Narrabri Gas Project Approved
September 30 2020
The controversial Narrabri Gas Project has been approved by the New South Wales Independent Planning Commission (IPC).
The approval comes after it was revealed that the IPC would not consider last-minute evidence from EDO’s clients that the project would likely have a greater impact on groundwater than previously thought.
The commission has granted “phased approval,” which means that the project proponent Santos must meet specific requirements around groundwater modelling before the project can progress to the next phase. There are four phases in all with construction of production wells beginning in phase two.
The commission also imposed a condition that any exceedance of the project’s predicted scope 1 and 2 greenhouse gas emissions – including fugitive emissions from wells – should be offset. The IPC did not require offsetting for the project’s scope 3 emissions, from when the gas is burned for energy.
However, the IPC has rejected many of the objections put forward by EDO’s clients, including that the project is not in the public interest and is against the principles of intergenerational equity because of its climate impacts.
“On behalf of our clients, we are very disappointed that the IPC has given consent for this project,” EDO CEO David Morris said.
“Our legal submissions and the independent scientific evidence to the IPC demonstrated that this project is not necessary – either to drive down gas prices or secure domestic supply.
“Allowing the Narrabri project to go ahead puts the groundwater, ecosystems and local communities around the Pilliga at risk. It adds another source of powerful greenhouse gas emissions to our atmosphere at a time when what is urgently needed is rapid and deep reductions in emissions.
“We will be meeting with our clients in the coming days to discuss their options in the wake of this decision.”
The Environmental Defenders Office acts for the North West Alliance and its member groups who oppose the new NSW gas field proposal. They argue that there is no demonstrated need for the project, that it’s not in the public interest, and that the project is contrary to the principles of ecologically sustainable development.
The $3.6 billion project is proposed for north-western New South Wales, an area known for its rich agricultural land. Project proponent Santos sought approval for 850 wells to be located over 425 sites including part of the Pilliga Forest and grazing land. The project is expected to have a lifespan of 20-25 years.
The Narrabri Gas Project is one of the most contested in Australia, with around 23,000 public submissions made during the Environmental Impact Statement process. On behalf of our clients, the EDO made a strong case against this development on three main grounds – its Groundwater, Climate and Ecological impacts.
Groundwater is a valuable source of water in the Pilliga, used primarily for irrigation, cattle and stock farming, as well as domestic purposes. The target coal seams for the Narrabri Gas Project are underneath aquifers that supply water for agriculture and domestic use and are important recharge zones for the Great Artesian Basin. The extraction of gas depressurizes ecological formations and may cause groundwater levels to decline, impacting water users.
Contamination of groundwater and surface water are also major environmental risks. For the Narrabri Gas Project, the major potential contamination source is ‘produced water’ that’s pumped from the coal seams. It is estimated that approximately 37.5 billion litres (GL) of water will be produced from the target coal seams during the life of the project.
A 2014 report found that, in addition to having high salinity, the water produced from the coal seams in the Narrabri region also contains significant level of heavy metals, boron and fluoride, which could make the produced water an environmental and human health hazard, and a major potential source of groundwater and surface water contamination.
EDO’s clients object to the Narrabri Gas Project on climate grounds, arguing the project is not in the public interest and contrary to the principles of ecologically sustainable development. Our clients argue the greenhouse gas emissions, including so-called ‘fugitive emissions’ that escape during the gas production process, would adversely impact on the environment and hinder measures to limit dangerous climate change.
CSG is composed primarily of methane (CH4). Methane is 86 times more powerful than carbon dioxide for atmospheric warming over a 20-year time period. The gas is responsible for about a quarter of total atmospheric warming to date.
In Australia, there are no regulations that directly limit methane emissions from oil and gas production. Potential fugitive emissions from CSG are so great that any environmental benefits from burning gas for electricity generation instead of coal are negated.
The effects of adding new methane sources to the atmosphere – both fugitive emissions, and the burning of the gas – are inconsistent with the Paris goal of limiting global temperature rise to 1.5 degrees Celsius above pre-industrial levels. In light of growing climate risks already being experienced in Australia, and the critical importance of combatting climate change now, our clients argue that the Narrabri Gas Project should be refused.
The Pilliga Forests are an important refuge for wildlife, with high-conservation-value remnant patches, which are part of a recognised National Biodiversity Hotspot. Our clients argue that the threat of serious and irreversible harm from the Narrabri Gas Project is clear.
Independent expert advice commissioned by the North West Alliance has identified that uncertainty about the location of gas infrastructure as well as the scale of direct and indirect impacts has made a transparent assessment of the biodiversity impacts of the Narrabri Gas Project impossible.
Some of the possible impacts of the operation of 850 gas wells in the area include:
- increased fragmentation of a landscape that’s already under severe environmental stress;
- increased sedimentation of waterways and the reduced availability of surface water that many animals rely on;
- increased disturbance from vehicle movements, dust, noise and lighting associated with gas mining operations;
- the exacerbation of factors that already impact the project area because of intensive forestry operations and climate change – particularly the loss of hollow bearing trees, vegetation loss and increased fire frequency.
Our client argues that because there is the threat of serious irreversible ecological damage, and because Santos has failed to establish the likely environmental consequences of the Narrabri Gas Project, the precautionary principle should be engaged and the project refused.
The NSW Independent Planning Commission held public hearings into the Narrabri Gas Project in July and August 2020. The Environmental Defenders Office produced more than 100 pages of legal submissions and 12 expert scientific reports, while more than 400 objectors gave evidence over seven days of hearings. The IPC’s decision, originally due in early September 2020, was delayed due to allow public comment on new material provided at the last minute by Santos and the NSW Government.
On 30 September 2020, the Independent Planning Commission decided to approve the project.
The Environmental Defenders Office would like to thank barrister Robert White for his generous assistance in presenting the case to the Commission for our clients in this matter.