UPDATE:
March 2012.
DPI, after 'careful consideration' has approved the application for Commonwealth to look for coal and mineral sands.
Previously, the company has announced that it will relinquish its option to look for CSG (coal bed methane, CBM) as part of its license application.
Feb 2012. There has still be no announcement by the state government on whether this application will be approved.
Community meeting, Nov 2011
More than 40 people attended a public forum to call for the creation of a No Go zone in the region at Toongabbie on November 17.
It has been reported that Morwell MP Russell Northe "understands community concerns". However, he has not yet expressed his support for a moratorium on new coal operations in 'greenfield' areas.
Check out these great websites put together by people in the Toongabbie area:
background
Commonwealth Mining Pty Ltd has lodged an application for a permit to explore for coal and coal seam gas (CSG, also know as coal bed methane, or CBM) for an area of Gippsland to the north east of Traralgon, covering the localities of Toongabbie and Cowwarr. It covers private land and road and road reserves.
Public notices were placed in newspapers on October 26 announcing this application, and the community has 21 day to lodge objections with the Department of Primary Industries.
A decision will then be made by the state government.
Background story from the Latrobe Valley Express available here. (Dec 2011).
Please take action – and send this alert to your friends
Any person may object to a licence being granted according to Section 24, Mineral Resources (Sustainable Development) Act 1990.
PLEASE NOTE: on 27th October, the Executive Chairman of the parent company of Commonwealth, Robert Annells, said in an interview on ABC Gippsland radio that his company was not looking for CBM. However, the application information lodged with DPI still lists Coal Bed Methane in its application. We have therefore kept information on CBM in the objection letter below.
Please send your submission to:
Manager, Earth Resources Tenements, Department of Primary Industries, GPO Box 4440, Melbourne Vic 3001.
Or via email: david.boothroyd@dpi.vic.gov.au
A suggested letter is given below – please feel free to modify it, add your name and address, and send by 17 November at the latest.
extra information:
The Friends of the Earth objection can be found here.
You can find the objection from Toongabbie Township Planning & Development Group here.
[below: Cowwarr Weir]
To:
Manager,
Earth Resources Tenements,
Department of Primary Industries
Dear Mr Boothroyd,
I write to register my objection to the following application for an Exploration Licence (EL) that has been put forward by Commonwealth Mining Pty Ltd.
Application Number: EL 5394
I am very concerned by this proposal to explore for coal bed methane (coal seam gas, or CSG), and black or brown coal. The application notice says that the company intends to “undertake a drilling program to assess potential coal resource”.
Given the very limited details that are available on the DPI website – and absolute lack of information from the proponent - I am assuming that any exploration that then leads to production of CSG could involve the use of hydraulic fracturing (fraccing).
I note that under section 2A of the Act the Minister is obliged to consider the environmental consequences of a decision regarding applications. The principles of sustainable development, which are outlined in the Act (available here: http://www.austlii.edu.au/au/legis/vic/consol_act/mrda1990432/s2a.html ) set out a compelling case for taking a precautionary approach to possible future impacts of mining and drilling operations. I firmly believe there will be major impacts from any CSG or coal operations.
I object to the application on the following grounds.
COAL BED METHANE (COAL SEAM GAS)
The Public Notice pertaining to these applications says that the company intends to “undertake a drilling program to assess potential coal resource”. I understand that on 27th October, the Executive Chairman of the parent company of Commonwealth, Robert Annells, said in an interview on ABC Gippsland radio that his company was not looking for CBM. However, the application information lodged with DPI still lists Coal Bed Methane in its application. I therefore wish to lodge my concerns about CBM in my objection to this application.
I understand this to mean that the company will drill exploratory holes to take samples. If the environmental costs of a mining operation are substantial – as I believe they will be in the case of both CSG and coal mining – then it would be negligent to approve the initial exploration permit. If a permit is granted and the proposal proceeds through to a works approval phase (ie, a mining license is issued), then the following problems can be expected to arise.
Ground water impacts
Test wells would be drilled into the coal seam. These initial wells are unlikely to produce much gas until the coal seam has been stimulated by hydraulic fracturing (fracking or fraccing). This is achieved by pumping a fracturing fluid into the coal seam at pressures sufficient to crack open the rock. This enables the gas to flow to the well more easily.
Gas companies are very reluctant to reveal what they use in the fracking process and yet continually imply they are quite safe. Fracturing fluids are primarily water but contain other chemicals, often including acids, solvents, surfactants, biocides, and hydrocarbons. Sand is often added as a propping agent to hold the fractures open and allow the gas to flow freely to the well bore. Some of this toxic fracturing fluid, known as ‘flowback water', resurfaces but much may remain underground.
Concerns about CSG operations:
· Extracting coal seam gas (CSG) requires the removal of large volumes of generally saline "associated water" from the coal seam.
· The extraction of associated water can lower water levels in adjoining aquifers.
· In many areas, we do not fully understand the degree of connectivity between different aquifers, nor the extent to which groundwater sources are connected to surface waters. In some places groundwater provides the base-flow to creeks and rivers; in others, creeks recharge groundwater aquifers.
· Hydraulic fracturing (fracking) causes micro-seismic events or little earthquakes intended to open up pathways for fluids or gases to flow. If these fractures intercept fissures or faults, the fracking fluids, contaminated water or gas can move into other geologic layers, contaminating the groundwater.
Salt and other contaminants
· Coal seam gas (CSG) water (also known as ‘associated', ‘produced' or ‘formation' water) is regarded as a waste by-product. Large volumes must be removed from coal seams to allow gas to flow.
· CSG water is generally high in sodium and contains many other contaminants. In the case of Queensland, where the industry is relatively far more advanced in its development, each megalitre (one million litres) of associated water generally brings up 5 - 8 tonnes of salt previously stored safely underground.
· CSG water may also contain heavy metals, carcinogens such as benzene, toluene, ethylbenzene and xylene, and radioactive chemicals that are naturally present in coal seams. Some of these highly toxic substances bio-accumulate - that is, they are concentrated as they move up the food chain.
Climate impacts
The production and burning of CSG for energy may be little or no better in terms of greenhouse pollution than coal.
· Coal seam gas (CSG) is a fossil fuel - a dirty energy source that adds to greenhouse pollution.
· The gas industry claims gas-fired power stations produce 70% less CO2 than existing coal-fired power stations. This figure only refers to the emissions released when the gas is burnt. It does not include the emissions involved in producing the gas - the drilling, fracking, compressing, pumping, liquefying and transporting the gas.
· Liquefying natural gas consumes at least 20% of its energy value and cancels almost 30% of its "clean" character.
· Monitoring of methane leakage in the oil and gas industry is limited, but conservative estimates suggest that during the life cycle of an average coal seam gas well, 3.6 - 7.9% of total production is emitted to the atmosphere as methane. This is at least 30% and perhaps more than twice as great as the life cycle methane emissions for conventional (natural) gas which range from 1.7 - 6%.
CSG may be cleaner than coal, but it is not clean, nor green.
BROWN AND BLACK COAL
Victoria currently relies heavily on coal to meet our energy needs.
With what we know about climate change, we know that the world must transition rapidly to a low carbon future. This will mean that we must adopt renewable energy sources to meet our energy needs.
Victoria is blessed with a range of renewable and low emissions energy options, including wind and solar, geothermal and wave energy.
The time for further investment in coal, especially broad acre open cuts, is long over. Coal mining on the Gippsland Plains will have a massive negative impact on local people, local economies, landscapes and waterways. It would add huge greenhouse emissions to the atmosphere. Because coal mining is a single-use option for land where it occurs, this would threaten on-going production in what is a significant food producing region.
Impacts on food production
I believe we need to see this proposal in the context of what is happening across much of eastern Australia. Many thousands of proposals to explore for or produce CSG/ CBM is already having negative impacts on agricultural producing areas such as the Darling Downs in Queensland. Here in Victoria, there are around 30 applications by various companies who are interested in CSG and/or coal. These occur across the ‘coal belt’ of southern Victoria, much of which is our prime agricultural country.
In the case of EL5394, most of the identified area is within the MacAlister Irrigation Area, the state’s second most significant irrigation zone. The Latrobe River, a significant river in terms of the Gippsland Lakes, flows through the EL area and the aquifer supports a significant agricultural sector.
I do not believe it is acceptable to be putting prime agricultural country at risk from CSG operations when we know about the significant negative impacts associated with this industry in Queensland.
I urge the Minister to act to protect key food producing regions by opposing this particular EL and, more broadly, to put a moratorium in place on any new coal and CSG proposals until there has been a thorough assessment of the likely impacts on our food production and long term food security. Such an assessment must also include likely impacts on rural communities, biodiversity and water, and contribution to our state’s greenhouse pollution.
The information used above in my submission largely comes from the Lock the Gate Alliance. Full references are available on their website. http://lockthegate.org.au/csg-facts/
Summary
For the reasons outlined above, I urge you to reject the proposal for this exploration permit.
Yours sincerely,
