PRA: Water management for the CSG industry

The coal seam gas industry does use a lot of water, not only in the construction of gas fields and supporting infrastructure but most of all in the dewatering process where huge quantities water is pumped out of the aquifer where the coal seams are located so as to be able to extract the gas.   Even the conservative if not sanitised report from the Queensland Water Commission says that “Petroleum tenure holders are predicted to extract approximately 95,000 megalitres of water per year over the life of the industry and this extraction will impact on water levels.”  This impact will largely fall upon landowners depending on bores and springs to water livestock and under licence restrictions irrigate crops.

The image is one developed by QWC with lines drawn on the map where they forecast the long term cumulative impacts of the coal seam gas industry will be on underground water. But already in these early stages of CSG production there are reports of bores outside of the 'affected area' predicted by the QWC showing dropped water levels, diminishing recharge rates and capacity.

The Petroleum Act and until very recently Qld government policy describe this water extracted in CSG production as a waste product. The Qld government invited submissions to a draft Coal Seam Gas Water Management Policy 2012. That submission process is over and the final policy has been released. 

Below are selected extracts from Property Rights Australia submission to the draft policy on CSG water management  

The draft policy correctly states that CSG water should not be treated as a waste product. Underground water is a very important resource and should be treated as such.

Landowners are limited by license in their water use but CSG companies are unfettered. The drawdown of aquifers in CSG areas is a primary concern of Property Rights Australia. Any substitute for clean, reliable underground water is a second grade option and should be recognised as such. Depletion of aquifers which service premium agricultural land sterilises that land and makes it unavailable as a reliable resource for an indispensable commodity, namely food, to future generations. 

“Make good” provisions are littered with uncertainty and unfairness.  The store set in the “make good” provisions by government and public officials is alarming. Government and public officials seem unconcerned at water drawdown and depressurisation as a result of this confidence when these provisions are untested.  Too much weight is being given to the inferior action of “make good” provisions when the EPA will only stop local extraction for catastrophic effects if companies are unable to “make good” or provide substitution. This is not good enough!  “Make good” is a poor substitute for a reliable clean underground water source. 

Well drafted, detailed, step by step “make good” agreements seem to be essential in contracts between landowners and CSG companies operating on landowner’s lands. It remains to be tested how difficult it will be to have the implications implemented and what steps are necessary should a dispute arise.

It is a concern that landowner’s bores experiencing impacts of who do not have a company operating on their property may have to jump through extra hoops to access “make good”. 

It is of concern that Government and public officials have not recognised that water quality is just as important as quantity of water available for landowners. Both crops and livestock can experience reduced performance from lower quality water and if this has been caused by CSG activity it must be recognised as an equally severe impact. 

A major failing of the draft policy is that it does not recognise any other contaminant present in CSG water other than salt. The policy does recognise that the quality of CSG water varies greatly. The amount and composition of remaining chemical elements and compounds needs to be known on a consignment by consignment basis.  Once treated the CSG water should be put to a suitable beneficial use. However it needs to be recognised that brine is not the only contaminant present in CSG water. Farmlands, farm aquifers and stock watering facilities should not be put at risk of contamination by any chemical elements and compounds that can cause impairment including substances such as heavy metals.

There are emerging new technologies of water treatment that when used as a replacement of or in tandem to the existing reverse osmosis water treatment plants will provide a far superior result in quality of water available to beneficial water uses and for the less volume of waste produced. 

The draft policy in Section 1.1, Priority 1 states that, “Appropriate plans are in place for mitigating short and long term impacts” It would be a far more satisfactory approach if proactive research is carried out to learn of possible impacts before they occur rather than continuing with the flawed “adaptive management” approach inherited from the previous Government. 

Baseline data needs to be ascertained; priority given to a comprehensive network of monitoring bores including bores to different aquifers at the same geographic location; the level of connectivity between aquifers needs careful research and the work of the Queensland Water Commission soon to be carried out by the new statutory body. Office of Underground Water Assessment should be independent & transparent.

There is no substitute for a clean, reliable underground water supply. All other options are vastly inferior.