Narrabri Gas Project Public Health Communiqué 2 – Time for health professionals to expose CSG risks to NSW communities

Coal seam gas (CSG) poses a serious threat to clean air, clean water, a safe sustainable food supply and a stable climate, the determinants of good health. Methane, carbon dioxide, and waste water containing salts and naturally occurring heavy metals and other constituents of potential concern (COPCs) from the coal seam, are brought to the surface along with drilling fluids. Leaks, spills and disposal methods of this toxic waste are all problematic. These impacts are well-documented, as is the escalating research on the impacts on human health in Australia and abroad.

Doctors for the Environment Australia have renewed their efforts to raise awareness of the risks of gas mining expansion, in their video #turnoffthegas

The NSW government’s Narrabri Gas Project Assessment Report says “with suitable controls, the Narrabri Gas Project is unlikely to harm the environment or adversely affect the health and safety of the local community”.

“Suitable controls” is highly subjective and reliant on Santos being open and transparent about gas, toxic waste and water contamination. To date, Santos has declined to provide NSW Government agencies with key information that would help assess the risk. The Water Expert Panel has identified constituents of potential concern (COPCs) that are missing from the assessment that could potentially change the waste composition and classification.

Public health also depends on the NSW Government to regulate, monitor and enforce compliance.

Santos’ aim is to be the lowest-cost onshore gas producer in Australia. When it comes to what are “reasonable and feasible” measures, Santos’ commercial interests would prevail in a legal contest over the company’s responsibilities. It is essential to demand MANDATORY, MEASURABLE performance standards. If Santos doesn’t already know how it will satisfy regulatory requirements, Narrabri Gas should NOT PROCEED.

NSW Planning puts public health concerns down as mere “anxiety”. It “acknowledges that ‘intangible’ fears may persist, which may lead to increased stress and anxiety in the community, and affect certain people’s mental health and sense of place.”

What are these “intangible fears”?
• New independent health studies not used to assess the project
• Risk to water resources
• Social impacts of transforming rural communities into industrialised FIFO destinations
• Greenhouse gas and other pollutants, including climate change
• Bushfires

Write a Submission to the IPC Public Hearing
It’s time for all public health professionals to ensure their voices are heard by the NSW Independent Planning Commission when it undertakes assessment of the highly controversial Narrabri Coal Seam Gas project. The interests of public health are being ignored by the proponent Santos, the Gas Industry Social Environmental Research Alliance (GISERA) and the NSW Department of Planning.

Despite the rapid growth of the coal seam gas industry in Queensland and the public’s concern about health impacts, an in-depth, independent study has not been conducted.

GISERA has a study underway with a short title of Potential health impacts from CSG. A recent variation has postponed the final report until November 2020, after the decision on the Narrabri Gas Project. The project leader is Dr Cameron Huddlestone-Holmes, a geologist from CSIRO Energy. When launched the health study was said to focus on how to “reassure” the public of the safety of the coal seam gas industry.

GISERA is an alliance between the five biggest unconventional gas companies in Australia, including Santos, and the CSIRO. One of their recent studies found fracking in Queensland had little to no impact on air quality, soils, groundwater and waterways. Due to vested interests and limited data it was widely criticised and likened to health research by a cigarette company.

The Department of Planning has provided the Independent Planning Commission with Recommended Conditions, which it says can safely regulate the 850 coal seam gas wells. However, after a quick look at these, it is clear that they will not be capable of ensuring public health and safety.

Points to make in your submission

“Reasonable and feasible” mitigation measures, an example of the vague and uncertain wording in the Recommended Conditions for Air pollution.
“B19. The Applicant must ensure that all reasonable and feasible avoidance and mitigation measures are employed so that air emissions generated by the development do not cause exceedances of the criteria” – on privately-owned land only.
Criticisms:
• The list of substances that are monitored is extremely limited – only particulate matter, ozone and sulphur dioxide. Methane is not monitored. Other substances not monitored include gases like Hydrogen Sulphide, compounds like BTEX and VOCs.
• The judge of what is “reasonable and feasible” is the Department, which has shown itself to have no commitment to enforcing conditions at other mining projects in the Namoi region.
• Draft Condition B19 only protects privately-owned land and does not cover public land.
Santos invites land owners to forego protections provided in the Recommended Conditions, without giving them honest disclosure of what this could mean if they live close to gas infrastructure.
Criticisms:
The Government’s Final Assessment Report (Page ix) claims Santos has committed to only undertake activities on privately-owned land with agreement from the landowner. The option for landowners to opt out of the air and noise pollution criteria, exposes them to loss of amenity and potential health harms, which are not adequately disclosed up front.
Assessment Report (Para 584) The Government Recommended Conditions require Santos to comply with a number of location criteria, including:
• no project-related infrastructure within 200m of any residence, unless otherwise agreed;
• no well pads within 100m of privately-owned land, unless otherwise agreed;
• production wells to be spaced at least 750m apart.
Criticisms:
These distances from infrastructure do not serve to protect residents or workers from fugitive gas emissions and noise. Potential contact with drill cuttings from well construction, proposed to be disposed of in situ, posing a risk from heavy metals and Naturally Occurring Radioactive Materials (NORMs). The distance specified between wells can easily be changed through a process of “Modifying” the consent conditions with little or no public consultation. Assurances about safe distance from gas operations are 100% unreliable.
Assessment Report (Para 598) The Department requires Santos to prepare a noise and air quality management plans in consultation with the Narrabri Gas Community Consultative Committee.
Warning: People for the Plains, a community group represented on that Committee, have repeatedly requested information and consistently been denied answers. The public has no trust in the NGP CCC for delivering informed consultation as dozens of outstanding questions were reported to the Parliamentary Inquiry on the Chief Scientist’s recommendations on CSG.
Key recommendations you should include in your written submission
• ALL performance criteria should be expressed as mandatory requirements NOT “reasonable and feasible measures” – such loose and subjective criteria will rarely or never be enforceable, as the recent history of mining in the Namoi valley has amply demonstrated.

Other References:
World Health Organisation
Australian Medical Association
Doctors for the Environment
Dr Geralyn McCarron, a Queensland GP, has published peer reviewed studies on the health of people in gas field communities, which have been ignored.