Additional Comments from the Australian Greens
1.1
The Australian Greens welcome this report, which clearly sets out many
of the concerns that the Australian community and key scientific research
bodies have with the rapidly evolving coal seam gas industry. We are pleased to
see tri-partisan agreement on a number of issues raised in the report,
including risks to groundwater and farming communities.
1.2 We note that the Inquiry was focussed only on coal
seam gas in the Murray Darling Basin, which did not allow detailed
consideration of the impacts of coal seam gas across the country, or of shale
gas which predominates in Western Australia, or of the land-based and marine
impacts of transportation and export facilities for LNG, or the emissions
intensity of coal seam gas. The Australian Greens will be moving for a fresh,
dedicated Senate Inquiry into these broader issues to ensure that the Senate
concerns itself fulsomely with this issue of such importance to the community.
1.3 The Australian Greens support the recommendations
in the Report, however wish to make some brief additional comments on a number
of issues not fully canvassed by the report and its recommendations.
1.4 We are very pleased there is tri-partisan support
for Recommendation 1 of the Report calling for a thorough review of the
appropriateness of 'adaptive management' in regulating the coal seam gas
industry. As is highlighted throughout the report, there are significant gaps
in information regarding particularly the cumulative and long term impacts of
the industry. The Australian Greens have concerns that the much touted adaptive
management framework to environmental regulation is inappropriate for this
rapidly developing industry, due to the high levels of uncertainty associated
with aspects of its development, and the potential for it to cause irreversible
harm to Australia’s ground water systems. We would like to see this framework
carefully scrutinised with, as noted in paragraph 1.73 of the report,
particular focus on the question of whether 'adaptive management' of the coal
seam gas industry’s development is consistent with the precautionary principle.
1.5 With regard to Recommendation 2 of the report, we
believe the more appropriate body to have responsibility for promoting a strong
and consistent regulatory framework for the coal seam gas industry is the
Ministerial Standing Council on Environment and Water. While regulatory
responsibilities for the industry varies across the states and territories, it
is more appropriate for the Ministers with responsibility for surface and
groundwater to have oversight through this process, rather than energy and
resources ministers who all too often define their role as promoters rather
than regulators of industrial development.
1.6 The Australian Greens strongly support
Recommendations 3 and 4 of the report which say that we must wait for the
results of specific scientific studies before issuing any further coal seam gas
approvals. This approach is consistent with my Senate motion on 13 September
2011 for a moratorium on further coal seam gas approvals until the long-term
impacts of the industry on our groundwater, agriculture, rural communities,
threatened species, the climate and the Great Barrier Reef are known, which
unfortunately was not supported. Clearly significant uncertainties remain about
the long-term consequences of the coal seam gas industry on Australia’s
groundwater resources. Far more research is needed to understand the extent to
the full potential impacts of coal seam gas on our water supplies, particularly
over the longer term. Once that information on the impacts of coal seam gas on
the long term sustainability of our water resources, agricultural land and
natural environment is amassed, there must be a conversation with the community
about whether this short-term fossil fuel industry is an appropriate investment
for Australia given the scarcity of our water resources, good quality food
producing land and the urgency of moving to renewable energy as quickly as
possible to avert dangerous climate change. The Australian Greens believe it is
not, when we have alternatives to energy production but not to food.
1.7 We strongly support Recommendation 7, that the
Commonwealth amend the Environment Protection and Biodiversity Conservation Act
1999 to include the sustainable use of the Great Artesian Basin as a 'matter of
national environmental significance'. While we note the terms of reference of
the inquiry are limited to consideration of the Murray Darling Basin, the
Australian Greens support extending that trigger to all groundwater and surface
water. My bill currently before the Senate, the Environment Protection and
Biodiversity Conservation Amendment (Protecting Australia's Water Resources)
Bill 2011 proposes the introduction of such a trigger to pick up the water
impacts of mining (including coal seam gas). This bill proposes that a new
matter of national environmental significance be mining operations that have,
will have or are likely to have a significant impact on the quality, structural
integrity or hydraulic balance of a water resource. If passed the bill would
mean that federal assessment and approval would be required for mining
operations likely to have a significant impact on Australia’s water resources.
Our conviction as to the need for this bill is all the stronger after hearing
the evidence from communities, scientists, state governments and other
interested parties through this Inquiry. We believe that this Report
strengthens the case for our bill to receive support from all parties and will
be seeking that in earnest.
1.8 We strongly support Recommendation 13, requiring
comprehensive water management plans - and the capacity to implement those
plans - before any further production approval for coal seam gas be granted. We
consider the issues raised in paragraph 3.40 of the Report require special
emphasis here: that given the risk of severe weather events in the coming
decades, there is a clear need for a step change in the management of water
both in normal and severe weather situations. As such, these water management
plans need to ensure adequate protection of groundwater, agricultural land and
downstream users at all times, including in times of severe weather and natural
disasters like the summer flooding on Queensland earlier this year. Further,
plans currently in place should be reviewed by state and federal regulators for
their adequacy to ensure continuous protection of our rivers, creeks and
groundwater throughout all seasons and weather.
1.9 We note and support the numerous recommendations
of the report that seek to enhance the rights of landholders in their
engagement with the coal seam gas industry. This is an issue that the
Australian Greens have already proposed a clear solution for, in the
Landholders’ Right to Refuse (Coal Seam Gas) Bill 2011, introduced in August of
this year. If passed, this Bill will provide Australian landholders the right
to refuse the undertaking of coal seam gas mining activities on their land
without prior written authorisation. The Australian Greens believe that farmers
should have the legal right to decide that they would prefer to be able to keep
farming on their land, and for their children to have that option, rather than
take the risk of possible long term groundwater depletion or contamination.
This bill does not alter the ownership of the minerals and gas, which remain
vested in the states, and acquisition laws with appropriate compensation would
still apply.
1.10 The Australian Greens support the general discussion
in the report on greenhouse intensity of the domestic coal seam gas and LNG
export industry, particularly the findings in paragraphs 5.20 to 5.22.
1.11 As highlighted in a recent paper prepared by Merril
Lynch[1],
a number of significant questions are yet to be answered regarding the
emissions profile of Australia’s domestic coal seam gas and LNG export
industries, including:
- The accuracy of the diverse assumptions built into industry
commissioned life-cycle analysis of CSG to LNG projects (including assumptions
that gas will substitute for coal), and
- The accuracy of current Australian emissions reporting standards,
and the risk that current practices under-estimate actual emissions as they are
not specific to the Australian context.
1.14 The government and the public has a significant
interest in ensuring the full costs and benefits of this industry, including
greenhouse implications, are fully understood when deciding the degree to which
this industry should be supported. Noting that this support from our society
takes many forms - through regulatory approvals, the various forms of public
support extended through subsidies, grants and infrastructure investments by
Australia’s governments, and the social and environmental costs of this
industry. It is also very much in the interest of industry and investors to
have accurate information available about the emissions intensity of coal seam
gas projects, to ensure accurate projection of the future carbon liability of
these projects.
1.15 Further, steps must be taken, as noted in the
report’s paragraph 5.22 to put in place rigorous monitoring and regulatory
regimes, with the necessary technical capacity to monitor all gas wells and
other potential sources of fugitive emissions.
1.16 Building on the findings in Chapter 5 of the report,
the Australian Greens make the following additional recommendations:
Recommendation 1
1.17 That a comprehensive independent life cycle assessment of
the greenhouse gas intensity of Australia’s domestic and export coal seam gas
industry is undertaken promptly, to ensure that decisions to approve such
activities are informed by independent, accurate information, noting such
information is also invaluable for industry and investors.
Recommendation 2
1.18 That the federal Government promptly develop
greenhouse gas accounting methodologies appropriate to coal seam gas extraction
and production in Australia.
Recommendation 3
1.19 Any projections of emissions from proposed coal seam gas activities must be specific to the gas field, whether it is coal or
shale (or any other source of natural gas), to the technologies used in
extracting transporting, processing and burning the gas, and the regulatory
framework under which the industry operates.
Recommendation 4
1.20 Governments must have in place rigorous, independent
monitoring of greenhouse emissions throughout coal seam gas extraction and
production processes, including monitoring of each gas well and all other
potential sources of greenhouse emissions. The regulatory regimes must be
backed up by a qualified inspectorate that can ensure compliance.
1.21 With regard to paragraph 5.1, we note there are
still significant questions around whether the life-cycle emissions of coal
seam gas is significantly less than coal, and secondly, even if it is found to
have lower emissions intensity, this simply may not be good enough given need
to urgently stabilise and start reducing global emissions (particularly when
the adverse water, food security, rural community and Reef impacts are
considered).
1.22 The Australian Greens would like to thank the many
scientific, environmental and community groups, and members of the public, that
made invaluable submissions to this inquiry, particularly the landholders and
groups who gave evidence during the committee's hearings in Roma, Dalby,
Brisbane, Narrabri, and Canberra.
Senator Larissa Waters
Australian Greens Senator for Queensland
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