Dear Commissioner
I write to you as a concerned NT resident, father, and Registered Nurse. The adverse events that have occurred as a result of Hydraulic Fracturing for gas (HF) around the world are concerning. I am concerned because of what the possible adverse effects of HF could do to the Northern Territory. I am not alone in this concern. Many individuals, organisations, and countries share this concern. Many countries are concerned enough to have banned HF. It is my position that the NTG should do the same – until more is known about HF and the effects it can have. I also believe that the NTG needs to wait until it has the resources to manage and regulate this industry in a safe way.
Here is a basic outline of my logic – which I will expand on later in this submission. Adverse events can occur as a result of HF. Mining companies and government can manage these adverse events – to an extent. The effects of these adverse events are not entirely known – however it has been established that they can lead to serious ill health and damage to the environment. My major concern is that these possible adverse outcomes are not entirely preventable – and when they happen they can have a devastating effect on human lives and the environment. To me this is not worth risking.
For me: the most important consideration is the health of people. When it comes to health: governments need to adopt basic ethical principles. The first principle is non-maleficence. That is: first – do no harm. In this case: the government needs to enact precautions based on potential negative impacts. The National Water Initiative (NWI) assessment (established by the Federal Government) concluded that there are significant uncertainties about the impact that HF could have on ground and surface water resources. It is known that many of the chemicals used in HF cause ill health – for example: hydrochloric acid, ethylene glycol, sodium borate, guar gum, dimethyl formamide, isopropanol – to name a small few. Some of the chemicals used are known carcinogens. On top of this: only a minority of chemicals used in HF has been fully assessed by the National Industrial Chemical and Assessment Scheme. It would be fine to consider HF if there was a guarantee that these chemicals could not reach our water supply and rivers. However – this guarantee cannot be made. For example: it is known that boron and methane is difficult to extract from the effluent – and can sometimes remain in the water post treatment. There is also room for error in the processes of HF.
Errors have been made. It is preventable to some extent – but there is never a guarantee. For example: the well can accidentally extend into an aquifer, well casings can fail, effluent can leaks from a storage pond – to name a few. Water storage is a great concern in the NT due to the large volumes of water movement during the wet season. Having open storage ponds full of hazardous chemicals is concerning in a monsoon environment. Mt Todd is an example of where this can go wrong. In this instance: water that was contaminated with cadmium, copper, and zinc – to mention a few – overflowed from Vista gold mine storage ponds into a subsidiary of the Edith River as a result of heavy rains. The Northern Territory Environment Protection Authority (NTEPA) concluded that this release had the potential to cause environmental harm – and that it was a result of a lack of planning and poor regulation. It has also been found that fish in the area were found to have elevated levels of mercury. Such mercury toxicity can cause many serious health problems – including significant growth impairment in utero. The NT Government was left with an estimated $122 million cleanup bill. In another recent incident: a Santos HF pond in NSW leaked. The groundwater downstream from the pond was contaminated – containing 20 times the safe level of uranium. Another example was revealed by an independent study into the unconventional gas mining in Tara QLD – showing evidence of increased levels of carbon dioxide and methane (there are likely to be other gases) in the air – which are suspected to have caused illness in nearby communities. Who is going to monitor the hundreds or thousands of wells in the NT? How will we ensure that this monitoring is rigorous? Is the NTG going to commit to regulating this industry – conducting rigorous monitoring to protect NT resident from the possible effects of HF?
Currently: it is largely mining companies who regulate how they prevent such adverse events. A mining company’s reason for existence – their primary goal – Is to make money. This supersedes their commitment to regulatory measures and environmental health. Ethical principles usually come into such a company’s consideration – however it is not non-maleficence that is their primary objective. It needs to be when human health is at stake.
My next major concern is the environment. The Northern Territory’s environment is one of a great, diverse splendor – which attracts people from all over the world. The abundant, diverse flora and fauna – of course – relies on clean water. Water contaminated with the chemicals used in HF can do – and has done – great damage to the environment. Even if adverse events were 100% preventable: there is still a large amount of damage done to the environment through the process of establishing and maintaining a gas well. There’s the clearing of land, creation of structures, building ponds to hold wastewater, creation of new roads, to name a few. As seen in QLD: this can leave large areas of land transformed into baron wastelands. Then there is the addition of hundreds of trucks for each well on our roads. With such destruction of flora, fauna, and country: we are likely damaging our state’s tourism industry. Tourism is a sustainable industry – which will be around for much longer than mining. It provides significant profit for our state (over 9% of GSP) – as well as significant employment (13% of NT employment – compared to around 3% from the entire mining industry).
Then there is the issue of water. The NWI concluded that hydraulic fracturing has not yet been properly integrated into water planning and management frameworks throughout Australia. Water is a fragile resource and is in great demand in the NT. The wet season often provides substantial amounts – however this is not always the case. Often we need to rely on ground water. Each HF well will require between 2-38 million litres of water – which will depend on the length of the well, the use of horizontal drilling, the number of fracking stages, etc. This large use can create risks for third parties – such as farmers. Allocating such large amounts of water to industry needs to be well planned – and right now it is considered – by a Federal Government taskforce – that this plan is insufficient.
My last major concern is the amount of public opposition there is to HF. This opposition seems to come from many people of the NT: traditional owners, farmers, healthcare, environmentalists, fishers, tourism, politicians, etc. Victoria has a moratorium until the end of 2014 – or until the research says it is safe. NSW had a moratorium. HF also has a large international opposition. The following countries have banned HF - France, Bulgaria, Romania, South Africa, Germany, Czech Republic – to name a few. Areas of the following countries have banned HF - USA, Argentina, Spain, Switzerland, Austria, Italy, NZ, Canada – to name a few. This concern is not just a matter of speculation and fear mongering; governments across the world are acting upon their concern – which has been raised by scientific evidence. An undertaking like this needs to have the support of a large percentage of the people – and right now it seems as though this is not the case.
Yours Sincerely
Kayne Jansen