In Queensland, the CSG industry’s area of development is increasing, the number and density of CSG wells is increasing and the number of immediately impacted farmer’s water bores is increasing, yet only half of them have been made good on to date, while inexplicably, the same number that are NOT immediately affected bores have also been made good on.
This information is discussed in the recently released 2019 UWIR Annual Report. The report discusses updates to the adaptive management approach the government is taking to managing the CSG impacts on underground water as described in the 3 yearly UWIR (Underground Water Impact Report).
In a joint statement released regarding this report, the Basin Sustainability Alliance (BSA) and Property Rights Australia (PRA) state their considerable concerns regarding the developing situation and the way the report leaves the experience of the farmers in this situation with unanswered questions and unconsidered issues.
Chair of PRA, Mrs Rea says as usual with these reports, the perspective taken is one from the Government and Industry and it fails to capture or relay the difficulties that the farmers who are expected to host this industry and its impacts are suffering from.
Mrs Rea goes on to state that these research and regulatory activities must move to truly consider the other stakeholders in this equation, the farmers. She says that those Farmers who are required to navigate this complex legislative and industry driven process experience conflicts and difficulty and say that the report fails to consider them or their side of the experience. Their experiences include:
- conflicts in the way the rules are implemented (in a way that often benefits the industry),
- problems arising when day to day agricultural water bore problems (non CSG) arise that have been left out of the revised Water Act,
- the time and money they must now invest to engage with the forced situation, and when problems occur, the additional expertise they are required to pay for to present their side of the issue,
- the issue of free gas impacts on bores not being given the same attention and support as the analysis of bores whose water levels drop due to CSG impacts,
- the fact that the farmer must deal with not just Office of Groundwater Impact Assessment, but also Department of environment & Science and the CSG industry and this triples the complexity and time involved by an order of magnitude for the farmer.
Ms Rea said that “while the academic and research side is necessary and there is undoubtedly big picture data that is becoming clearer during each reporting period, the day-to-day reality on the ground at the farm is just as important and must be given an equal level of examination and adaptation and financial support.”
“Unfortunately, this is the same story for almost any aspect of the impact of the CSG Industry for the individuals in agricultural required to host the industry.” says Ms Rea. — ENDS
Further Briefing Notes
As a result of the impact of the CSG industry activities through the removal of water from the target aquifer and resulting effects on over/under-lying aquifers through connectivity, the Office of Groundwater Impact Assessment (OGIA) carries out an independent cumulative assessment in the ‘cumulative management area’ (CMA) and prepares an Underground Water Impact Report (UWIR) every three years.
The most recent UWIR is the Surat UWIR 2019, which took effect from 16 December 2019 and superseded the previous two UWIRs from 2012 and 2016.
An annual report is prepared to provide an update on changes to circumstances that would impact on the predictions reported in the current UWIR. The most recent annual report has been released in December 2020.
The following is a summary of the updated information to the UWIR 2019.
- Inclusion of Coal Mines
Surat CMA was amended to include coal mines in the Surat Basin. As a result, OGIA is now working on the integration of coal impacts in the next iteration of the UWIR, which is due in late 2021.
- Net increase of planned CSG Development
In 2020, the net planned development area had increased by about seven per cent since the UWIR 2019.
The majority of this change is driven by an increase in planned production area from Santos.
- Increase to total number and density of CSG Wells
At the time of the UWIR 2019, there were about 6,800 existing CSG production wells. This number has now increased to about 8,000. With the increase in net footprint, the total number of projected wells has also slightly increased – from about 21,000 reported at the time of the UWIR 2019, to about 22,000 now. There have also been some changes to proposed well densities: the average well density is about 1.7 wells per km2, with individual tenure holders’ well densities ranging from 1.3 to 1.8 wells per km2.
- IAA (Immediately Impacted Area) Bores
there is a total of 224 bores that have been identified as IAA bores since the first UWIR in 2012.
Prior to 2019, 122 IAA bores were identified. The 2019 report identified an additional 100 IAA bores to be assessed. This report has made adjustments to a net increase of 2 IAA bores since 2019 UWIR, leaving a total of 224 IAA Bores.
- Make Good Agreements
Of the 224 effective IAA bores identified so far, make-good agreements have now been achieved for 117 bores. In most cases (about 100), the agreements have resulted in financial compensation. Additionally, tenure holders have reached 112 agreements for bores that are not identified as IAA bores.
- LAA (Long Term Affected Area) Bores
Expansion of the industry development profile (mostly Santos to the north) has resulted in a net increase of an additional 22 LAA bores compared to the UWIR 2019.
- Total Volume of CSG Water Extracted
A total reported volume of 54,000 ML was produced from CSG wells in 2019.
- UWIR reaching into agricultural controls to address related CSG impacts
In relation to management of impact of CSG in springs, the UWIR is considering the use of stock control measures to improve wetland resilience to impact instead of a CSG industry related control measure.
Issues being reported from the perspective of the farmer:
While the UWIR and the Annual Reports are significant achievements in terms of adaptive management and data gathering and interpretation from Government / CSG Industry perspective, it fails to capture or relay the difficulties that the farmer expected to host this industry and its impacts are suffering from. As a group PRA/BSA are calling on the powers that be in government and industry to expand their ‘consultative’ and regulatory activities to truly consider the other stakeholders in this equation, the landholder.
See below a brief summary of some of the issues being reported by members to PRA/ BSA
Issues that farmers are facing with the implementation of the UWIR and resultant interaction with the industry:
- In relation to farmer’s underground water rights prior to the Water Act 2012 (changed to encompass the CSG industry)
- rights to drill replacement bores at their own determination are subjugated / potentially removed
- Under the Water Act prior to 2012, if a Farmer’s water bore was to collapse, he was able to drill a replacement bore in the same location, simply classified a ‘replacement bore’. Importantly, the farmer was able to make that decision at any time, a time suitable to his financial and operational needs. This was lost/ failed to be accommodated when the Water Act was amended.
- arbitrary ‘baseline assessments’ are now conducted by gas companies which are relied upon to determine make good agreements.
- The amendments to the Water Act 2012 granted the gas companies unlimited take, which now means that a farmer’s bore is subject to predicted impacts from the gas industry activities and such impacts will make the bore subject to make good arrangements. An arbitrary baseline assessment is required to be undertaken by the gas company on the farmer’s water bores in the impacted area: arbitrary because, Gas industry ‘baseline assessment’ becomes the status of the bore that forms the basis for any make good valuation. The implications of this are:
- A baseline assessment on a collapsed bore, before it can be refurbished, will mean the bore is listed as nonoperational and therefore reduces his make good entitlement significantly.
- If the farmer decides to drill a bore next to the old one, once considered a replacement bore, it is now considered a ‘new bore’ and will not be subject to
- rights to drill replacement bores at their own determination are subjugated / potentially removed
- the same make good arrangements as the current bore. Consequently, since 2012 he has lost his right to drill a replacement bore at his convenience.
- Baseline Bore Assessments conducted en mass by the gas companies
- Who is checking the voracity of the reports?
- If a farmer is not satisfied that the report by the company is correct, he must fund his own expert investigation costs.
- During a review cycle, the farming community requested that 10% of bore assessments undergo field verification is that occurring, who is checking
- The need to undertake additional monitoring and management of their bores in direct relation to the CSG Industry costs farmers, this is an additional impost that would not be present if not for the CSG industry. Farmers should be provided financial support in relation to the additional costs to their bottom line.
- Inconsistent implementation (as it suits the industry)
- Some farmers are provided a make good agreement on a bore that is Not classified IAA,
- Others are offered a make good agreement on bores that have not undergone a baseline assessment
- Others are told that a make good will not be done until the bore undergoes a baseline assessment
- Farmers must deal with the responsible tenure holder for make good, but impacts to water bores could be from neighbouring tenure holders, enabling tenure holders to refuse to address an IAA because their individual modelling shows they are not undertaking work in the area for a long period of time.
- Some neighbouring tenure holders have been known to shut in and plug and made good on water bores despite the bore not being on their tenure.
- Impacts from CSG activity are not limited to drops in water level, free gas (increase in methane in the head space of the bore and dissolved in the water) is also considered as an impact (and has serious health and safety implications for the farmer). However, to date the UWIRs are not capturing this information in their reporting in relation to the modelling, nor in relation to the number of make good agreements that have been undertaken in relation to free gas.