To The Commissioner,
Thanks for taking on this important task.
I first heard of this inquiry when I saw the head of the EPA on the nightly news, welcoming this as an opportunity to streamline future assessments of fracking applications. Please be clear in your report that this is no such thing, that the NT's environmental assessment laws provide no framework or structure for streamlining assessments, and that fracking projects presents significant risk that must be fully assessed. It may be that the EPA should conduct a strategic assessment of likely cumulative impacts, however this should in now way diminish the integrity and stringency of assessments of individual project proposals.
I'd like to respond to some claims regarding supposed benefits of fossil fuel development.
Santos calls natural gas "the fuel of the future" - but I recognise that gas is just another dirty old fossil fuel. They say natural gas will provide us wealth and energy security while fuelling our region. But I don't see that.
What I see is urgency to exploit this resource in the small window of time in which tentative carbon budgeting gives it value. I do recognise that demand for natural gas is in part driven by the fact that it is slightly less carbon intensive than other fossil fuels like coal and oil. But I also recognise that the same rationale will soon make gas as unpopular as these slightly dirtier counterparts. This perspective gives an economic rationalisation of the mad rush we see to suck it out and sell it to the first bidder, but also calls into question claims of energy security and prosperity.
An abundance of climate-wrecking dirty old fuel is not a basis for energy security. And a commodity whose value is likely to be soon trashed by the same forces that currently happen to be making it desirable is not a good long term investment. We'd be mad to pump infrastructure funding into new fossil fuel plants, that would then lock us in to the costs and responsibility of burning that dirty fuel for decades to come - or abandoning the infrastructure early. It might make sense in less wealthy countries who lack our renewable advantage, but in Australia, the lucky, sunny country, we can afford to allocate infrastructure investment wisely to capitalise on the abundance of renewable resource we live with.
There may be some value in gas for co-generation, but right now industry can't point to much evidence of a plan to enact this vision. In fact, right now it appears that the Australian Government is establishing temporary policy obstacles that appear to be achieving the perverse goal of slowing down and frustrating the inevitable rise of renewables. Given the poor policy settings of this federal government, perhaps the best approach to this one potential benefit of gas would be to leave it in the ground until the renewable dominos are lined up.
Santos rightly claim that LNG can cut emissions in export markets. Unfortunately, this is a capacity, rather than an inherent attribute of LNG. Without a framework for emissions trading (either domestic or international) it is highly unlikely that this capacity will be realised. In fact, in the absence of carbon pricing to enable international trade, it should be expected that any immediate exploitation will merely add to humanity's collective carbon debt. Without a framework to guarantee that LNG is actually displacing some existing dirtier fuel consumption, it might be a better heuristic to assume that the world is simply burning more : more gas, more coal, more oil, more uranium: more, more more. Santos' calculations for carbon savings made "when this gas is substituted for coal" are predicated on fantasy: we have no solid grounds for making this presumption that our dirty gas exports actually are displaying dirtier coal. Projections decades into a future that might just as easily be powered by the sun are plain false accounting.
I wholeheartedly reject the claim that natural gas will significantly reduce greenhouse emissions. It could play a role, in the right policy environment, as part of a broader strategy. But the current policy environment is one of unfettered growth and accelerated consumption, with no genuine target, let alone a strategy to reach it.
I share other concerns raised by many contributors to your inquiry. I particularly endorse the contribution from the Environment Centre of the NT. I do have grave concerns about the water consumption of fracking, given that the top end of the NT experiences annual drought, while much of the remainder is desert, and everyone drinks bore water. The only way the industry could proceed at the volume it is threatening would be to ignore the efforts all other water users have made to cooperatively manage their shared resource. I'm not certain about the risk of water contamination from well failure, however I am very concerned, and look to this inquiry to learn more about it.
But the single greatest environmental disqualification I see to fracking is that it opens up a whole new world of fossil fuel exploitation, without any frameworks to guarantee it will be wisely applied for cogeneration with renewables or genuine displacement of coal. Without such guarantees, this dirty old fossil fuel will only add to our carbon burden, and on this basis alone I recommend that fracking be banned. I understand that there is a popular demand for a moratorium pending anticipated amendments to water allocation laws, and greater certainty over groundwater contamination risk. In this eventuality, I recommend a further caveat against the industry that makes carbon pricing and a renewables roadmap a precondition to any further gas exploitation.
Thanks, and good luck with your work.