Dear Commissioner,
I wish to make a submission concerning the Northern
Territory Governments inquiry into hydraulic fracturing and the
exploration of shale and tight gas. I call on you to make
recommendations to amend the laws of the Northern Territory (NT) in
response to the following concerns:
1. We don’t currently fully understand the impact of
hydraulic fracturing and horizontal gas exploration or the wide range
of implications on the environment, native fauna, flora and most
importantly the implications for human health. Therefore the law must:
- Require drilling competency standards to protect safety, health and resource management.
- Ensure sustainable resource management through the
collection of baseline scientific data in order to identify the
environmental impact of such activities, these should be published and
easily accessible to members of the public.
- Reflect the precautionary principle in environmental assessment and regulatory control.
2. Current NT laws do not allow for community consultation or public participation, therefore the law must:
- Provide sufficient public consultation through adequate
notice of proposed exploration ventures. Simply advertising once in a
local newspaper is unjust and does not allow the public an opportunity
to voice their concerns.
- Facilitate the landowner and provide the opportunity
for the affected parties to exercise the right to object or refuse gas
exploration on their land.
- Require the publication of the Ministers reasons for
decision and all associated documentation considered by the Minister in
the decision making process, including Environmental Impact Statements
and Assessments (EIS & EIA).
- Allow, support and facilitate an independent third party to carry out external reviews of any decision made by the Minister.
- Provide an opportunity for the appeal of a decision made by the Minister to an independent organisation or tribunal.
- Allow the regulation of access to land by explorers and operators and allow the land owner to specify terms of access.
3. Environmental Impact Assessment (EIA) is not adequate, therefore the law must:
- Be amended to ensure each project with the potential
for environmental degradation is properly assessed not just
economically but also environmentally in order to achieve the central
goal of the EIA process, sustainable development.
- Allow the EIA process and all decisions made to be transparent and readily available for public submission.
- Require EIA & EIS for exploration activity. It
would be considered highly detrimental to propose one EIA document may
suffice for all hydraulic fracturing ventures throughout the Territory
due to the vastly heterogeneous nature of the underlying stratigraphy.
- Require the operator to integrate the waste water
management planning and rehabilitation into the exploration and
production as a requirement for licencing.
- Require the consideration of all alternatives and provide for land use reservations.
4. Regulatory oversight is not effective, therefore the law should be changed to:
- An independent body such as the Environmental
Protection Agency (EPA) should be appointed to regulate all
environmental impacts of the hydraulic fracturing of shale and tight
gas in the Northern Territory. This should include sub-surface and
groundwater contamination as well as impact on biodiversity on site.
- Require frequent on site visits by environmental and regulatory officers.
- Remove intent and knowledge as elements of environmental offences.
- Substantially increase penalties and extend statute of limitations for prosecutions.
- Apply the Water Act to all mining activity in
the Northern Territory including the exploration for hydraulic
fracturing of shale and tight gas. This will allow for the excessive
water use these operations require to be closely monitored and
regulated.
- Apply the Waste Management and Pollution Control Act to all mining activity, regardless of where it takes place across Australia.
- Implement suitable structural co-ordination between the relevant Government agencies.
5. The real cost of Hydraulic Fracturing should be known and recovered from Operators, including:
- Wear and tear on existing infrastructure including public roads.
- Water usage and pollution.
- Cost for the rehabilitation of the decommissioned gas wells and fields.
- Reduction in value of land to landholders as a result of Hydraulic fracturing of shale and tight gas.
- Loss of ecology and biodiversity.
- Impact on human health.
Additional to these concerns I have a number of
other concerns regarding the operational logistics of shale and tight
gas exploration and the impacts on human health, these are as follows:
Human Health: Communities living near gas
fields in the US have reported serious health effects following the
commencement of shale and tight gas operations. Additional to this
residents of Tara in Queensland have also reported a wide range of
health effects following the exploration of shale and tight gas in
their local areas. The reported health implications are as follows:
- respiratory and neurological effects
- severe headaches
- nausea, vomiting
- nose bleeds, rashes, eye and throat irritations
- severe skin irritations
- higher risks for cancer
Impacts on human health and the environment.
- Excessively high water usage.
- Excessively high use of harmful chemicals of which up to 70% remain underground.
- Loss of traditional land, sacred sites, highly fertile farm land and national parks.
- High risk of groundwater contamination, this is of
great concern as both rural and remote communities in the Northern
Territory depend upon these resources.
- Migration of gas, methane and other toxic substances
into groundwater or aquifers through fracturing of tight and shale gas
induced pathways.
- Soil and sub-surface water contamination due to chemical laden waste water and retention ponds.
- Air pollution from hazardous air pollutants released from wells and infrastructure before, during and after operation.
- Major threat to human and environmental health.
I am very concerned at the wide range of potential health
risks associated with hydraulic fracturing and exploration of shale and
tight gas. Having studied Nursing for a number of years I am well aware
of such risks and I feel these pose a great danger to already
vulnerable minority groups throughout remote areas of the Northern
Territory. I would like to thank you for your time on this matter and I
would like to call on you to make the correct and necessary changes to
the current laws in order to protect the environment and most
importantly human health. I would also like to call on you to take
action against the current Northern Territory Government and their
plans to destroy large parcels of land across the Northern Territory. I
thoroughly look forward to the pleasure of speaking with you in the
near future concerning this matter.
Regards
