On 03.04.20 Santos applied to vary their Environmental Protection Licence (EPL20350) to all but decommission several water monitoring bores in their network, removing their ‘requirement to monitor’ and provide those results to the EPA and the public.
This variation application went unnoticed for several weeks and is still pending. It concerns monitoring bore(s) that have demonstrated levels of methane, in at least one of the bores the raised methane levels are claimed to have been caused by termites (see excerpt from Santos Ground Water Monitoring Report, Annual Return 2017/2018 dated June 2018 below).
North West Protection Advocacy have applied via GIPA for the information around this variation. At a time when transparency is essential from Government and Santos we are shocked to see Santos attempting to near decommission water monitoring bores, especially ones that have an unverified source of methane in them (see letter below).
The EPA did not check and verify the Santos report with its own analysis of the monitoring bore that came to the conclusion that methane in the bore is because of termites. With such a contentious issue (methane in a bore) why was there no investigation and no proof provided?
NWPA wrote the following letter to the EPA and received the following reply.
To: email@example.com Cc: firstname.lastname@example.org
Re: Santos s.58 Licence Variation lodged 030420
To: Gas Regulation Branch – NSW EPA
North West Protection Advocacy are writing to seek urgent information surrounding the variation of Santos license 20350. It has come to our attention that Santos seek to decommission several water monitoring bores at the Tintsfield and Bibblewindi locations. We note that previous licence variations have been granted that have allowed Santos to decommission monitoring bores and are concerned that this variation goes a step further.
NWPA are asking if the EPA can provide the application for transparency purposes. If this is not possible then please provide details of which monitoring points Santos seeks to decommission to enable community-based citizen scientists to assess the likely impact of any gaps in data that may occur as a result of decommissioning.
The Notice of variation issued to Santos on 11-Oct-2018 noted that “D. The EPA has considered the future usage of the Bibblewindi Ponds as stated in the Santos EIS. The EPA acknowledges that the ponds may be used in the future for the storage of produced water, after being upgraded to comply with the relevant standards. This licence variation amends the license so that surface water monitoring at these points is not required if produced water is not being stored in the ponds.”
Surface water monitoring is no longer required at Bibblewindi and NWPA wish to place on record that decommissioning of any further water monitoring bores at a time when Santos are seeking to expand operations is not ideal and that we are opposed to this license variation being approved without full transparency.
In regards to Bibblewindi please see these Questions submitted to the Community Consultative Committee in February 2019 and the responses provided by Santos below in relation to BWDMW15D. Is this one of the bores Santos are seeking to decommission?
While Santos may have indicated to the EPA that these sites may not be used for some time the EPA has indicated otherwise (see EPL licence variation issued on 11.10.18). Santos have also indicated in the press that if they are granted approval they will begin development of the project immediately.
As you would be aware the Government Water Monitoring Bores in the Gunnedah Basin are still not operational and reporting of data is not publicly available. The Plumb Road WMB only reports standing water level. These bores have been installed with taxpayer funds to enable community and government regulators to understand subsurface water quality etc. Until such a time as these become operational and accessible to the public NWPA request that Santos be asked to maintain their EPL as it stands until the Assessment of the Narrabri Gas Project is decided and the government water monitoring bores are operational.
NWPA received the following response from the EPA on 29.06.20:
The IPC questioned NSW Planning thoroughly on the implementation and operation of Santos Water Monitoring Network and the Departments own monitoring. As a condition of Phase 1 approval groundwater monitoring bores will need to be installed. The GIPA information will be available on the 18th August, 2020.