Sunday, 15 December 2013

Watch for the 1,999 hectare footprints

The big four coal seam gas companies in Queensland have had their major projects approved. By the evidence presented firstly by the Courier Mail newspaper and secondly by ABC TV Four Corners program the approval process left much to be desired. To learn more of these events read an earlier post on this site, Gas leak response. Recently the Crime and Misconduct Commission (CMC) cleared any wrongdoing in the approval process mostly by a neat side step of that matters raised '… do not fall within the CMC’s jurisdiction.’  For further reading go to this highly referenced and detailed report of what has occurred in the online Independent Australian article, How the Queensland Government fracked the State

Despite its many flaws the big projects to this point were subjected to an approval process. They had to negotiate an Environmental authority (EA) with the government. They hired consultants to prepare mind blowing large Environmental Impact Statements (EIS) which were open to a public review and submission process. EIS look at more than just environmental impacts; they also include impacts on the likes of cultural heritage, transport, agricultural production and the very important underground water impacts. Each coal seam gas company are developing tenements they hold outside the areas approved within their current projects and to bring each of these new areas into production one would have thought that they would need to be scrutinised for any major impacts on conservation values or top farming soils etc.; but apparently not.

Take the example of the British Gas owned QGC project, Queensland Curtis Liquid Natural Gas (QCLNG) project which was approved for mapped area that included 6,000 gas wells, CSG water storage ponds, linking roadways, linking gas & water pipes, compressor stations, processing plants, accommodation camps, export gas pipeline and a LNG plant on Curtis Island.

The first photo (above) was taken at the end of November 2013 shows the QGC Woleebee Creek processing plant under construction; a massive piece of industrialisation lifting out what was once quiet cattle paddocks west of Wandoan in what was once amongst Australia’s best beef fattening country.

On the 6th November the Australian Financial Review ran an article, BG seeks clearance for extra 400 CSG wells, in which it was announced:

BG Group is seeking environmental approval to drill an additional 400 coal seam gas wells near Wandoan to help maintain gas flows to its $US20.4 billion LNG export project in Queensland once production from the initial batch of wells starts to tail off.”

“A BG spokeswman said the area involves about 50 landholders and the construction of up to three gas compression facilities, water and gas gathering pipelines, access roads and laydown areas in addition to the wells.
“The development is not expected to have any significant environmental impact, with about 94 per cent of the total permit area – or about 123,500 hectares – cleared of trees and used mainly for grazing,” he said.”

“Also included in the project are access tracks, accommodation camps and gas and water gathering lines, as well as storage ponds and pumping stations. Gas will be treated in processing plants being built as part of the initial project.”


The AFR article does say that this new smaller area to the existing QCLNG project is seeking environmental approval; but what approval?  According to a presentation given by Rory Ross at Shine Lawyers CSG information seminar at Wandoan on the 4th December, any state approval will be no more than a tick and flick process with no public notification or public input. Apparently there is a trigger for any project with a footprint of above 2,000 ha to be subjected to scrutiny but no so those below. QGC doesn’t consider the project requires an EIS as it has determined that it has a 1,400 ha footprint.

QGC has to seek approval from the Commonwealth under the Environment Protection and Biodiversity Conservation Act (EPBC). I’m yet to find a link to the application but if you type into a search engine these words - EPBC QGC Detailed description of proposed action - you should find a PDF file to download.
The second image (above) is sourced from this application, the green line shows the boundary of the new ‘400 well’ area; the light grey lines shows the pre-existing farm property boundaries for the “about 50 landholder’s”.  On the map if you look to the south of the green boundary to old farm boundaries marked in red, these are farms now owned by QGC and amongst them you will see a gasfield area in green text named, Woleebee creek; this is the location for massive the processing plant as shown in the first photo.   

But how available is the Commonwealth process to public notification or input?  At the Shine Lawyer seminar the audience was informed that the application was opened to public submissions for 10 working days on the EPBC website before the document was removed from the site. Apparently the environment minister, Greg Hunt, has determined that the application has to be subjected to further additional scrutiny but to find this information is not easy.

Currently any scrutiny of these additional smaller areas is held by a thin thread of the EPBC act and specifically the water trigger amendments introduced by the former government to appease the former independent MP Tony Windsor. There have been rumblings for the water trigger removal and one vehicle for doing so could be the Productivity Commission and then this last week there was the agreement between the States and the Commonwealth for “One stop shops” for environmental approvals.

The processes for approvals for CSG projects in the past have been far from desirable; current arrangements are not ideal and what for the future? There is certainly a lot of room for improvement and while onerous, conflicting, repetitive and time consuming regulation is not needed for all productive sectors of the economy there must be in place effective scrutiny.  

The last image was prepared by Rory Ross for his presentation. The yellow triangles depict current CSG wells. Look at the saturation to the south of the proposed new “400 well’ area to the Woleebee Creek field; this is the footprint of a 750 metre well spacing, the same according to the application will go in the new area to the north. Makes a mockery of a 1,400 ha footprint within the 123,500 ha area; even Roma farmer Peter Thompson who often speaks out about the positives about CSG made this very important observation in an October interview in the Weekend Australian when speaking about reaching a value on compensation for CSG activity on his land:
“At the end of that time it was finally agreed he would be compensated for the impact on his entire land, not just the area where the gas wells were. That saw him achieve the level of payment he originally sought.
"It was bringing it to an acceptance that the work impacts the whole property - the impact is not just around the gas wells, the impact is across the whole place," Mr Thompson said.”
To meet an ongoing need for export volume of LNG the CSG companies will progressively bring into production new fields. Going by current indications they will be tacked onto the initial project piece by piece, each below the 2,000 trigger. So watch out for the 1,999 footprint.

Previous related discussions
UPDATE #1- Follow up discussion


  1. It now appears that the CSG/LNG companies deliberately grossly understated the amount of wells that they intended to drill so that it would not look as bad as it really will be.
    Now that they have their approvals for the original number, they are now trying to get the "real" number needed (that they did not previously declare) to make their gas extraction viable.
    If they were so inept that they could not determine how many wells were needed prior to approval, then let them now, go whistle dixie for any above the original number that was apparently their estimated requirement and which was deliberately understated. (Their Quote from above)
    “BG Group is seeking environmental approval to drill an additional 400 coal seam gas wells near Wandoan to help maintain gas flows to its $US20.4 billion LNG export project in Queensland once production from the initial batch of wells starts to tail off.”
    It appears from this statement that they knew that there would be insufficient for the future in the original approval but they chose to fudge the figures for the purpose of getting the approval. This in effect hid from the property owners concerned the real impact that they intended inflicting all along.
    They appeared to be quite sure how many wells they would need in their application, now they say that there is not enough to carry on into the future. In other words they deliberately withheld the real facts and now that they have got what they originally asked for, they want to change all of the rules and get more by default.
    This is only the Wandoan area. How many more of the CSG/LNG companies throughout the entire Gasfields, deliberately gave understated estimates in their original applications to get to an irreversible situation so that they could then seek to get perhaps thousands more CSG wells as BG group have now done.

  2. The approvals process for mining and Coal Seam gas may be long and unwieldy. Stripping away green tape and red tape should always be an aim of governments.
    Having said that, Australia’s water resources are far too important not to be thoroughly scrutinised at several levels.
    The fast-tracking of mining and CSG projects will lead to unforseen or downplayed consequences which will prove to be a problem in the long term.
    The media has portrayed the issue of whether the power to delegate all approvals, including water approvals to the States as a battle between big business and environmental groups. The “community” may get some consideration. However, everyone, including the Productivity Commission is ignoring the long term need for a reliable source of water for agriculture.
    The intent of the legislation is shown in the link below.
    The central illustration in the article above shows at least ten private water bores that are subject to “make good” provisions. This would, I believe be in addition to those which are inside the tenement area and covered by the legislation.
    “Make good” will certainly be better than no arrangement but its ease of use and efficiency is yet to be tested. We are yet to see whether effects on bores will be widespread or not, but widespread dependence on external water sources will not be tenable in the long term.
    Property Rights Australia has always maintained that there is no external substitute that is equal to a reliable source of clean underground water which is suitable for purpose.
    If it comes to a situation where water tables are dropping rapidly and problems are all too obvious there needs to be some authority to order a “stop work” until the problems are solved. This may very well be an action that is never required but gaps in the effectiveness of regulation will become obvious as time goes by. There needs to be authority to plug the gap rapidly. Already we have seen some examples of cases where regulation has not been up to the job of protecting everyone’s interest.


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