Submission to the Independent Planning Commission on the Narrabri Gas Project
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Submission to the Independent Planning
Commission on the Narrabri Gas Project
Introduction
In its Letter of Referral to the Independent Planning Commission, the Department of
Planning, Industry and Environment (DPIE), concludes that the proposed Narrabri Gas
project is “approvable” and that it is “critical for energy security and reliability in NSW”
which will provide a series of benefits to New South Wales and Australia in general. These
include:
• Providing essential gas supplies to the domestic market;
• Providing economic benefits to the Narrabri region and the State;
• Supporting the development of gas-fired power stations as a transition towards greater
reliance on renewables; and
• Putting downward pressure on gas prices.
The above conclusion is subject to the proponent’s meeting a recommended “comprehensive
suite of strict conditions”, 61 pages of conditions, in fact, which will help ensure that the
Project complies with relevant legislation, regulation etc and so that it will “not result in any
significant impacts on people or the environment”.1
In my view, each of these “conclusions” is at best highly debatable, for which reason I
oppose the Project. I shall examine them in the following sections.
Essential gas supplies to the domestic market
At the outset it should be noted that it is not just DPIE that supports the “more gas is needed
for domestic purposes” argument. The Commonwealth Government from the Prime Minister
down are keen supporters of this argument and, indeed, the need for more fossil fuel power
generation, with a somewhat equivocal level of support from the NSW State Government.2
In 2019 Australia became the world’s biggest exporter of natural gas.3 According to a number
of energy industry sources Australia has plenty of gas with one gas executive being quoted as
1
DPIE Letter of Referral, 12 June 2020 at: https://www.ipcn.nsw.gov.au/resources/pac/media/files/
pac/projects/2020/03/narrabri-gas-project/referral-from-the-department-of-planning-industry-and-
environment/dpie-letter-of-referral.pdf
2
Mike Foley, “NSW the winner from ‘non-binding’ energy deal with Morrison government,” Sydney Morning
Herald, 4 February 2020, at: https://www.smh.com.au/politics/federal/nsw-the-winner-from-non-binding-
energy-deal-with-morrison-government-20200203-p53xah.html
3
Nick Toscano, “Australia tops Qatar as world’s biggest LNG exporter”, Sydney Morning Herald, 6 January
2020, at: https://www.smh.com.au/business/the-economy/australia-tops-qatar-as-world-s-biggest-lng-exporter-
20200106-p53p5h.html
1saying that Bass Strait gas could supply Victoria, NSW and Queensland “indefinitely.”4,5
Furthermore, the East Coast transmission pipeline system is an “interconnected grid covering
Queensland, New South Wales, Victoria, South Australia, Tasmania and the ACT” … most
of which is “bi-directional which means that gas produced in Queensland can be used in
Tasmania and gas from Bass Strait can be sent to as far north as Gladstone … and it means
gas can be sent where it is needed.”6
Taken together, the above factors suggest that it is, at the very least, contestable to assert that
it is essential for energy security and/or reliability reasons to get more gas into the domestic
market. Were it not so serious from human and environmental health consequences, it would
be risible to suggest that the biggest exporter of LNG in the world is unable to supply its own
domestic gas needs quite comfortably.
Indeed, if there is a “shortage” of gas to the domestic market on the East coast it is not
because there is insufficient gas but because of systematic policy failures by State and
Commonwealth government over several years to allow the existence of a non-competitive
gas market and the development of three LNG plants in Queensland which funnel Australian
gas overseas.7,8
Economic benefits to the Narrabri region and the State
The DPIE Letter of referral states that the Project would create 1,300 jobs during construction
and 200 jobs during operations and also quotes that Santos will provide money to the
Narrabri Council for various community projects and a Community Benefit Fund. I note that
the quoted dollar amounts are both qualified by the words “up to”.
It may well be that these figures are valid and, if so, are of undoubted benefit to the State and
the Narrabri region. There is no mention, however, of the cost of deriving these community
benefits or of alternative means of achieving similar benefits.
Unmentioned costs of achieving claimed economic benefits
Costs associated with CSG mining are well-documented and include the health costs of
increased air and noise pollution, environmental degradation and community disruption. A
review of 685 peer-reviewed scientific papers about the impact of unconventional natural gas
development concluded that 84% of public health studies contain findings that indicate public
4
Samantha Hepburn, Australia has plenty of gas, but our bills are ridiculous. The market is broken.” The
Conversation, 22 October, 2019 at: https://theconversation.com/australia-has-plenty-of-gas-but-our-bills-are-
ridiculous-the-market-is-broken-125130
5
Charis Chang, “How Australia is being screwed over its gas” 17 March 2017, at: https://www.news.com.au/
finance/economy/australian-economy/how-australia-is-being-screwed-over-its-gas/news-story/
4187e60617aec18e87d57453cfca0167
6
APGA, Pipeline facts and figures – East coast gas transmission pipeline system, East Coast gas grid, at:
https://www.apga.org.au/pipeline-facts-and-figures
7
Samantha Hepburn, 22 October 2019, as cited above.
8
Charis Chang, 17 March 2017, as cited above.
2health hazards, elevated risks, or adverse health outcomes; 69% of water quality studies
contain findings that indicate potential, positive association, or actual incidence of water
contamination; and 87% of air quality studies contain findings that indicate elevated air
pollutant emissions and/or atmospheric concentrations. 9
In Australia, there is the additional cost to the whole community of having to absorb and
mitigate the additional greenhouse gas emissions caused by the Santos Narrabri Project, if
Australia is to meet its Paris Climate Agreement commitments.
While there is debate about the amounts of emissions from extracting CSG and burning it, in
particular fugitive methane emissions which are about 25% more harmful than CO2, there is
no doubt that CSG mining and use do pollute. In addition to CO2, gas-fired power stations
produce substantial quantities of carbon monoxide, oxides of nitrogen and sulphur, VOCs and
particulate matter – both PM10 and the particularly harmful PM2.5.10
Air pollution alone, including that from extracting and burning fossil fuels and motor
vehicles, costs Australia an estimated $16 billion per year11 and contributes to over 3,000
premature deaths each year.12
Renewable energy benefits
In terms of alternative ways of producing economic benefits and enhancing energy supply,
there is increasing evidence that investment in renewable energy projects and technologies
could provide as many if not more clean and green jobs and community benefits than the
continued pursuit of dirty fossil fuel jobs.13,14 Green jobs are on the ascendant whereas fossil
fuel jobs and investment are on the decline as the world moves to greater reliance on
renewable energy. These jobs are likely to decline more rapidly as big investment bodies
9
Jake Hays and Seth B C Shonkoff, “Toward an Understanding of the Environmental and Public Health
Impacts of Unconventional Natural Gas Development: A Categorical Assessment of the Peer-Reviewed
Scientific Literature, 2009-2015”, PLoS One, v.11(4); 2016 at: https://www.ncbi.nlm.nih.gov/pmc/
articles/PMC4838293/
10
National Pollutant Index e.g. AGL’s gas-fired LPG liquification plant at Wallumbilla, QLD at:
http://www.npi.gov.au/npidata/action/load/emission-by-individual-facility-result/criteria/state/
QLD/year/2019/jurisdiction-facility/Q012SAN013 and Somerton gas-fired power station in Victoria at:
http://www.npi.gov.au/npidata/action/load/emission-by-individual-facility-result/criteria/state/null/year/
2019/jurisdiction-facility/00021386
11
Health Effects Institute (2017), ‘State of Global, Air 2017’ (online database), www.stateofglobalair.org.
Ambient PM + Ozone mortality: Australia -3099 deaths (2015 global burden of disease x $A5.2M the 2010
value of statistical life)
12
Institute of Health Metrics and Evaluation (IHME). GBD Compare Data Visualization. Seattle, WA: IHME,
University of Washington, 2016. Available from: http://vizhub.healthdate.org/gbd-compare.
13
Beyond Zero Emissions, The Million Jobs Plan, June 2020, at: https://bze.org.au/mjp-thank-you/
14
Climate Council, The clean jobs plan, 21 July 2020, at https://www.climatecouncil.org.au/resources/clean-
jobs-plan/
3continue to divest their fossil fuel investments15,16 and any new fossil fuel investments such
as pipelines could become stranded assets.17
Supporting the development of gas-fired power stations
It is a highly contested assertion that Australia needs more gas-fired power stations as part of
our transition to more electricity from renewable sources. There are those who argue that this
is unnecessary and that the transition can be made without the ‘interim’ gas solution; that
renewables with storage will be sufficient, cheaper and cleaner than gas. That argument
aside, there is the view that CSG from Narrabri will not be cheap and will not bring prices
down and, even if it did, previous periods of low domestic gas prices did not lead to a
significant expansion of manufacturing jobs and industry which might need the power
produced by these additional plants.18
Putting downward pressure on gas prices
A major argument for the need to open new CSG fields in NSW is that additional gas will
bring down the price of energy in general and gas in particular.19,20
This assertion, too, is highly questionable for several reasons.
Firstly, as stated above, Australia has an abundance of gas and as a result is now the biggest
producer of LNG in the world. Thus, in the face of such abundance, it seems very debatable
that even more gas will reduce domestic prices. This view is supported by a number of
industry analysts.21
Secondly, CSG is expensive to obtain. The Australian Chief Scientist said unequivocally:
“shale gas will not be cheap in Australia.”22 In addition, Macquarie Bank analysts suggest
that the proposed four new gas import terminals around Australia, including at Port Kembla,
might seriously undermine the price competitiveness of CSG from the proposed Narrabri
15
Taylor Kuykendall et al., “Investment giant BlackRock marks a major milestone in coal divestment
movement”, S&P Global Intelligence, 22 January 2020, at: https://www.spglobal.com/marketintelligence/en/
news-insights/latest-news-headlines/56669181
16
Wouter Klijn, First State Super Divests Thermal Coal; Divestment Part of Broader Transition, i3 Investment
Innovation Institute, 9 July 2020, at: https://i3-invest.com/2020/07/first-state-super-divests-thermal-coal/
17
Nick Bonyhady, Mike Foley, “Back to the future with gas jobs plan”, Sydney Morning Herald, 29 July 2020,
page 1.
18
Nick Bonyhady, Mike Foley, “Back to the future with gas jobs plan”, as cited above.
19
Cheap gas, really? Why gas – from coal seams or ships – may not mean lower prices, ABC News 12 February
2020, at: https://www.abc.net.au/news/2020-02-12/coal-seam-gas-import-or-mining-will-not-guarantee-lower-
prices/11954268.
20
Mike Foley, “NSW the winner from ‘non-binding’ energy deal with Morrison government,” previously cited
21
Cheap gas, really? Why gas – from coal seams or ships – may not mean lower prices, cited previously.
22
Australian Government, Office of the Chief Scientist, “Engineering Energy: Unconventional Gas Production,
Recommendations”, June 2013, page 1 at: https://acola.org/wp-content/uploads/2018/08/shalegas-osc-
recommendations.pdf
4Project.23 One commentator went so far as to say that exporting gas from Australia and then
re-importing it at further cost was “economic suicide” while at the same time agreeing that
gas from Narrabri will not be low-cost.24
Thirdly, in early 2016 gas giant AGL announced to the Australian Stock Exchange that it was
abandoning its natural gas projects in NSW and Queensland and ceasing production at its
Camden Gas Project in 2023, twelve years earlier than expected. This was because “the
economic returns to support the investment of approximately $1 billion were not adequate.”25
A clear statement of support for the fact that CSG is expensive to obtain and process and
hardly a ringing endorsement of the assertion that more gas will bring down gas prices.
Finally, the Royal Dutch Shell Group, one of the world’s biggest fossil fuel and
petrochemical producers, is to build and operate a solar plant in Queensland with sufficient
output to power around 50,000 homes. It will not be used for domestic purposes, however,
rather it will be used to power natural gas processing plants26 and in so doing reduce the
carbon footprint of the company’s Queensland gas extraction operations by approximately
300,000 tonnes per year.27
The Shell decision is the clearest of indications that renewable sources of power generation
are cheaper than fossil fuel generated power, most pointedly in this case gas generated
electricity. It is also a clear indication of the huge amounts of greenhouse gas emissions
emanating from the production of CSG.
Skill, careful management, transparent and effective regulation and monitoring
In finally stating that its assessment concluded that the Narrabri Gas Project “is approvable
subject to strict conditions,” DPIE recommended a “comprehensive suite of strict
conditions.”28 This statement and the 61 pages of conditions recognise the complexity of the
whole project and the range of risks inherent in it.
23
Gas imports spells end of Santos’ controversial Narrabri CSG, analysts say, Sydney Morning Herald, July 9,
2018, at: https://www.smh.com.au/business/the-economy/gas-import-spells-end-of-santos-controversial-
narrabri-csg-analysts-say-20180709-p4zqe0.html
24
Cheap gas, really? Why gas – from coal seams or ships – may not mean lower prices, cited above
25
AGL pulls out of CSG plan in Gloucester as NSW and Queensland projects are abandoned, ABC News, 4
February 2016, at: https://www.abc.net.au/news/2016-02-04/gas-giant-agl-pulls-out-of-gloucester-csg-
project/7138784
26
Shell joins the renewable energy game solar panel investment, Energy Matters, February 11, 2020, at
https://www.energymatters.com.au/renewable-news/shell-joins-the-renewables-game-solar-panel-investment/
accessed 13 February 2020 and The Gangarri Solar Project at https://www.shell.com.au/energy-and-
innovation/the-energy-future/gangarri-solar-
project.html#iframe=L2Zvcm1zL2VuX2F1X3NvbGFyX2VucXVpcnk
27
Shell breaks ground on 120MW PV project to power onshore gas operations, February 7 2020, at
https://www.pv-magazine-australia.com/2020/02/07/shell-breaks-ground-on-120-mw-pv-project-to-power-
onshore-gas-operations/
28
DPIE Letter of Referral, 12 June 2020, as cited previously.
5The NSW Chief Scientist and Engineer said in relation to CSG extraction that risk
management had to be of a high order with stringent requirements and that current risk
management needed improvement to reach best practice.29 The Australian Chief Scientist
also reinforced the need for best practice regulation and monitoring and stated that it was a
matter of urgency to develop and implement a transparent, adaptive and effective regulatory
system.30 The Australian Council of Learned Academies’ report on unconventional gas
production also pointed out that companies involved in CSG mining “will require great skill,
persistence, capital and careful management of any impacts on ecosystems and related natural
resources” if they are to successfully mine CSG.31
Regrettably Santos and other CSG miners in Australia (and in other parts of the world) have
had a litany of accidents, spills, cover ups and non-disclosures..32,33,34 Equally regrettably,
many of these same accidents, incidents and cover ups reflect poorly on the competence and
effectiveness of the responsible regulators.
In recent years Australia has seen writ large huge failures both in private and public sector
governance and management and government regulation in a wide range of areas from child
sexual abuse, the aged care sector, the banking and insurance industries, management of
water in NSW, Queensland and Victoria, wide-spread wage underpayment, the Centrelink
Robo debt collection scheme, through to fraud in private Registered Training Organisations.
And yet governments continue to talk about “light touch regulation” and “cutting green and
red tape”.
This is hardly a history which encourages public trust in the competence and professionalism
of both the CSG industry and the government regulators, especially when it is widely
acknowledged that both need to be at best practice level to manage the identified, complex
and multi-faceted risks and exposures inherent in CSG mining.
For all of the above reasons, I oppose the Santos Narrabri gas project.
David W Roden, 31 July 2020
29
Chief Scientist & Engineer. Final Report of the Independent Review of Coal Seam Gas Activities in NSW,
NSW Government, September 2014.
30
Australian Government, Office of the Chief Scientist, Engineering Energy: Unconventional Gas Production,
Recommendations, June 2013, page 1 at: https://acola.org/wp-content/uploads/2018/08/shalegas-osc-
recommendations.pdf.
31
Cook, P, Beck, V, Brereton, D, Clark, R, Fisher, B, Kentish, S, Toomey, J and Williams, J (2013).
Engineering energy: unconventional gas production. Pp 19, Report for the Australian Council of Learned
Academies, www.acola.org.au.
32
Mike Foley, Santos fined over Pilliga spill, The Land, 10 Jan 2014, at: https://www.theland.com.au/story/
3581836/santos-fined-over-pilliga-spill/
33
Peter Hannam, “’Embarrassing’: Santo fined for using CSG water without a permit”, Sydney Morning Herald,
17 October 2018, at: https://www.smh.com.au/environment/conservation/embarrassing-santos-fined-for-using-
csg-water-without-a-permit-20181017-p50a7v.html
34
Ricketts, A. (31 October ,2012) Contaminated sites and accidents related specifically to CSG/LNG in
Australia. ACTIVIST. Accessed on 4th April, 2017 from: http://aidanricketts.com/contaminated-sites-and-
accidents-related-specifically-to-csglng
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