BirdLife Australia submission on the Narrabri Gas Project

BirdLife Australia Southern NSW Branch

10 August 2020

Contents BirdLife Australia ...... 1 Introduction ...... 1 Pilliga Forest – a Key Area ...... 1 Effects on Key Habitat of the Project ...... 4 Under-recognised Benefits of the Natural Environment...... 6 Closing remarks ...... 7

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BirdLife Australia BirdLife Australia is an independent science-based conservation organisation with over 100,000 supporters throughout Australia. For more than 100 years BirdLife has been a leading advocate for native and for those who value them.

Introduction This submission is made by the Southern NSW Branch of BirdLife Australia. The likely impacts on threatened species and their habitats are our primary concern.

Our members live in central and southern New South Wales and have many connections to the Narrabri and Liverpool Plains region volunteering their time to assist conservation through citizen science such as wildlife surveying and actions such as treeplanting as well as visiting the region as tourists. Many also have relatives and friends in the area.

We welcome the opportunity to comment on the proposed Narrabri Gas Project. We object to the proposal as it will have a significant and unacceptable impact on matters protected under the Environment Protection and Biodiversity Conservation (EPBC) Act 1999. The DPIE Final Assessment Report seriously underestimates the significant impact on the environment and the conditions set and mitigation measures proposed will be inadequate to offset the irreversible degradation of this very high conservation value area.

Pilliga Forest – a Key Biodiversity Area

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The Pilliga Forest is a globally recognised Key Biodiversity Area (KBA). It is 500,000 hectares of rare intact temperate eucalypt woodland. Value comes partly from the size of the intact remnant despite the variety of land tenures involved both private and a variety of public owners and managers and despite a history of logging.

Key Biodiversity Area is a global concept of the IUCN, the International Union for Conservation of Nature. IUCN has set a global standard to identify ‘sites contributing significantly to the global persistence of biodiversity’. Sites must qualify by meeting one or more of 11 criteria which after independent scientific review and submission of documentation are confirmed as qualifying.

The Pilliga Forest has qualified with the trigger species being the Painted and Diamond Firetail. Over 200 other bird species have been recorded for the Pilliga.

Painted Honeyeater BirdLife Australia

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There are also irregular records of the Critically Endangered and Critically Endangered .

Regent Honeyeater (C) Ross Sergeant 2019 birdlifephotography.org.au

The Pilliga was spared the impact of bushfires in the summer of 2019/20 which have created obvious displacement of species such as the Glossy Black Cockatoo and may now be even more important in south-eastern Australia as a fire and drought refuge.

The IUCN submission for Key Biodiversity Area status stated that “the whole Pilliga is important for woodland birds”, “the woodlands support the largest population of Barking Owl and other declining woodland species in NSW.” Woodland bird populations are continuing to experience rapid decline within south-eastern Australia with more than 40 species threatened with extinction. Birds such as the Brown Treecreeper, Speckled Warbler, Grey-crowned Babbler, Turquoise Parrot as well as those species already mentioned.

This project will destroy the shelter, feeding and breeding habitat of many of Australia and NSW’s most threatened birds tipping them further into risk of extinction.

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Speckled Warbler C Goswell

The Federal Parliamentary Interim Report into Australia’s Faunal Extinction Crisis concluded “the status of biodiversity in Australia is generally considered poor and deteriorating.”

Effects on Key Habitat of the Project

The installation of up to 850 new gas wells on up to 425 new well pads and the construction and operation of gas processing and water treatment facilities will be devastating to the woodland.

Bibblewindi facility E Dark

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The amount of clearing for:

- well sites - gas processing and water treatment facilities - water and gas gathering pipelines - power and communication lines - access roads - wildfire buffer zones will not only result in direct loss of the habitat of woodland trees, shrubs and groundcover but will result in significant fragmentation of the remaining habitat with attendant effects.

Clearing will result in the creation of vast kilometres of edge effect allowing:

- access by pest species such as foxes, cats, goats, pigs, deer - access to weed species brought in by vehicles and construction materials - an increase the wildfire risk with much easier access to remote areas of the forest - an increase in Noisy Miner numbers, a native honeyeater species, which are recognised as a Key Threatening Process under Australian environmental law through aggressively excluding other native species from potential habitat. They are advantaged by fragmentation opening up habitat and creation of edges. The creation of kilometres of access roads will result in the loss of valuable breeding individuals by vehicular collision.

The extent of clearing required will result in the size of remaining intact habitat remnants being reduced to levels too small to support species who find open corridors as a barrier to movement. This will be exacerbated by future climate change with unable to relocate as habitat becomes unsuitable due to the inability to cross open or modified corridors.

There will be disturbance of drainage by well site and road construction which will cause erosion and changing drainage patterns for existing watersheds /ephemeral wetlands.

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Road edge effect and fragmentation E Dark

Another major effect of clearing will be the significant number of hollow- bearing trees that will be removed reducing breeding opportunities for many species. Loss of hollow-bearing trees is also a Key Threatening Process under NSW environmental law. Hollows may take at least 80 years to form. Artificial hollow programs are very expensive to operate and have limited success.

There will be significant noise and light disturbance not only during construction and maintenance phases but ongoing 24 hour operations at sites which will result in species withdrawing from significant areas of the remaining habitat.

Pollution of air, soil and vegetation by the 24 hour burning off of gases will be experienced.

There have already been contamination incidents from spill events which have not been successfully rehabilitated let alone the time required for rehabilitation to develop into usable mature habitat if ever.

The potential reduction of the water table will result in mature woodland dying with changing water availability.

Under-recognised Benefits of the Natural Environment

The significant remnant woodland of the Pilliga Forest and its state and federally listed threatened birds are an under-recognised source of sustainable of tourist income for the region. Intrastate, interstate and

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international birdwatchers currently visit the area to experience the unique birdlife that the rare intact habitat supports.

Will Santos allow future visitors access to these publicly owned habitats and the opportunity to experience this wildlife or will they seal it off?

Closing remarks Please listen to the independent scientists, please listen to the Community.

We ask your Commission to deny approval for the Narrabri Gas Project due to its significant environmental impacts on the Pilliga Forest and the threatened birds listed under state or federal legislation which currently depend on it. The conditions set and mitigation measures proposed will be inadequate to offset the irreversible degradation of this very high conservation value area.

Should you have any queries or wish to discuss this submission please contact Catherine Goswell through the BirdLife Southern NSW office on [email protected]

Catherine Goswell Conservation Sub-Committee BirdLife Australia Southern NSW

10 August 2020

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