The environmental, social and human health importance of the aquifers and wetlands of the Lower South East of South Australia and SW Victoria and the increasing threats to their existence.

My submission to the Senate Select Committee on Unconventional Gas Mining March 2016

I am Marcia Lorenz B.A. Grad. Dip. Ed. Admin., a retired school teacher. I only discovered the attractions of the South East when I came to Beachport 12 years ago. I am a volunteer at the Millicent High School where I support the Aboriginal children in their work with their culture and the environment. I am also a volunteer with other environmental groups in the region.

My submission concerns the likely detrimental effect of unconventional gas extraction (“fracking”) on the aquifers and wetlands of the South East of South Australia and therefore on the myriad of species, both flora and fauna that constitute wetland habitats.

1 HISTORY

Historically, post white settlement, wetlands were viewed as wastelands with no thought being given to the natural environment and the diversity of species they contained. Economics was the driving force. It would be wonderful if we could say that times have changed and politically there is the realisation that in order for humans to exist, the natural environment must be taken into consideration. After all we now have knowledge that wasn’t available to the ordinary person in the early days of settlement.

Post European settlement change in land use has significantly altered the landscape of the South East resulting in the loss of many areas of wetland habitat with <6% of the original wetland extent now remaining.1

An estimated 2,515 km. of drains were installed to remove surface water and shallow groundwater from the landscape.1

Most ground water is now directed out to sea in some cases destroying seagrass meadows.

Yarra Pygmy Perch

2 UNDERGROUND AND SURFACE WATER FEATURES OF THE SOUTH EAST OF SOUTH AUSTRALIA

2.1 Aquifers The water used in the South East is generally extracted from either the confined or the unconfined aquifer but there are also many localised sub-aquifers.2

2.1.1 The Tertiary Confined Sand Aquifer (TCSA) The tertiary confined sand aquifer is used as the primary water supply for 8 towns in the region: Beachport, Kalangadoo, Kingston, Lucindale, Naracoorte, Port MacDonnell, Robe and Tarpeena.

The following information from PIRSA appears to describe it well.

2 The TCSA is a deep and relatively unpolluted aquifer at a depth of 35-300 metres. The water quality is very good because it is protected from contamination not only by its depth but also by the presence of the confining layer that separates the two aquifers.

The confined aquifer contains ‘ancient water’, more than 25,000 years old and is not replenished by local rainfall or surface water.

For management purposes the confined aquifer is treated regionally as one aquifer but it is actually a multi-aquifer underground system.3

The NRM Board has more information:

In recognition that much of the water in the confined aquifer is over 25,000 years old and has minimal modern day recharge, new water allocations from the confined aquifer will be limited to the following uses:

 public water supply  bridging volumes

 co-produced water from petroleum and CO2 production (temporary allocation)  mining (temporary allocation)

A risk assessment to determine the level of risk to the confined aquifer groundwater and its users from current levels of demand and allocation,(my emphasis) indicated that no management areas were at a high or very high level of risk.

Some policies in the Water Allocation Plan (WAP) require new allocations or transfers to be the subject of a hydrogeological assessment. For the confined aquifer the assessment will seek to confirm that the allocation of water shall not cause or have the potential to cause an increase in groundwater salinity or have a detrimental impact on the structural integrity of the aquifer as well as not resulting in excessive seasonal variations or long-term declines in water levels.2

2.1.2 The Unconfined Aquifer The unconfined aquifer underlies much of the South East of SA. More than 90% of the water e xt racte d from this aquifer is used for irrigation.

As for the confined aquifer, the unconfined aquifer is treated as one aquifer for 2 management purposes but there are actually multiple sub-aquifers.

It is important for the maintenance of water-dependent ecosystems, including important coastal springs; drinking water supplies for Mount Gambier, Millicent and 2 Penola and other private domestic water supplies; recreation and tourism.

Salinity of the unconfined aquifer is one of the major factors that limits water use in the South East…..The unconfined aquifer has been subjected to pollution, both point source and diffuse source and shows increasing nitrate levels.4

The combined thickness of the aquitard between the confined and unconfined aquifers is about 20 metres…..Some flow between the confined and unconfined aquifers has been identified where fractures, faults and sinkholes occur however this is considered to be minimal.5 (my emphasis)

3 2.2 Surface Water

2.2.1 Natural Creeks Natural creeks are not widespread in the Lower South East due to the topography of parallel sand dune systems and the sandy soil. 8 Mile Creek is the only one of significance in the lower South East with Salt and Maria Creeks further north.

While these creeks have all been highly modified from their original condition, they are, given the rarity of these types of habitats in the region, still significant, supporting 5 values that are not otherwise well-represented in the region.

The Regional NRM Plan states that action is needed to conserve and manage refuge pools along the creeks to conserve threatened species populations.

2.2.2 Coastal Dune Lakes These lakes are a major feature of the South East. Some are saline and some fresh. They receive water from underground water discharge, rain water and surface water drainage systems.

Banded Stilts on Lake George, Beachport, Lower SE, SA These lakes, like Lake George, near Beachport, are very important for shorebirds, migratory and non- migratory, and other waterbirds such as swans and ducks that can be seen in thousands around the fresh water springs rising into Lake George.

The South East is also an internationally significant site for migratory waterbirds including a large number that are listed under the following international agreements: Japan-Australia Migratory Bird Agreement (JAMBA), China-Australia Migratory Bird Agreement (CAMBA) and the Republic of Korea-Australia Migratory Bird Agreement 5 (ROKAMBA).

Migratory water birds….make round trip migrations of up to 26,000 km. each year between their breeding grounds in the Northern Hemisphere and their non-breeding areas in the south. The wetlands of the South East and the marine environment are 5 significant staging points for large numbers of these birds.

4

Shorebirds on Lake Eliza

Coastal wetlands and lakes are important for shoreline stability, storm protection, ecological productivity and sediment and nutrient retention/discharge. They provide nursery, breeding and feeding areas for many species of fish, crustaceans and waterbirds.5

2.2.3 Swamps and Marshes The majority of the wetlands of the South East are either swamps or marshes and many are of an ephemeral nature.

They occur across the region from the samphire scrublands of the upper South East coastline to the freshwater meadows that occur inland to the Victorian border down to the peat fens associated with rising springs in the far South East of the region…..Wetlands in the region are primarily under threat from competing high demand for underground water and surface water resources.5 (my emphasis)

5 Swamps and marshes have a complex interaction with the regional hydrology and incorporate processes that combine to produce a mosaic of underground water- dependent ecosystems.6

2.2.4 Karst Rising Springs and Peat Fens Karst rising springs and peat fens are distinctive and fascinating elements of Lower South East hydrology.

Prior to European settlement 30,526 hectares of rising springs associated with wetland 5 habitat existed in the South East. Only 1040 hectares (3.4%) remain today.

Piccaninnie Ponds are one of Australia’s best examples of rising limestone springs and are surface expressions of a much larger cave system of great beauty and interest, which has made the site one of Australia’s premier cave diving destinations, Paul Caica said, when Minister for Sustainability Environment and Conservation.

Karst Landscapes are characterised by features created through solution, the most obvious being caves and sinkholes. The South East has over 600 numbered cave 5 entrances that lead to subterranean features.

The original wetland covered 1,100 hectares, most of which was drained post the Second World War. It supported large areas of open water, reed beds, coastal peat fens, a mobile coastal dune system, grassy open woodlands and dense thickets of Tree Everlasting (Ozothamnus ferrugineous), Tall Saw Sedge (Gahnia clarkei) and Silky Teatree (Leptospermum lanigerum)… However, despite the loss of habitat this wetland system remains one of the most extensive examples of Karst Wetlands in Australia.6 (my emphasis)

It is situated in one of the 15 national biodiversity ‘hotspots’ listed by the Australian 5 Government in October 2003.

A number of nationally-threatened orchid species are exclusively associated with terrestrial rising springs habitats… Rising spring habitat is also important for a number of reptile species considered threatened in South Australia… Dense scrublands associated with rising springs are the preferred habitat of the State endangered 5 Swamp Antichinus (Antichinus minimus maritimus).

Peat fens occur where there is continuous upwelling of groundwater which is their primary water source. They are associated with rising springs in the far south east of the region and are very susceptible to changes in the regional underground water levels. They are one of the most vulnerable wetland types, being highly susceptible to degradation.7

2.3 Extraordinary Wetland Features

2.3.1 The Blue Lake Mount Gambier’s Blue Lake is world renowned for its magnificent blue colouring in summer. It is less well-known for the fact that it has the largest stromatolite communities recorded in Australia … These structures form around the edge of the lake and extend from just below the surface to over 45 metres deep and are the deepest stromatolites ever recorded.5

2.3.2 Caveton Park Estate

6 The Caveton Park Estate cave supports aquatic bacterial colonies which form in sheets. 1 The biology of these colonies is yet to be studied, but they are likely to be endemic.

2.3.3 Lake Hawdon Lake Hawdon South supports the internationally rare and fascinating thrombolites which are calcareous mounds produced over hundreds of years by bacteria and algae. They have been treated with little or no respect since white settlement. The lake is also important for shorebirds, both migrating and non-migrating.

Thrombolites on Lake Hawdon

2.4 Drains Drains, though not natural features, must be considered since they have almost completely changed the landscape and ecology of the South East. Their purpose is to remove surface and ground water to enable farming and grazing to be carried out.

Prior to installation of the drainage network an estimated 45% of the South East 5 landscape was subjected to inundation either permanently or seasonally.

In many areas where wetlands and other naturally occurring water features have diminished, drains are often the only permanent water systems providing water 1 habitat for aquatic flora and fauna species, such as native fish and invertebrates.

Until recently there was doubt whether the Australian Mudfish still existed in the State until two were found in Sutherland Drain, (near Beachport) giving ecologists a rare second chance of 1 understanding its requirements and achieving its conservation in South Australia.

Many nationally threatened species are represented only in the South East Natural Resources Management region and survive in isolated pockets of suitable habitat. The South East Drainage Network has an important role in providing water to key environmental assets.

3 THREATS TO AQUIFERS AND WETLANDS IN THE SOUTH EAST OF SOUTH AUSTRALIA

Groundwater is finite and therefore precious.

3.1 Past and Present Threats 7

3.1.1 Drainage Due to drainage for land use the wetlands of the South East were reduced to <6% of their size before white settlement.

3.1.2 Increasing demand for water.

THE CONFINED AQUIFER

Water pressure levels are declining.

Additional monitoring wells are required for the TCSA, however the cost of drilling 1 and completing wells in deep confined aquifers are prohibitive.

THE UNCONFINED AQUIFER

One of the present threats is the increasing demand for water for agriculture, vineyards, pasture and crops, forestry, domestic supplies and industry.

Over extraction may take many years to reverse. Lowering of water tables may negatively affect groundwater- dependent ecosystems and reduce streamflow.

The dominant source of water for Ewens Ponds and 8 Mile Creek is the Unconfined Tertiary Aquifer….This is of particular concern given the rapid proliferation in intense irrigation pumping of groundwater in the immediate vicinity of Variegated Pygmy 5 Perch habitat since the 1990s.

The only two populations of River Blackfish left in the Lower South East are in Ewens 1 Ponds and Mosquito Creek.

All habitats where River Blackfish are found in South Australia have some form of linkage to groundwater to secure water supply…River Blackfish appear more susceptible to poor water quality in comparison to other native obligate freshwater 1 fished of the region.

The majority (70%) of wetlands in the South East have been identified as having a high likelihood of interaction with the unconfined aquifer…Despite the enormity of the underground water resource, the greatest threat facing the unconfined aquifer is its use in excess of sustainable limits.1

CREEKS, SWAMPS AND MARSHES

From a State context around a quarter of the [native fish] species recorded within South Australia’s political boundaries are represented in the South East, around 5 of which are exclusive to the region.8

Over extraction of water leaves little for the environment. Too little water for creeks means loss of refuge pools for fish in dry seasons which could lead to the local extinction of some already threatened species.

The main physical reliance for [the endangered Yarra Pygmy Perch] …is high volumes of clear fresh-flowing water and dense bankside vegetation. The primary threat to the 5 species is reduced flow due to declining spring recharge.

The Dwarf Galaxia’s preference for shallow wetlands leaves it vulnerable to minor changes to water regime where a reduction in groundwater level by as little as 300 8 mm. could be the difference between a wetland undergoing sufficient inundation for successful recruitment or population failure.9

A rare species of damselfly, the Ancient Greenling (Hemiphlebia mirabilis) is globally significant as the only living representative of a family (Hemiphliidae) that can be traced back 250 million years. It only occurs in a limited number of sites in South East 8 Australia and needs wetlands for its survival.

3.1.3 Pollution

THE CONFINED AQUIFER

There are no records to suggest the water quality of this resource has changed dramatically over the last 100 years.

THE UNCONFINED AQUIFER

Most underground water contamination reported in the South East to date has been localised (or “point source”) beneath, for example, railway, abattoir and industrial sites. Contaminants include arsenic, heavy metals and hydrocarbons. Widespread (“diffuse”) contamination of underground water by nutrients or pesticides is a real threat that warrants further investigation, particularly for contaminants that present a known health risk to human and ecological receptors. Future management in the region will require a detailed risk assessment of the contamination threat beneath different land uses.5(My emphasis)

Hypogean [subterranean] life exists in a continuum through different types of karstic, cave and fissured aquifers. Gilbert (“Groundwater Ecology”, 1996) asserted that life there is as diversified as in the surface biotic milieu and that aquifers form the most extensive array of freshwater ecosystems on our planet. That these ecosystems exist in the groundwater makes the nature of their dependence absolute, albeit poorly understood and appreciated…..Aquifer ecosystems….may, as a class, be the most susceptible to groundwater pollution.4

CREEKS, SWAMPS AND MARSHES

Pollution and increasing salinity from agricultural and industrial sources are damaging already severely reduced swamps, marshes and lakes in the region.

The availability of freshwater habitat in the region, in what is otherwise a very dry state, accounts for the fact that a recent inventory found the South East to be a “biodiversity hotspot” for freshwater fishes with around a third of the State’s species 5 found in the region.

De-watering, pollution and salinity are threats to their survival.

Water quality is considered a critical component of the ecological character of the 6 wetland system.

Prolonged exposure to salinity….without seasonal freshening is likely to be detrimental 1 to the endangered Yarra Pygmy Perch.

LAKES

9 Lake Bonney S.E. SA is a tragic example of what can happen to a vital, living lake with government short- sightedness and disregard for the natural environment. Lake Bonney, 23 km. long, was, in living memory of the white population, a beautiful place for boating and picnics with its clear water and white sandy beaches. The fishing was good too.

It seems that many of these uses stopped once the lake was lowered in 1958 to appease the flooding concerns of local land owners.10

Lake Bonney has been damaged by the discharge of large amounts of nutrients and contaminants from pulp and paper mills for over 70 years and smaller volumes have also entered the lake from the Millicent wastewater treatment plant for over 45 10 years.

It was the largest freshwater lake in Australia for most of its past.

According to the EPA, major improvements to plants and animals in the lake have been gained with their work, from 2005 to the present.

Imagine the importance of this lake and other wetlands to the local Buandik people whose name means “People of the Reeds”.

3.2 New Threats to the Unconfined Aquifer and Wetlands

3.2.1 Introduction

Many nationally threatened species are represented only in the South East NRM region 5 (South Australia) and survive in isolated pockets of suitable habitats.

The South East is a biodiversity hotspot for freshwater fishes with 14 native species recorded (around one third of the State’s species) and six species of State conservation 5 significance.

While findings flag significant range reductions for many species in line with massive loss of wetland habitats (70%) importantly there is still something left to save with respect to a diverse range of fishes including threatened taxa and rare habitat types (e.g. clear flowing springs with lush vegetation, wet teatree heath, stream habitats, natural permanent swamps).11

The future of humanity depends on wetlands… Wetlands act as a natural sponge against flooding and drought and protect our coastlines. They burst with biodiversity and are a vital means of carbon storage.12

Groundwater is a precious, finite and irreplaceable resource. About one third of the globe’s freshwater lies underground. There it may travel for as long as thousands of years before flowing into rivers, lakes, streams and oceans. Due to chronic over- pumping, chemical contamination and climate change, groundwater has become one of the world’s most threatened resources.5

3.2.2 Fracking

10 PETROLEUM TENEMENTS IN THE SE OF SA

The whole of the South East, except for Mount Gambier and parts of some national parks is under licence for shale gas extraction which requires the controversial high pressure, high volume, slick water fracturing, or in other words, fracking or unconventional gas, UCG. The primary component of fracking is clean or brackish fresh water, in our case from the relatively pure confined aquifer.

Once an aquifer is contaminated it may be unusable for weeks, decades, centuries, or 10,000 years, depending on the contaminant.13

As you have read, underground water is essential here for humans and the environment. Fracking, judging by USA, Queensland and N.S.W. experience, may well be the last straw for our fragile environment and threatened species.

From U.S. experience and experience to date in unconventional gas developments in Australia, there is good evidence (e.g. N.Y. State Department of Environment and Conservation, 2011) that… some degree of environmental contamination will be an unavoidable result of shale gas expansion…..Most of the impacts on biodiversity cannot readily be mitigated and will result in unavoidable loss.14

11 We conclude that species and habitats most at risk are ones where there is an extensive overlap between a species range or habitat type and one of the shale plays (leading to high vulnerability) coupled with intrinsic characteristics such as limited range, small population size, specialized habitat requirements and 14 high sensitivity to disturbance.

This is precisely the situation we have here in the Lower South East.

Contamination from spills and leaks, illegal dumping and loss of well integrity

Thousands of leaks and spills have been reported from fracking sites - the industry itself admits to 1,000 incidents in one year in North Dakota alone. However the government and industry continue to write them off as unfortunate one-offs rather than inherent problems.15

As DMITRE said in March last year: Well failure in the past has been due to preventable mishaps.

Statements attesting to the safety of shale gas development made by industry and regulatory agencies lack credibility in the face of a growing litany of accidents and contamination problems.16

Gloucester, NSW: Hazardous BTEX chemicals (benzene, toluene, ethylbenzene and xylenes) were found in the water of two of AGL's wells. AGL discovered the chemicals on January 15, but didn't report the breach until almost two weeks later.17

In Wyoming, According to the US Centre for Biological Diversity: in 2013 the US Government abandoned its research into local pollution from fracking. Their results were showing fracking- related chemicals in nearby groundwater.

A study of shale gas wells in Pennsylvania showed that 6-7% of newly constructed shale gas wells in that state were leaking within a year of being built.18

Total truck movements during the construction and development phase of a well are estimated at between 7,000 and 11,000 for a single 10 well pad. During the most intensive phase of development, it is estimated that there could be around 250 truck trips/day onto an individual site…..The risk of spillage is considered to be moderate for an individual installation and high for multiple installations.19

The Land, March 8th 2014: Water leaked from a storage pond at Santos’s Narrabri project has contaminated groundwater with heavy metals and other elements, elevating uranium levels to 20 times the safe drinking limits, according to the State’s environmental watchdog. Other elements detected in the groundwater include lead, aluminium, arsenic, barium, boron and nickel. The mining company says these are naturally occurring elements. Santos responded to the news of the leaks, saying impacts of the contamination are localised and do not impact regional groundwater used by the community.

But what about the environment?

Santos was fined $1,500.

12 Following these fines the N.S.W. Government moved to fast track the Narrabri project.

Poor construction of pond lining is blamed for the leaks. Impacts on groundwater is likely to be a particular issue in many areas.Despite documented cases of groundwater contamination throughout the Western Canadian Basin, no energy regulator has yet constructed a groundwater monitoring system to watch how oil and gas activity is changing the quality of groundwater over time.

Governments dependent on hydrocarbon revenue have chosen to neglect ground water For decades.18

Pilliga CSG wastewater spill, NSW, 2011.In 2011, a 10,000 litre spill of toxic coal seam gas water occurred killing native vegetation and soil. The water contained dangerous levels of lead, mercury, sodium and other heavy metals. In 2015 this spill site can still be seen as unsuccessful rehabilitation, probably impossible. Jackson oil spill, Queensland, 2013. In May 2013, an uncontrolled oil spill was reported in Santos' Zeus field near Jackson in Queensland's remote south-west. The flow lasted 'almost a week' before international experts were able to contain it. The rate of flow was estimated at 50,000 litres per day. Uranium contamination of Narrabri aquifer, NSW, 2013. In 2013 it was discovered that underground aquifers in the Pilliga Forest has been contaminated with toxic levels of heavy metals and uranium 20 times above the safe drinking levels. This occurred from leaking coal seam gas evaporative ponds at the Bibblewindi water storage site. All attempts to remove the pollution have failed. Origin Energy executives raised concerns about oil leaking into underground aquifers from its wells in Queensland more than a year and a half ago, documents obtained by The Australian show. The revelation appears to contradict repeated statements by Origin to The Australian that it did not know of any oil leaks into aquifers in Queensland’s Surat Basin. The documents show the problem was raised at a meeting, attended by more than 20 executives, including general manager of production John Rodda, to discuss abandoning Origin facilities in Queensland, Western Australia and Victoria. The meeting heard that Origin’s large number of unused wells were an “increasing risk” and expensive to maintain. “Business is being consumed by increasing risk & incidents, large burden on limited resources,” the minutes record. Doubts were raised as to whether Origin had set aside enough money to cover the shutdown cost, with executives told that “financial abandonment provisions appear to be inadequate”. Attendees were told that 24 of 76 wells surveyed “have a form of leak at wellhead (valves or seals)”. This does not necessarily mean any oil or gas escaped, as all but one well had at least one valve still working. The meeting was told Origin did not know exactly how many wells in Surat had been plugged and abandoned, or “P&A’d”. “The number of Surat P&A’d wells is thought to be in the region of 200 wells, but not confirmed,” executives were told. Dealing with those wells had “been firmly out-of-scope” of the decommissioning project, “but recently the potential requirement for ongoing inspection and monitoring has been raised”. Attendees were also shown photos of rusty wellheads, including one apparently tied up with string.

13 Oil leaking into an aquifer was among allegations made against Origin by former compliance manager Sally McDow in a wrongful dismissal lawsuit she has filed against the company. Asked about the allegation on December 30, an Origin spokeswoman told The Australian: “There has been no known oil leak to an aquifer in the Surat fields.” An Origin spokesman repeated that statement in response to further inquiries last week. “Origin has robust compliance processes and rejects any inference to the contrary,” the spokesman said. “We engage openly and regularly with regulators via dedicated teams and we are confident that there has been no breach of an external compliance reporting obligation.” Ms McDow alleges Origin has a culture of covering up health, safety and environment breaches. In its defence, filed with the Federal Court this week, Origin denied Ms Mc Dow’s claims of bullying and a cover-up of compliance failures. The company denied Ms Mc Dow’s redundancy in October was a sham and said it was the result of a company-wide restructure that cost 800 jobs, including seven in the compliance team. It admitted that an internal compliance audit produced in December 2013 and relied on by Ms Mc Dow to support her allegations “identified shortfalls against the Origin internal standards and identified action items for achieving those standards over time”. No trial date has been set. http://www.theaustralian.com.au/business/mining-energy/origin-executives-knew-of-oils- leaks-into-acquifers/news-story/6f5aa2b1a6c150107671ba755ccda9ca

The environmental problems of holding ponds (sumps)

Sumps and well sites at Penola, SA, (Jolly 1 and Bungaloo 1), according to Beach Energy, are appropriately fenced to minimise fauna access. A Beach Energy representative has admitted that the fences will keep out large animals only, e.g. sheep and cattle, but will not keep out wildlife, for example birds, frogs, bees, tortoises, snakes, lizards or any native animals that walk on short legs or can jump. This has presumably been approved by the EPA.

The task of the EPA is to prevent, reduce, minimise and where practicable, eliminate harm to the environment.

14 A rotting dingo found in a poisonous plastic-lined pond operated by a West Australian gas explorer has prompted concern from the Greens. Buru Energy's Yulleroo operation in the Kimberley has seen the creation of numerous plastic-lined ponds which trap water. But Greens Member for the Mining and Pastoral Region Robin Chapple said when the ponds are dry they become death traps for animals. "It's not just dingoes but also reptiles, birds and various small marsupials that have been found trapped in these ponds," he said. "These tailings dams contain a toxic mixture of chemicals from the fracking process and also often include heavy metal traces and hydrocarbons drawn up from deep underground as a part of fluid recovery. They are clearly not addressing the reality that native animals will see these ponds and assume they are a safe water source."

Scientists from the U.S. Geological Survey recently published a peer-reviewed journal article that discusses the results into the investigation into a 2007 fracking wastewater spill in Kentucky. Fracking wastewater that was being stored in open air pits….overflowed into Kentucky’s Acorn Fork Creek and left an orange-red substance, contaminating the creek with hydrochloric acid, dissolved minerals and metals and other contaminants. Prior to this pollution, the creek was so clean that it was designated an Outstanding State Resource Water. State and federal scientists found that the toxic fracking waste ‘killed virtually all aquatic wildlife in a significant portion of the fork.’ The dead and distressed fish had developed gill lesions and suffered liver and spleen damage. The lead USG scientist in the investigation stated: ‘Our study is a precautionary tale of how entire populations could be put at risk even with small- scalefluid spills.’ One of the things that bothers me most about this case is that the scientists had been alerted to the fish kill ‘by a local resident.’

The fine was $50,000.

What to do with the waste (produced) water?

The problem of what to do with the produced water after our clean water has been converted to toxic waste is far from being solved. Local wastewater treatment plants are not equipped to handle it.

Various means of getting rid of it have been tried. (Out of sight. Out of mind)

Pumping it under pressure into empty wells has been tried in the USA, causing many small earthquakes.

Spraying it onto roads in Queensland “to keep down dust”. Where does it go from there? Into the groundwater.

Treating it in inadequate water treatment plants and spraying it onto farmland. A frightening thought, especially as that is what Beach Energy did with waste water from their Jolly 1 and Bungaloo exploratory wells near Penola in the South East of South Australia.

Permits can be granted to release wastewater in Australia. In N.S.W. a permit was granted for the release of water into the Condamine River…that contained 22 chemicals that exceeded the limits of environmental guidelines – boron, chlorine, cadmium, cyanide and zinc.20

Illegal dumping has been resorted to.

15 Brisbane Times, Jan. 9,, 2015

AGL has been mired in fresh controversy over its coal seam gas activities near Gloucester (Qld.) after a contractor shipped untreated wastewater to the Hunter region despite explicit rejection of the plan from the local water authority. AGL said Transpacific Industries transported 600,000 litres of so called flowback water from its four pilot coal seam gas wells to a facility at Kooragang Is. near Newcastle. The flowback water…. was then treated before being discharged into the Hunter Water’s sewage network….Hunter Water was alerted to the discharge by reports in the ‘Newcastle Herald’

Tolcide is probably the most toxic fracking chemical used by AGL and may be present in water samples, including river water. Tolcide is listed as hazardous and is harmful to aquatic life so its potential presence in groundwater is serious. However AGL didn’t even have an approved testing method to monitor for Tolcide until 19th Dec. after all four wells were fracked…..AGL’s licence requires a zero detection of Tolcide and also Monoethanolamine. AGL’s report admits this zero limit was breached on 20th Nov., yet the only action taken was to continue with the fracking and not tell the EPA until 15th Jan. The problem of what to do with the wastewater is admittedly greater for coal seam gas extraction than for shale gas extraction as less is needed, but the amount is still significant and the quality of the wastewater is lower and therefore of greater risk to the groundwater and the environment.

A single frack requires approx. 500,000 litres or water (around 15 truckloads) and there can be 10 to 20 fracks per well. 3,446 wells are planned for the Otway Basin so far. That is a lot of water from the confined aquifer.

Howarth and Ingraffea (2011 NPR) cite examples of water contamination of tributaries of the Ohio River with barium, strontium and bromides from municipal wastewater treatment plants receiving wastewater from hydraulic fracturing processes.

What to do with abandoned wells?

The 30-70% of water remaining in a well after fracking means millions of litres of fresh water are converted to toxic water and are lost to humans and ecosystems for the foreseeable future.21

The EPA (U.S.A.) reported in 1992 that an estimated 1.2 million oil and gas wells were abandoned in the U.S.A. of which 200,000 were leaking.

Decommissioned wells need to be effectively sealed for hundreds, if not thousands of years.

The isolation of the well contents from the surroundings depends on the cement lining of the well. There is considerable doubt that current cement technology can provide 14 long term isolation.

New findings from West Virginia show how unmapped, long-abandoned wells – including those from generations ago – can become re-pressured during nearby fracking operations and serve as conduits for the contamination of drinking water.22

14 Well abandonment is an issue that requires more research and development.

16 What to do with abandoned wells? We do not have an answer yet.

The amount of land needed for shale gas

A different perspective on fracking: wells in the Jonah Field, Wyoming

Because of the nature of shale gas extraction, more land is required than for coal seam gas. Fracking of shale gas produces a sudden rush of fuel that decreases rapidly. After taking this first boost the companies move on. The environmental impact is increased as more and more land is fragmented.

As a range of different wetlands occurs over the Lower South East more and more of them will be likely to be impacted upon by wells, pipelines and roads.

Lack of knowledge and resources for environmental research

In most Australian sedimentary basins, knowledge about the relationship between deep aquifers, faults, fractures and over- and underlying-gas shales (or coal) is poorly understood. In addition, the internal characteristics of deep aquifers such as permeability, porosity, water quality and groundwater flow direction are generally not 5 known.

The role which groundwater plays in controlling ecosystems in Australia is very poorly understood….As an unseen and poorly understood resource, groundwater nevertheless fundamentally controls the health of major ecosystems across 9 Australia.

Virtually nothing is known about Australia’s aquifer systems, their importance in 4 terms of biodiversity and their importance to the systems into which they discharge.

Current regulatory systems are inadequate for managing and mitigating the risks of UCG mining and/or to prevent the practice where risks are too high…The established pattern globally is that the UCG mining industry has been successful in ‘capturing’ governments and regulators to the detriment of the environment and public interests.23

17 The makeup of fracking fluid is constantly changing due to regulatory changes and in 5 response to innovation seeking better gas recovery.

12 environmental risks posed by fracking, ranked by research priority (risk) from high (3) to low (1). Souther et al/Frontiers of Ecology

3.3 New Threats to the Confined Aquifer

3.3.1 Breach of the Aquitard

The combined thickness of the aquitard between the confined and unconfined aquifers is about 20 metres…..Some flow between the confined and unconfined aquifers has been identified where fractures, faults and sinkholes occur however this is considered 5 to be minimal.

As there is more and more shale gas drilling through both aquifers and across fault lines there is a serious concern that the means of linkage will be increased leading to pollution of the confined aquifer.

4 TAKING INTO ACCOUNT CLIMATE CHANGE

Already the driest state, climate change presents South Australia with a tough 8 challenge, especially in securing a reliable water supply.

18 We can say with considerable certainty that rainfall patterns will change as a result of climate change and often in unpredictable ways, creating large risks for water availability.24

Water from the aquifers is now, and will be in the future, essential for human survival and the survival of the natural environment. We cannot afford to waste it.

The International Energy Agency has indicated that two thirds of all proven fossil fuels must stay in the ground if the world is serious about avoiding dangerous climate change.

To minimise the risk we must de-carbonise our economy and move to clean energy sources by 2050.24

5. PEOPLE AND THE NATURAL ENVIRONMENT – CHANGING ATTITUDES

Social norms have led to us taking natural resources for granted, particularly as it is 5 hard to quantify the benefit they provide in non-economic terms.

There is an ever increasing concern shown by the community for protecting regional 5 diversity.

In our region this can, in part, be attributed to the wonderful work done by DEWNR, the South East NRM board and the NGO group Nature Glenelg Trust in involving local people in regeneration programmes in the South East and providing opportunities to learn about the native flora and fauna from expert speakers. At community education nights there is often standing room only. Children are especially welcome at the information nights and field trips and come along in large and interested numbers.

Children on a Wetlands Information Day at Bools Lagoon

The South East Natural Resources Management board states as its vision,

19 Healthy landscapes for better living. They say, collectively we must place a higher value on the soils, water, biodiversity, coast and marine assets of our region and recognise the social, environmental and economic contribution that they make.

But people are also increasingly understanding that the natural environment has a right to exist for its own sake and not only as something that exists for humans. A new “right to life” understanding is developing, but not, unfortunately, in the petroleum companies and in the associated government departments.

People are understanding that the time to take, take, take is giving way to a time to give back, ultimately for our own survival.

Good work is also being done in the South East of SA in involving schools in saving native fish from extinction due largely to habitat degradation and lowering of groundwater levels from water extraction.

Millicent Students growing wetland plants at the school, for wetland regeneration

Not only is returning water to drained swamps good for the environment (in bringing 8 back fish, frogs and waterbirds) but they also make great places for people to enjoy.

Aquasave has been providing support for Yarra Pygmy Perch captive breeding facilities at Kingston Community School and Millicent High School since 2008 and 2010 respectively and have been achieving great results.As the South East of South Australia moved into a severe drought, populations of the nationally vulnerable Yarra Pygmy Perch were at serious risk of extirpation.

The schools are active contributors to threatened species conservation in the South East. In 2014 Millicent High School, S.A.’s DEWNR and Nature Glenelg Trust released captive Yarra Pygmy Perch back into the wild, the culmination of five years of hard work, maintaining fish in captive facilities at both Millicent High School and Kingston Community School along with the establishment of a refuge site in a dam near Millicent, SA.

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Millicent Students, with DEWNR Assistance, releasing Yarra Pygmy Perch into a Holding Dam

Saving the environment has become a practical part of these children’s education. They are involved in useful and essential work, but more than that, they get to work with young, enthusiastic environmentalists who are wonderful role models for these children, mostly boys, who see that it is possible and acceptable to have a career in ecology or simply to care for the environment as a way of life.

Things are looking good down here. Farmers are planting trees and learning about using less environmentally destructive methods of farming. Organic food production is thriving and attracting local buyers and tourists. Industries are learning that they must be environmentally sustainable to be able to survive. The government, NGOs, land owners, schools communities and volunteers are working hard linking wetlands for the benefit of wetland flora and fauna, waterbirds and shorebirds, the community and the tourist industry. All are removing the previous fragmentation that was so detrimental to the survival of species.

Things are moving forward at an amazing rate. Turning the region into a gasfield will destroy it all. There will be many broken-hearted and broken-spirited people just as the Aborigines were when we took their land.

6 INDIGENOUS PEOPLE SPEAK

A BUNGANDITJ DESCENDANT’S FEELINGS

The plight of the Bunganditj, People of the Reeds, fills me with terrible pain.

The ‘White fella white-wash job’ was very successful. Our proud Bunganditj people have suffered the worst possible fate. Rape, murder, lung disease, stolen women, stolen children, slavery and poison. Nowhere to camp and hunted by men with guns and horses. Most blackfellas died soon after white invasion and some of those surviving did not see old age.

Clear waters now gone, muddied by too many sheep and cattle. No game to hunt, no skins to wear. The social fabric was no more, just a torn and tattered dirty rag. Swamps drained, dead dry creeks. Ducks, geese and fish no longer easy to hunt, the black people moved away or died.

21 The coastal strip was irresistible to the new settlers. The Blackfellas had to adapt, move on or be squashed. Lots of sad spirits in the smoke. Today’s roads spread like a slimy octopus over our old trading tracks. Linking secret waterholes and the best campsites. Hunting grounds now fenced with netting and barbed wire, good patches of scrub cut into bits and pieces.

Pine and bluegum forests now stand proud where there were once healthy swamps and shimmering grasslands. The white fella now watches as his brothers continue the decay. Over fishing, pollution, dirty dairies, cow shit in the water.

Old blackfellas give up. Sad sick young women, worried mothers, confused Aunties and bewildered grandmothers. And so the Bunganditj land will suffer.

On a cold wintery night, another fat moon soaks into the river sands of a lonely beach with a lazy Southwesterly wind. Nearby the sighing sheoaks whisper the secrets of the bush.

Ancient stringybarks and giant muddy gums that could not run away…remnants; they stand witness to the terrible atrocities committed around their ankles.

(An abridged version of a contribution to the Buandik exhibition, One Land. Two Cultures., in the Beachport National Trust. Museum.)

When face to face with what we whites have called ‘primitive people’ we have seen ourselves as ‘civilised’. We are increasingly coming to realise that to destroy our environment for short-term gain cannot be called civilised behaviour.

Ecuador, which has powerful indigenous groups, has changed its constitution to give nature ‘the right to exist, persist, maintain and regenerate its vital cycles structure, functions and its processes in evolution.

However, the abstract rights have not lead to new laws or stopped oil companies from destroying some of the most biologically rich areas of the Amazon.

The Andean spiritual world view ….places the environment at the centre of all life.25 In Bolivia, a country which has a strong indigenous Andean population, passed 11 new laws in 2011, granting all nature equal rights with humans. They include:

 the right to life and to exist;  the right to continue vital cycles and processes free from human alteration;  the right to pure water and clean air;  the right to balance; 25  the right not to be polluted.

If we cannot even achieve these goals for ourselves, what hope is there for the environment?

22 7 WHAT I STRONGLY ADVOCATE

My submission concerns the effects of unconventional gas extraction on the natural environment, with reference to the Lower South East of South Australia. What applies to the Lower SE applies equally to South West Victoria. We share the same aquifers and the same limestone geology.

The state of the natural environment cannot be divorced from human welfare, though until recently we have not understood this. Now that we do, there is no excuse for undertaking unnecessary actions that put the environment in danger of further degradation and even ultimate destruction.

I believe unconventional gas extraction is unnecessary and that SA has the potential to be fossil fuel free in a short time. I believe SA’s new logo is blatantly against limiting global warming and therefore against the hopes of its citizens. For that reason I believe fossil fuel extraction should not go ahead.

23 I believe there will be a serious threat to aquifers and groundwater if unconventional gas exploration and extraction are allowed to go ahead in the South East of South Australia and SW Victoria.

Wetlands – swamps, lakes, marshes, rising springs, peat fens, water-filled cave systems, creeks and ephemeral wetlands are all features that make the landscape of the South East distinctive and unique. They are what many tourists come to see and locals enjoy all year round. I believe the landscape of the South East would be completely altered by thousands of gas wells and the associated roads and pipelines crisscrossing the land.

Gas wells require large amounts of water. It is well-known that in the vicinity of gasfields the water table often drops. A lowering of the water table would be disastrous for shallow wetlands and coastal lakes. Habitats and wetlands will be damaged. It is almost impossible to regenerate a heavily polluted site to its former health and beauty. The environmental work that is being done here involves linking wetlands previously separated and almost destroyed by drainage. Linking these wetlands makes it possible to provide habitats for native fish and other wetlands flora and fauna which were in danger of extinction. One of the characteristics of gasfields is that they chop up the land with roads and pipelines. All the good work being done here is in danger of being lost.

Other characteristics of UCG extraction, noise, dust, flaring and bright lights day and night are harmful to humans and wildlife, particularly to nocturnal animals that require darkness for hunting. The behavior of moths and other night-flying insects is also disrupted.

For these reasons I strongly advocate that it does not go ahead.

I believe there will be a serious degeneration of the landscape if the exploration and extraction of UCG is allowed in the South East. What is now beautiful and productive land will become industrialised and changed forever by an industry with a short life and after effects possibly lasting hundreds, if not thousands of years.

For that reason I strongly advocate that it does not go ahead.

I believe to go ahead with so little knowledge is nothing short of criminal and creates a very dangerous situation for the future.

In every country where UCG exploration and/or extraction is taking place (including Australia) regulators have been shown to be ineffectual, or in some cases, dishonest. This is not entirely their fault as they are presented with a task they know almost nothing about. This is a new technology and the knowledge just isn’t there. There is almost nothing known about the long- term effects of UCG extraction on the environment.

24 For that reason I strongly advocate that it does not go ahead.

I believe risking our large and growing income from tourism is not a good idea.

As for net economic outcomes, I believe allowing the natural environment to be replaced with gas fields will destroy our reputation as a delightful tourist resort and an important source of “clean and green” food as our government likes to say. Besides the interesting features of the landscape and the remnant bushlands, what tourists enjoy is the fresh, clean air, the crystal clear seawater and the clean beaches. Who wants to holiday in a gas field? Pollution is not attractive.

For that reason I strongly advocate that UCG operations do not go ahead in the South East of South Australia and SW Victoria.

I believe that the SA Government in the matter of unconventional gas extraction is not honest and open with the South Australian people as evidenced by their publication The Facts about Natural Gas and Fracture stimulation in South Australia put out by the Department of State Development. This brochure seems to me to be deliberately designed to obscure the facts and give readers a false sense of security.

Compare the UNEP Global Environmental Alert Service (GEAS) with the SA Government’s brochure where chemicals used in fracking are stated to be, “Commonly found in household cleaning products, hair products and food additives” and that’s that. UNEP Fracturing fluid consists of large amounts of water mixed with chemicals and sand. In most countries the chemicals used in fracking fluid are considered trade secrets (Zoback et al., 2010). If companies are not required to publicly disclose the full list of chemicals used, assessing potential short- and long-term impacts on public health will be difficult. Colborn and others (2011) compiled a list of products (about 1000) used in fracking fluid. They carried out literature review on 353 chemicals and found that “more than 75% of the chemicals could affect the skin, eyes, and other sensory organs, and the respiratory and gastrointestinal systems. Approximately 40–50% could affect the brain/nervous system, immune and cardiovascular systems, and the kidneys; 37% could affect the endocrine system; and 25% could cause cancer and mutations.” (Colborn et al., 2011). Nonylphenol, for example, which is commonly used in fracking fluid, mimics estrogen, and can cause the feminization of fish, even at concentrations not detected by normal monitoring of the fluid (NYS-WRI, 2011). The consequence of the feminization of fish is an imbalance between male and female populations, resulting in a deficit of fertilization and potentially leading to a rapid decline of these fish populations. There have been hundreds more such reports.

25 The SA Government brochure says “Fracture stimulation has been used safely in South Australia since 1969, in both conventional and unconventional wells.” This is not a lie and yet it is blatantly dishonest. Multi stage slick water, horizontal, invasive, high volume, high pressure, fracture stimulation has only been used since 2002, and not 60 years. Multi well pads have only been in use since 2007. UCG extraction these days bears little resemblance to the process used in the 60s.

Property owners do not have the right to refuse entry to petroleum companies. Therefore the SA Government’s statement in its brochure that in 14 years and 14,000 notices of entry issued for operations there have been no legal objections from people or enterprises is meaningless. Who can afford to take on a petroleum company!

The Hon Tom Koutsantonis MP, Minister for Mineral Resources and Energy says, in the same brochure, “Decades of experience in South Australia have shown fracture stimulation can be carried out in our oil and gas fields safely and without harm to social, natural or economic environments.” These decades of experience have been in the Cooper and Eromanga Basins in far north SA. The South East of SA and SW Victoria bear little resemblance to the Cooper and Eramonga Basins. It seems, for the SA Govt. we are to be an experiment in fracking in farming lands, wetlands and rural communities.

Property owners do not have the right to refuse entry to petroleum companies. Therefore the SA Government’s statement in its brochure that in 14 years and 14,000 notices of entry issued for operations there have been no legal objections from people or enterprises” is meaningless.

On a recent trip to Adelaide I was amazed to read on the sides of buses, “Natural Gas Clean and Green” trumpeting our ignorance to the world. How embarrassing. The 100-year horizon is commonly used for impacts on climate change; however, given the need to reduce GHG emissions in the coming decades, it is also critical to assess the 20-year horizon (Howarth et al., 2011 b). Methane (CH4) is a more potent GHG than CO2 - albeit over a shorter lifetime. When methane is released in the atmosphere (venting), its Global Warming Potential (GWP) is up to 72 times higher than CO2 over a 20 year period, but then gradually decreases so that over a 100 year horizon its GWP is 25 times higher than CO2 (IPCC, 2007). Recent studies found that emissions from UG could initially lead to an increase in climate warming in a 20-year horizon and would only be comparable to coal over a 100- year time horizon (Wigley, 2011; Hultman et al., 2011; Burnham et al., 2011; Hayhoe et al., 2002).

I believe that since Governments cannot be open and honest about UCG then, it seems to me, the truth is obviously too damaging to both government and 26 petroleum companies and must be hidden from the public. Therefore UCG extraction should not proceed.

I believe that the needs of the environment and UCG are not compatible and for the sake of our future we must support the environment. For that reason I believe unconventional gas extraction should not go ahead.

Marcia Lorenz,

27 8 REFERENCES

1 Slater, S and Hammer, M, Drought Response Plan for Nationally Listed Freshwater Fishes of South East South Australia: Regional Action, Contingency and Long Term Recovery, Aug. 2009 2 PIRSA: Water Resources of the Limestone Coast 3 Natural Resources South East Water Allocation Plan: Managing the Confined Aquifer 4 DEWNR: Prescribed Wells Areas of the South East Confined Aquifer. Groundwater Level and Salinity Status Report, 2011 5 SE NRM Board: Regional NRM Plan Feb 2010 6 Department for Environment and Heritage: Ramsar Management Plan. Piccaninnie Ponds Karst Wetlands 2011 7 RDA Board: Limestone Coast Regional Roadmap 8 Nature Glenelg Trust 9 Tom Hatton, CSIRO Land and Water, Richard Evans, Sinclair Knight Merz CSIRO: Dependence of Ecosystems on Ground Water and its significance to Australia Occasional Paper no. 12/98 10 EPA Environmental Information. Legislation and Programs. Lake Bonney SE 11 Michael Hammer: The South East Fish Inventory, Distribution and Conservation of Freshwater Fishes in the South East of South Australia. (2002) 12 Natural Resources South East. Water Allocation plan (WAP) Factsheet 7 Managing the Confined Aquifer Nov. 2013 13 The Conservation Aug. 4th. 2014 14 Academy of Learned Academics. (ACOLA) Engineering Council of Learned Academies: Engineering Energy: Unconventional Gas Production. A Study of Shale Gas in Australia. May, 2014 15 UNEP: Gas fracking: can we safely squeeze the rocks? Nov. 2012 16 The Australia Institute Spheres of Influence. Blind Rush 17 Getup 18 Andrew Nikiforuk: What’s missing from Canada’s Fracking Debate, July 2nd. 2014 19 AEA, Support to the Identification of potential risks to the envir onment and human health arising from hydrocarbons operations involving hydraulic fracturing in Europe 20 The Australia Institute, Paper number 16, March 2014, Matt Grundoff 21 NRM Damien Mavroudis: Downhole Risk Practices associated with drilling and well-completion practices 2001-2009 22 New Internationalist, Dec. 2013 23 Conservation Council of WA 24 Climate Commission. The Critical Decade 25 The Guardian, 11 April 2011

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