affected by a coal mine is
localised, while a CSG field consists of an extensive network of wells over a
vast area. The most likely of threats from a CSG field is water and soil
contamination, by heavy metals, neurotoxins, radioactive isotopes and salinity
from produced water. A produced water spill will leave the surrounding land
unusable for decades, if not centuries. Contaminated groundwater or
contamination in the artesian basin, is likewise
unable to remediated. It is also likely to have a far wider effect. Given the
contamination, leaks and impacts we are already seeing in Coal Seam Gas fields
in QLD and NSW, continuation of the CSG industry is tantamount to salting the
earth.
Suggestions in scoping document for upgrades to port of Newcastle lend weight to the argument that proposals are not for a NSW transitional period to a lower carbon economy – but for the export market.
Biodiversity/Aboriginal Heritage
We welcome the
recognition given to biodiversity and aboriginal heritage, however we suggest
that rather than “there may be some value...” that there is indeed great value in
both recognising and considering both biodiversity and aboriginal heritage.
Planning
for Jobs and Housing
The scoping paper assumes that the expansion of coal mining and CSG “will
generate additional jobs and the need to house new employees....in regional
areas” recent events in Queensland (Burke, 2011) and intention of mining
companies to move to 100% fly-in, fly-out operations , demonstrates that this
is not necessarily true. The mining companies have their own agenda and their
agenda is not necessarily in the best interest of local communities, states or
even Australia. The move to fly-in, fly-out not only reduces any economic
benefit to local communities, but also increases the opportunities for foreign
labour, as is common in WA.
Triple bottom line, cost benefit analysis
We welcome the concept of triple
bottom line, cost benefit analysis incorporating social, environmental and
economic costs and benefits. We suggest that this should not just be restricted
to “regions where coal mining or gas extraction may have the
potential to displace or adversely impact other high value existing land uses.”,
but to all proposed coal and gas operations. In particular the Coal Seam Gas
industry has the potential to impact on the wider populations through impacting
food production and clean water. The proposal in Queensland for 40,000 CSG wells, has the potential to render up to 40,000 square
kilometres of land unusable for grazing, cropping or even to be rehabilitated
for environmental considerations. Given that the cost of fresh fruit and
vegetables in Australia responds so dramatically to any natural disaster –
permanently removing this amount of arable land will impact on every household
in Australia.
We also
note that the scoping document only mentions Environmental Protection and Biodiversity Act and
the Water Management Act. We suggest
that the Threatened Species Conservations
Act and the Fisheries Management Act are also of concern.
Specific
species of Stygofauna (See Environmental threats –
above) can be considered as
(a) a member of a threatened species, population or
ecological community as defined in the Threatened Species Conservation
Act 1995 (NSW);
(b) a member of a threatened species, population or ecological community as
defined in s 220B of theFisheries
Management Act 1994 (NSW); or
(c) a member of a listed threatened species or listed threatened ecological
community as defined in theEnvironment
Protection and Biodiversity Conservation Act 1999 (Cth);
It is also
important to note that species (which may or may not have threatened species
status) that have aquatic larvae in fresh water are covered under the Fisheries Management Act – so any
operation that is extracting, returning or potentially contaminating inland
rivers needs to consult the Fisheries
Management Act as well.
One of the
largely ignored social costs (in Australia) of coal and coal seam gas mining is
the impact that related pollution has on health and social development
(particularly of affected children) and ultimately the crime rate. Masters
(1998), Motluck (1997), Koop and Lundberf
(1992) among others have long documented the strong links between industrial
pollutants and violent crime with counties (in the USA) containing coal and
coal related industries with three times the national average of violent crimes.
The levels of pollution in the air correlate with the levels of heavy metals
and neurotoxins found in the local population, while the level of heavy metals
and neurotoxins are heavily correlated with school dropouts and violent
criminals.
Surface and groundwater management
We welcome the
inclusion of a policy on surface and groundwater management, we consider this
to be an important component of any triple bottom line assessment. We note that
this should not only include consideration of the Water Management Act but also include consideration of the Fisheries Management Act, the Threatened Species Conservation Act, and Environment Protection and Biodiversity
Conservation Act (see issues with stygofauna and
freshwater larvae, this document).
Strategic Aboriginal Heritage assessment
We welcome the
inclusion of recognition of the importance of Aboriginal heritage, and we urge
diligence to ensure that not only significant areas of Aboriginal heritage
considered protected, but that a wide variety of areas of Aboriginal regardless
of their perceived strategic importance are protected from the tyranny of small
decisions.
Subsidence management
The Federal
Government recognizes subsidence as a major issue for both long-wall mining and
the coal seam gas industry. Recent events in NSW (Cubby 2011) highlight not only the damage subsidence can do, but the inability
to repair damage once it has occurred. Areas where subsidence
can impact on food, water, critical infrastructure or dwellings should be off
limit to both long-wall mining and the coal seam gas industry. We would like to highlight that this area
should encompass the underground extent of the long-wall mine or gas well – not
just the surface footprint.
Although touted as a transitional energy source it is obvious from the scoping document that the urgency in pushing forward on CSG is the potential export market (p8, p10), so the question to ask is - as an export industry is it worth it.
The scoping document states that across across local, state and commonwealth governments there is a yearly revenue into government coffers of $1 billion, but this is offset by the ~ $1 billion a year the NSW Government spends in coal industry subsidies (Patterson, 2007). The scoping document also mentions the creation of 19,000 direct jobs and 70,000 indirect jobs, possibly adding 5 billion to the economy. The push by mining companies of fly-in, fly-out operations reduces the level of job creation and indirect benefits to the economy. We are also concerned that FIFO operations increases the likelihood of foreign contractors being employed under conditions that are not allowable under Australia workplace regulation and that the push by mining companies for fly-in fly-out operations from overseas on less than award rates is discriminatory to those workers, and helps drive down pay and conditions for Australian workers.
We would like to see the ~$1 billion a year in coal industry subsidies to be diverted to commencement of a concentrated solar thermal plant.
The Department of Environment estimates that the health costs of air pollution (DEC 2005, NPI)is between $1.8 billion and $8 billion per year (DEC 2005) for Sydney alone.
There are also more direct costs to those
living close to the mines or working in them. It has long been known that the
life expectancy of miners is far below that of the general population. While
there have been some improvements this trend seems unlikely to change in the
foreseeable future (Smith and Leggat 2006). We are
not sure how you cost the decreased life span of the estimated 19,000 people
directly employed in the coal industry, but we are sure it is considerable.
We suggest that health costs due to continued use of non-renewable energies alone, should be more than enough for any government to redirect resources and funding into immediate development of renewable energies, and cessation of coal industries.
A true triple bottom line costing of these industries incorporating not only immediate health, social (including crime rates), environmental costs, but the opportunity cost of the loss of arable lands, and the future costs of not addressing the affects of increased carbon emissions is long overdue and we look forward to a comprehensive overview of all impacts of this industry.
It does seem rather absurd (with all the known effects) that we are continuing to invest in ways and means of extracting carbon (in its many guises), while simultaneously investing in researching ways to capture that carbon and re-store it back underground.
Sydney Residents Against Coal Seam Mining for an immediate moratorium on all Coal Seam Gas exploration and extraction until the environmental and health issues can be thoroughly researched, and all true costs have been calculated.
By
Jacinta Green, Anne Picot, Zio Ledeux,
Irene Doutney, Lisa Newey,
Jacinta Tonkin, Brian Martin, Pip Hinman, Fiona Paul,
On behalf of
Sydney Residents Against Coal Seam Gas
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