Our Position on Coal Seam Gas (CSG)
Six Degrees considers the Coal Seam Gas (CSG) industry to have serious environmental and health impacts that need to be understood and addressed by State Government before any further decisions are taken to proceed with the full development of current coal seam basins and associated infrastructure.
We advocate for robust investigation into the potential impacts on the ecosystem services provided by agricultural land, on human health, on environmental toxicology, and especially about the potential degradation of groundwater systems, including the Great Artesian Basin - one of the few reliable sources of fresh water for inland Australia.
Six Degrees considers that the current policies and management arrangements of the Queensland State Government are lagging significantly behind industry developments in this area.
As a consequence, CSG companies are being permitted to effectively carry out an uncontrolled experiment on the Queensland environment with potentially catastrophic consequences.
Background on Coal Seam Gas
Coal Seam Gas (sometimes referred to as coal-bed methane) is methane gas with small amounts of other gases such as carbon dioxide which are removed before the methane is used as a fuel or chemical feed. CSG is naturally kept under some pressure within cracks and pores in underground coal seams by the action of water molecules.
To get it out, a bore is sunk through to the coal seam where, under the natural water pressure or by a pump, the gas begins to flow to the surface with the water. At the surface a simple separation operation divides the gas from water and each is piped off. The gas is pumped through pipelines at high pressure to users.
Coal seam gas water is groundwater necessarily or unavoidably brought to the surface in the process of coal seam gas production. The amount of coal seam gas water produced during coal seam gas development varies both with the location and stage of the production cycle.
Likewise, the quality of coal seam gas water is highly variable but it frequently contains high quantities of salt and other contaminants that limit the water’s use without treatment.
It has been suggested that the Surat Basin and Darling Downs could have as many as 40,000 wells constructed in the coming years. At this scale of production, the farming lands of the Surat Basin/Darling Downs could contain more than 7.5 million tonnes of salt.
Much of the water produced from coal seam gas extraction in Queensland’s Surat Basin is also contaminated with metals and toxic hydrocarbons of various types from the coal seams. Releasing it untreated into the natural environment is not an option.
For some excellent overviews of Coal Seam Gas:
- What we don't know about Natural Gas Drilling @ ProPublica
- Coal Seam Gas overview @ Caroona Coal Action Group
- Undermined: a documentary from Sixty Minutes
- Hydraulic Fracturing 101 (or fracking) @ Earthworks
Coal Seam Gas Water
The waste or ‘product’ water is presently dumped into above ground evaporation ponds, ranging from 1 to 100 hectares in area. The volumes of water anticipated at full export production are 281,000 million litres per year.
Disposal of an annual volume of 281 GL (based on the upper estimates of the potential size of a Queensland LNG industry by the Queensland Government) in two-metre-deep ponds requires 14,000 ha in year one, and 280,000 ha (280 km2) by year 15. If 8-metre-deep-ponds are used, initially 3,500 ha are required, building up to 280 km2 by year 30.
There are widespread concerns about evaporation ponds and the long-term legacy associated with salt, heavy metals and fracking chemicals stored in them. Also, as the CSG industry expands, there are concerns about the groundwater and landscape impacts of coal seam gas extraction and coal seam gas water disposal methods.
For more information on the water risks associated with CSG:
The Queensland Government has recently enacted the Queensland Coal Seam Gas Water Management Policy (June 2010) which states, among other positions
- discontinuing the use of evaporation ponds as a primary means of disposal of coal seam gas water. Transitional arrangements will be developed by the government in consultation with industry to address issues with existing evaporation ponds. Remediation of existing evaporation ponds is to occur within three years.
- making CSG producers responsible for treating and disposing of coal seam gas water. Unless the producers use direct injection of coal seam gas water or have arrangements for environmentally acceptable direct use of untreated coal seam gas water, coal seam gas water must be treated to a standard defined by the Environmental Protection Agency (EPA) before disposal or supply to other water users.
Download the CSG Management Policy here.
Despite this, there is evidence that evaporation ponds are still being constructed, and remain favoured as the cheapest option for CSG producers.
Current alternative approaches consist of lined ‘turkey nest’ dam constructions, which are tantamount to evaporation ponds. Alternative arrangements are available; for example, the product water could be pumped back underground as is done extensively in US and Canada.
The CSG reserves and developing fields are, naturally enough, currently around the margins of the major deep coal basins such as Surat, Bowen and Gallilee basins. Much of the Surat basin CSG for instance, is under high quality agricultural land which has led to some deep concerns from the community about the impact of this industry.
Coal seam gas production in this area has a likely lifespan of thirty years, and the prospect of thousands of hectares of evaporation ponds turning into dry, heavily contaminated metre-deep dust bowls is a very present risk.
There are possible risks to health - experts have suggested as plausible the spread of disease-bearing saline habitat mosquitoes. Risks of chemical residue contamination of meat and crops from proposed use of product water for irrigation or stock watering, are currently under investigation.
There are also risks to the natural environment from permitted discharges to ephemeral creeks in areas of national environmental concern, particularly where the storage ponds are located on floodplains or flood-prone areas.
To date there has been little or no publicly available evidence that there is complete compliance with issued conditions from environmental authorities as to water quality testing and use. There remains confusion as to who owns, and is therefore responsible for, the product water when it reaches the surface.
Recommended Regulatory Protections
The Senate Standing Committee on Environment, Communities and the Arts presented the findings of its Inquiry into the impacts of mining in the Murray Darling Basin in December 2009. Among the recommendations of this report, the Committee found that the impact of coal seam methane extraction on water connectivity was not well understood due to the emerging nature of the industry. As a consequence, they recommended that:
- as a matter of priority and preferably prior to the release of future Mineral Exploration Licences, state governments establish regional water plans in areas potentially subject to mining or extractive industry operations.
- the Commonwealth Government works to ensure the prevention of new mines or extractive industries in the Murray Darling Basin if their impacts on water resources are inconsistent with the Basin Plan.
Six Degrees calls on the Queensland State Government to impose immediately a moratorium on all further CSG development until it can be unequivocally demonstrated that they will not have unacceptable social and environmental impacts.
We anticipate that the minimum amount of time required to establish a sufficient evidence base to proceed with CSG development is five years.
We call on the Queensland State Government to enact the statutory arrangements for the establishment of an Assessment Commission, substantially modeled on the Commonwealth’s Resource Assessment Commission, to undertake this investigation. The Assessment Commission should also undertake independent, robust and transparent assessments, through which the proponent of a CSG development must demonstrate that such a development is in the long term public interest and be allowed to proceed, given the array of unacceptable social and environmental risks.
Our position on the environmental and health risks associated with CSG are detailed below:
Robust and Transparent Impact Assessment
- We call for a robust, transparent and independent assessment of the environmental impacts of the proposed CSG extraction. These projects have been given a 'tick the box' simple environmental approval for the activities they are currently conducting in the Surat Basin – which includes the construction of thousands of gas wells, water and gas pipelines, compressor stations, involves significant land clearing and arrangements for selling the gas on the domestic market. No environmental impact statements were required. These are required only for the export side of the operation.
Water Management and Aquifer Protection
- We require a much greater level of understanding of the impact of the enormous levels of water extraction (which some estimate could extend to 350,000 megalitres a year of water from the Walloon Coal Measures which are part of the Great Artesian Basin) on the groundwater-surface water connectivity and the security of the resource for both consumptive and environmental purposes. There is significant risk that extracting this water will cause de-pressurisation of these aquifers with possible upward or downward movement in the rest of the Great Artesian Basin, depending on the conductivity of containing material. This could cause serious water table draw-downs and aquifer contamination, and may have irreversible consequences for the security of the water resource.
Disposal of Salt and Land Contamination
- We have grave concerns about the use and disposal of salt and other materials contained within the coal seam gas water. About 2 million tonnes of salt a year will be brought to the surface in this water extraction - roughly the same amount that goes down the entire Murray Darling system each year. Due to the storage options currently in use, the flood events common in the region are at significant risk of overflow. In these instances, the contaminated water will cover some of these high clay content cropping lands, the salt will destroy the capacity of the land to produce. The high clay content of much of the cropping lands in the Surat region allows for greater water retention, and a second harvest each year, which would also make any water contamination even more devastating. Damage caused to areas which are among the most productive areas of Queensland's agricultural belt will force food production into less productive farmlands, where more intensive, less ecologically sustainable methods would be necessary to provide similar crops. This would be a permanent and irreversible tragedy that will compromise Queensland’s ecological productivity and integrity, and our food security.
Limited Accountability and Responsible Governance
- There remains insufficient certainty in relation to accountability and responsibility to allow the expansion of this industry to proceed at the present time. The companies still do not know what to do with the water they are extracting. The Queensland Government has said they cannot just evaporate it in ponds on any long term basis so they are looking at using reverse osmosis to desalinate it and irrigate salt-tolerant plants, sell it to local communities, pipe it across country to power stations or re-inject it into aquifers other than the ones they came from. All of these have potentially serious, and as yet uninvestigated, consequences.
Disclosure on Fracking Chemicals
- We are deeply concerned about lack of disclosure by the CSG companies regarding the chemicals being used in the hydrological fracturing, or fracking, process. Hydraulic fracturing (or fracking) is a well stimulation technique which consists of pumping a fluid and a propping agent (“proppant”) such as sand down the wellbore under high pressure to create fractures in the hydrocarbon-bearing rock. Fracking includes the use of a fluid, consisting of water, hydrochloric acid and additives including surfactants, bactericides, clay and iron inhibitors and nitrogen. There is a wide array of chemicals that can be used to fulfil these functions, but at the present time our ability to assess the risks associated with these chemicals is prevented by the absolute lack of disclosure as to what is being used for fracking in Queensland.
Consistency in Regulation
- The expansion of the CSG industry cannot proceed without being subject to the same environmental regulations of landholders in the region. Currently, the CSG industry is exempt from the underground water extraction and tree clearing controls that other rural landowners have to abide by.
Climate Change Impacts
- Naturally, Six Degrees are very concerned about the impacts of accelerated CSG extraction on the climate. The greenhouse gas emissions from the four proposed projects in the Surat Basin - extracting the gas, piping it, compressing it, liquefying it, flaring and venting it and clearing land, all before any gets put into an overseas power station - will produce 10% of our national 2020 target and 20% of our 2050 target. They will increase the overall national emissions from the entire mining sector by 67%. This calls into serious question claims that gas is a clean energy source.
Impacts on the Natural Environment
- From a natural environment perspective, we have deep concerns about the impacts of the extraction on environmental integrity, biodiversity and water quality and quantity, and believes that there should be no further expansion of this industry until there is sufficient evidence to guarantee that these impacts will not occur. There will be serious impacts on biodiversity from the thousands of hectares of land clearing needed for gas wells, connecting pipelines, the overland pipelines to the port of Gladstone as well as the building of associated infrastructure. The area affected contains many threatened species. Contamination of aquifers also has possible ramifications for the springs, wetlands, rivers and lakes that are connected to the aquifers. The springs alone contain many species, including 14 endemic species.
Participation of Traditional Owners
- Questions remain to be answered about the participation of Indigenous communities and Traditional Owners in decisions relating to the expansion of the CSG industry. The springs fed by the Great Artesian Basin are well known to have cultural heritage significance for Aboriginal people going back many thousands of years. Some of these have already dried up because of over-allocation of water within the Basin, particularly within the area known as the Condamine Alluvium.
Health impacts on Residential Communities
- The US experience with this industry is that there are serious health impacts for nearby residents resulting from the poisoning of local underground and surface water. Some of the wells in the Surat Basin are within 100 metres of residences. These wells, pipelines and LNG plants can also explode, such as occurred in Texas, USA on June 7th, 2010.
Adaptive environmental management regime is a structured, iterative process of optimal decision making in the face of uncertainty, with an aim to reduce uncertainty over time via system monitoring and instigating change where required.
Aggregation dam is a dam that receives and contains CSG water or CSG water concentrate. An aggregation dam must be designed and operated so that during any period of 30 days, following the first 90 days of operation of the dam, the total volume of water leaving the dam, other than by evaporation, must not be less than 85 per cent of the volume of water that has entered the dam.
Brine is defined as saline water with a total dissolved solid concentration greater than 40,000 milligrams per litre. Brine dam means a dam designed to receive, contain or evaporate brine.
CSG water is defined as underground water brought to the surface of the earth or moved underground in connection with exploring for, or producing, coal seam gas. When brought to the surface, it is referred to as 'product water'.
CSG water concentrate is the concentrated saline water waste stream from a water treatment process that does not exceed a total dissolved solid concentration of 40,000 milligrams per litre.
CSG evaporation dam is defined as an impoundment, enclosure or structure that is designed to be used to hold CSG water for evaporation.
Saline effluent includes both CSG water concentrate and brine.
These definitions are taken from the Queensland Government's CSG Water Management Policy, June 2010.