Australia: The Rise of the Girly Gas

Coal seam gas (CSG), once referred to as the 'girly gas', due in part to its low calorific value, is in the spotlight more than ever.

Issues covered in the media range from commercial viability of the projects to impacts upon agricultural land; from community impacts to environmental impacts.

This article outlines the environmental impacts of CSG activities, addresses how the Queensland and Federal Governments are seeking to manage these impacts while maintaining support of this burgeoning industry and evaluates the implications of this regulation on the approval processes of four proposed CSG to Liquefied Natural Gas (LNG) projects in Queensland. With the decision of the new Federal Minister for the Environment, Tony Burke due on 22 October 2010 in relation to two of these projects, it is timely to investigate and analyse the particular environmental issues associated with these projects.


Barely a day passes without a newspaper article, media release, community newsletter or blog discussing, criticising, evaluating, supporting or decrying the CSG activities undertaken or planned in Queensland's Surat and Bowen basins.

Issues range from commercial viability of the projects to impacts upon agricultural land; from community impacts to environmental impacts – not to mention the skills shortage that is feared to result from the approval of the proposed major CSG projects. A gas once referred to as the 'girly gas' due in part to its low calorific value is in the spotlight more than ever.1

The purpose of this article is to focus on the environmental impacts of CSG activities and address how the Queensland and Federal Governments are seeking to manage these impacts while balancing that regulation against its support of the industry generally. I will then evaluate the implications of this regulation for the approval processes of four of the proposed CSG to LNG projects in Queensland.

What is CSG?

CSG is a natural gas, approximately 98 per cent methane, which collects in underground coal seams by bonding to the surface of coal particles. The CSG process involves drawing water from the coal seams which releases the CSG.2 In circumstances where the coal seams are very deep and of low permeability it may be necessary to use the method of hydro-fracture (or 'fraccing') to increase permeability. This is done by pumping a fluid comprising 99.5 per cent water and sand (plus 0.5 per cent of other additives) at high pressure down a cased well and into the coal seam.3

Environmental Impacts

The primary environmental impacts of CSG activities are the management of CSG water and the impacts on groundwater, in particular, in relation to the rights of other users.

CSG Water

CSG water means underground water brought to the surface of the earth or moved underground in connection with exploring for or producing CSG4. Significant quantities of CSG water are likely to be generated as a result of CSG generation and contain variable concentrations of salt. The salinity of CSG water is typically measured as the concentration of total dissolved solids (TDS) with values ranging from 200 to more than 10,000 milligrams per litre. Good quality drinking water has TDS values of less than 500 milligrams per litre. The TDS of sea water is between 36,000 and 38,000 milligrams per litre. The salty nature of CSG water means it has the potential to cause environmental harm if released to land or waters through inappropriate management.5

In March 2010, the Queensland Government released its Coal Seam Gas Water Management Policy (CSG Water Management Policy). The policy and legislative developments discussed below reflect the commitments set out in the CSG Water Management Policy.


The extraction of CSG necessarily involves the taking of groundwater. In its Blueprint for Queensland's LNG Industry (September 2009), the Queensland Government recognised that it was critical to manage the impacts (including the cumulative impacts) of CSG extraction on other water users and on springs.

The majority of the proposed CSG activities fall within the Great Artesian Basin and it appears that more information is required on the impacts of those activities. For example, a report released in early September 20106 by the Central Downs Irrigators Limited warns of a risk of one of Queensland's most important freshwater aquifers, the Condamine Alluvium, draining into the saline Walloon Coal Measures which are subject to CSG activities.

The report notes, however, that insufficient data exists to quantify the extent to which freshwater will flow into the coal measures and in a statement to the media on the day of the release of the report, the Queensland Minister for Natural Resources, Mines and Energy The Honourable Stephen Robertson stated that the Government would treat the report seriously but that a moratorium on CSG exploration was not necessary because "to a large extent, a moratorium is already in place through a heavily-conditioned approval process placed in CSG exploration and development through the independent Coordinator-General".7 This process is discussed further below.

Legislative Context and Developments

The environmental impacts of CSG activities are regulated primarily by the Environmental Protection Act 1994 (EP Act). However, where CSG activities form part of a larger project (such as the four proposed Queensland CSG to LNG projects discussed below), significant project status under the State Development and Public Works Organisation Act 1971 (Qld) (State Development Act) can be given to the project. Significant projects receive a "whole of government" environmental impact assessment overseen by the Coordinator-General. The Coordinator-General then assesses the environmental impact statement (EIS) and releases an evaluation report in which the Coordinator-General imposes conditions on the construction and operation of the project. Where secondary approvals (such as environmental authorities under the EP Act) are required, the conditions imposed upon those secondary approvals must be consistent with the Coordinator-General's conditions.8

Where CSG activities (whether they form part of a larger project or not) will have or are likely to have an impact on a matter of national environmental significance9, it will require referral to the Federal Minister for Environment (Federal Minister) for a decision as to whether the project is a controlled action under the Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act). Where a project is declared to be a controlled action under the EPBC Act, it requires environmental assessment and approval by the Federal Minister. Where appropriate, this environmental assessment can be carried out in conjunction with the assessment process under the State Development Act.

Environmental authorities for petroleum activities such as coal seam gas exploration production must be obtained under the EP Act10. Petroleum activities and greenhouse gas activities are together referred to in the EP Act as 'Chapter 5A activities'. Chapter 5A activities are either a level 1 or a level 2 activity depending upon the risk of environmental harm. The environmental assessment process for level 1 chapter 5A activities is more stringent than as for level 2 chapter 5A activities. Schedule 5 of the Environmental Protection Regulation 2008 (Qld) (EP Regulation) sets out the relevant level 1 chapter 5A activities.

An application for a level 1 chapter 5A activity must be supported by a range of information, including:

  • relevant information about the likely risks to the environment11
  • details of wastes to be generated and any waste minimisation strategy12
  • an environmental management plan that complies with section 310D of the EP Act,13 and
  • the prescribed fee.14

Recent amendments to the EP Act and the release of new environmental policies by the Department of Environment and Resource Management (DERM) relating to CSG activities have placed more stringent obligations on CSG proponents. These changes to the regulation of environmental management have impacted upon and delayed the assessment and approval of two CSG to LNG projects (discussed further below).

Underpinning the environmental management of the CSG industry is the concept of 'adaptive environmental management' – a system to monitor and instigate change where required.15 Adaptive management is also said to allow for best practice environmental management to be implemented as technologies develop over time. The concept of adaptive environment management is reflected in requirements in the EP Act and related policies to regularly monitor, evaluate, report on (and where necessary improve) the effectiveness of technologies and environmental protection measures.

Environmental Management Plan (EM Plan)

At the heart of the environment regulation of CSG activities is the EM Plan. The purpose of an EM Plan is to propose environmental commitments to help DERM decide the conditions of the environmental authority (chapter 5A activities).16

Under the EP Act, an EM Plan must describe:

  • each relevant resource authority for the environmental authority
  • all relevant activities the subject of the application
  • the land on which the activities are to be carried out
  • the environmental values likely to be affected by the activities, and
  • the potential adverse and beneficial impacts of the activities on those environmental values.

An EM Plan must also:

  • state the environmental protection commitments the applicant proposes for the activities to protect or enhance the environmental values under best practice environmental management
  • contain enough information to allow DERM to decide the application and conditions to be imposed on the environmental authority (chapter 5A activity)
  • address any other matter prescribed under an environmental protection policy or regulation, and
  • include a rehabilitation program for land proposed to be disturbed under each relevant resource authority for the application, which also states a proposed amount of financial assurance for the environmental authority.

However, amendments to the EP Act which took effect on 5 July 2010 impose specific requirements for EM Plans relating to a CSG environmental authority (that is for an environmental authority (chapter 5A activity) for a level 1 chapter 5A activity involving exploring for or producing coal seam gas). Further, the holder of an existing CSG environmental authority must give DERM a revised EM Plan that complies with the following requirements by 5 July 2011.17

In such a case, the EM Plan must also state the following:

  • the quantity of CSG water the applicant reasonably expects will be generated in connection with carrying out each relevant coal seam gas activity
  • the flow rate at which the applicant reasonably expects the CSG water will be generated
  • the quality of CSG water, including changes in the water quality that the applicant reasonably expects will happen while each relevant coal seam gas activity is carried out
  • the proposed management of the CSG water including use, treatment, storage or disposal of the water
  • the measurable criteria (the management criteria) against which the applicant will monitor and assess the effectiveness of the management of the CSG water including criteria for each of the following:
    • the quantity and quality of the water used, treated, stored, disposed of
    • protection of the environmental values affected by each relevant CSG activity; the disposal of waste, including for example, salt, generated from the management of the water, and
  • the action that is proposed to be taken, if any of the management criteria are not satisfied, to ensure the criteria will be able to be satisfied in the future.18

Each year, CSG operators must submit as part of the annual return an evaluation of the effectiveness and appropriateness of the management of CSG water.19 If it is determined that the CSG water has not been managed appropriately, then the CSG operator must outline what future actions will be taken to ensure appropriate management of their CSG water. This requirement does not apply to the first annual return the holder of an existing CSG environmental authority is required to lodge after 5 July 2010, unless the holder has already given DERM a revised EM Plan.20

Evaporation Dams

The EM Plan must not provide for using a CSG evaporation dam in connection with carrying out a relevant CSG activity unless the EM Plan includes an evaluation of best practice environmental management for managing the CSG water and alternative ways for managing the water and that evaluation shows there is no feasible alternative to a CSG evaporation dam for managing the water.21

A CSG evaporation dam means an impoundment, enclosure or structure that is designed to hold CSG water for evaporation.22 CSG evaporation dams should be distinguished from CSG water aggregation dams. DERM prefers that CSG water be contained in dams designed to aggregate water (deep dams with a small footprint) rather than dams designed to evaporate water (shallow dams with a large surface area).

The prohibition applies also to existing CSG environmental authorities, unless the construction of the CSG evaporation dam had substantially commenced before 5 July 2010. Despite this, it is still possible for DERM to approve the construction of an CSG evaporation dam as part of the EM Plan approval process, provided the requirements of section 310D(6) (above) are met.

In March 2010, DERM released Guideline: Preparing an environmental management plan for coal seam gas activities (EM Plan Guideline) to further assist understanding the requirements of EM Plans for CSG authorities.

The EM Plan Guideline describes the preferred structure of an EM Plan, including a list of potential project activities and environmental values that could be relevant to the project area. As with all EM Plans, the level of detail required depends upon the specific characteristics of the project activities and the environmental values of the project area. The amount of information provided should be commensurate to the risk of environmental harm and based on an assessment of the potential impacts of the proposed activities on the environmental values of the project site.

CSG Water Management Hierarchy

In particular, the EM Plan Guidelines provides significant detail on how CSG water should be managed by reference to a 'CSG water management hierarchy'. The EM Plan Guidelines distinguish between preferred management options (Category 1) and non-preferred management options (Category 2).

In Category 1, four management options are preferred:

  • injection where the detrimental impact on environmental values and water quality is unlikely and where it can be demonstrated that the injection fluid has inconsequential reactivity with the target formation and native groundwater it will come into contact with
  • untreated use, where the CSG water can be used without first substantially changing its composition (e.g. livestock dewatering, mining and extractive industries such as coal mine wash plants and industrial uses such as cooling tower water)
  • treatment (for example, by desalination, chemical treatment or ancillary sterilisation or filtration) and use, although the CSG water must be of an appropriate quality for the proposed used and comply with the conditions of the environmental authority, the general approval of a resource for beneficial use or a specific approval of a resource for beneficial use,23 and
  • direct supply via pipeline to a water supply dam managed by a water service provider, in which case proof of a contract for the supply of the water between the environmental authority holder and the responsible entity must be provided along with an indication of the amount and quality of the water to be supplied.

In Category 2, the following management options are considered to be 'non-preferred':

  • disposal via evaporation dams, unless an applicant can demonstrate that there is no feasible alternative for using, treatment, storing or disposing of CSG water
  • disposal via injection where a detrimental impact is likely
  • disposal to surface waters, and
  • disposal to land, unless it is approved for beneficial use (e.g. for dust suppression or irrigation).

EM Plans that are developed through the environmental impact assessment process must describe the preferred option where several options are proposed within the EIS. Management options must be converted into specific commitments within the EM Plan.

Coal Seam Gas Water Management Plan (CWMP)

To address the specific issues arising out of the management of CSG water, the EM Plan Guidelines also require a CWMP to be incorporated into the EM Plan.

The CWMP must:

  • provide an estimate of the volume of CSG water produced annually over the life of the project and describe the characteristics of CSG water produced
  • describe how and where the CSG water will be produced, aggregated, stored and kept separate from other waters until it is used, treated, distributed or disposed of
  • describe how CSG water will be dealt with in accordance with the CSG water management hierarchy including a description of the estimated amount of CSG water that will be dealt with under the preferred water management options in category 1 and the water management options that are not preferred in category 2
  • where CSG water is proposed to be treated, describe:
    • the treatment process
    • how and where the treated water will be stored and used, and
    • how and where the waste generated by the treatment process will be stored, used and/or disposed of;
  • If any CSG water is proposed for direct disposal as waste, provide information sufficient to demonstrate that legislative, environmental, technological, economic and social requirements have all been evaluated and taken into consideration in deciding the disposal as waste is the only feasible option;
  • describe the detail of any pilot programs or trials for CSG water solutions, including:
    • objectives of project
    • quantity and quality of CSG water applied
    • location and area
    • duration of the activity
  • describe the characteristics of the receiving environment
  • describe the control measures that will be implemented for each water management option (aggregation, storage, treatment, use or disposal) to prevent or control the release of a contaminant or waste to the environment
  • describe the indicators or other criteria against which the performance of the CSG water management practices will be assessed
  • describe a monitoring program sufficient for the prediction and early detection of any detrimental impacts on the receiving environment from CSG water management practices
  • describe the procedures that will be adopted to regularly review the monitoring program and to report to management and DERM should unforeseen or non-compliant monitoring results be recorded
  • describe the procedures that will be implemented to prevent unauthorised environmental harm from unforeseen or non-compliant monitoring results.
  • describe procedures for dealing with accidents, spills, failure of containment structures and other incidents that may arise in the course of the CSG water management practices and result in the unexpected release of contaminants or waste to the environment, and
  • describe the procedures to be used to identify and implement strategies that minimise the quantity of CSG water generated at the surface of the land, promote efficiency in the use of CSG water as a resource through direct use and treatment, improve the water management practices employed where non-preferred management options are being used and minimise the total area of land disturbed by CSG water dams.

Model Environmental Authority Conditions

In further support of the legislative amendments and new policies, DERM (in consultation with the Australian Petroleum Production and Exploration Association) has also introduced model conditions for level 1 environmental authorities for CSG activities, which may be used as a basis for proposing specific environmental protection commitments in an EM Plan.

Despite the existence of these model conditions, it is possible for applicants to propose alternative conditions which are more specific to the particular project through the EM Plan. DERM may also impose alternative conditions if necessary. However, the introduction to the model conditions states that it is unlikely that DERM will accept less rigorous conditions without clear evidence that the risk of environmental harm is significantly reduced by the specific environmental practices to be implemented, the technologies to be used or the nature of the environmental values impacted by the project.

Management of Groundwater impacts

CSG producers are permitted to take groundwater under the Petroleum & Gas (Production and Safety) Act 2004 (Qld) (Petroleum and Gas Act) as it is a necessary activity in the process of extracting CSG.

Legislative amendments are proposed to the Water Act 2000 (Qld) (Water Act) to transfer the management of groundwater associated with CSG production from the Petroleum and Gas Act to the Water Act.

These amendments will also include trigger thresholds for groundwater level drawdown in bores and springs. If the projected decline in groundwater levels (associated with CSG production) in water bores exceeds the trigger threshold and the bore owner has experienced a reduction in water supply, then the CSG operator must investigate the matter.

If it is established that the CSG activities have contributed to the reduction, then the CSG operator must negotiate arrangements with the bore owner to 'make good' the impact. Such arrangements may include restoration of water supply (such as by deepening a bore) or compensation for the loss of supply to the bore owner.

CSG producers will be required to periodically prepare and submit underground water impact reports to DERM for approval. The reports will be required to contain: the results of monitoring; projects of the extent of water level impacts; an inventory of springs where impacts on water levels in underlying aquifers are projected to exceed trigger threshold values and an assessment of the risk to those springs having regard to matters such as the connectivity of the springs to the underlying aquifers; and a proposal for managing impacts.

DERM has also indicated that the Surat Basin is likely to be a 'cumulative impact management area' within its proposed cumulative underground water management regime. This regime is designed to manage areas where water level impacts of CSG producers overlap.

At the time of writing, no such legislative amendments have been introduced to give effect to these proposed changes. The author's inquiries with DERM indicate that these amendments are likely to be tabled by the end of 2010.

Soft Measures

The Queensland Government has also introduced further initiatives to compliment these legislative and policy developments. In July 2010, the State Government announced additional compliance staff within DERM and Queensland Parks and Wildlife and a Mines Registrar who will be the first point of contact for land holder issues arising from the CSG industry and attend to applications for tenements (together with two support staff who will focus on compliance, monitoring and enforcement).24

On 4 August 2010, the Minister for Climate Change and Sustainability The Honourable Kate Jones announced the appointment of a 'squad' of 11 additional officers to undertake approvals and compliance functions in the CSG sector, "working to ensure companies meet all their regulatory requirements for environmental protection."25

At the same time, the State Government announced it would ban petroleum compounds containing benzene, toluene, ethylbenzene and xylenes (commonly referred to as B-TEX) from use in CSG operations or 'fraccing. Fraccing involves pumping fluid at high pressure into a coal seam to facture the seam and allow gas to flow readily into gas wells (although the vast majority of gas wells do not need to be fracced).26 The use of B-TEX in fraccing has caused community concern as evidenced by the recent detection of small quantities of the chemicals during routine testing by Australia Pacific LNG27. While there was no evidence of environmental harm or evidence of the source of the chemicals, there has been a call by environment group, Friends of the Earth for a moratorium of CSG activities as a result - further indication of the attitudes in relation to these activities.

At the time legislation had not been introduced to effect this requirement, the Minister for Natural Resources, Mines and Energy announced that he would be writing to all existing CSG environmental authority holders to express the expectation that 'the current non-use of B-TEX chemicals will continue until such time as the new legislation is in place'. The Minister also foreshadowed that he will use the existing head of power in the EP Act to require DERM to refuse any application for new CSG activities that involve the use of B-TEX chemicals to facture the coal seam.

On 5 October 2010, the Minister introduced the Natural Resources and Other Legislation Amendment Bill (No. 2) 2010, which (amongst other things) deems an environmental authority (chapter 5A activities) to include a condition prohibiting the use of 'restricted stimulation fluids' such as B-TEX in fraccing.

Despite the somewhat emotive nature of the media releases, the State Government has also gone to great pains to assure the CSG industry of its importance and value. The balance between economic development and environmental protection (and the corresponding balance between stakeholder interests) will be a fine one that must be well managed by a Government already experiencing a lack of popularity amongst voters and business.

Impact on Current Proposals

Four CSG to LNG projects are currently subject to environmental impact assessment by the Coordinator-General under the State Development Act and by the Federal Environment Minister under the EPBC Act. Following such assessment, the proponents must obtain secondary approvals, including environment authorities under the EP Act.

In this section, I provide an overview of the status of the projects as at the date of writing and discuss how the new policy and legislative developments have impacted upon the assessment process. The current status of the projects is set out in Table 1 below.

Table 1: CSG to LNG Projects28

Project Proponent Status under State Development Act Status under EPBC Act
Gladstone Liquefied Natural Gas Project (GLNG) Santos Limited and PETRONAS29

Declared significant project on 16 July 2007

Coordinator-General's Evaluation Report issued 28 May 2010

Declared controlled action on 14 April 2008

Federal Minister extended period in which to make a decision on 11 July 2010 (decision now due 22 October 2010)

Federal Minister accepted variation to project (involving an amended route through a common infrastructure corridor proposed by the Queensland Government) on 3 September 2010

Queensland Curtis LNG Queensland Curtis LNG

Declared significant project on 4 July 2008

Coordinator-General's Evaluation Report issued 23 June 2010

Declared controlled action on 15 September 2008

Federal Minister extended period in which to make a decision on 11 July 2010 (decision now due 22 October 2010)

Australia Pacific LNG Origin Energy Ltd and ConocoPhillips

Declared significant project on 9 April 2009

EIS submitted 29 January 2010

Public notification of EIS until 4 May 2010

Coordinator-General requested supplementary work on 19 July 2010, which was subsequently submitted by the proponent

Coordinator-General's Evaluation Report expected at the end of September 2010

Declared controlled action on 3 August 2009
Shell Australia LNG Shell CSG (Australia) Pty Ltd

Declared significant project on 12 June 200930

Public notification of terms of reference from 2 October 2009 to 2 November 2009

Proponent currently preparing EIS

Declared controlled action on 21 August 200931

In the Evaluation Report for the Gladstone LNG Project, the Coordinator-General stated he was not convinced that there was sufficient detail in the draft EIS and SEIS on the construction layout and location of the gas field infrastructure, in order to determine with some degree of accuracy the impacts on the environmental values in the gas fields. He further went on to comment that the content of the EIS and the Supplementary EIS was 'not sufficient to provide the necessary detail required by the legislation in applications for petroleum and gas tenures'. It is not intended to analyse the particular concerns raised by the Coordinator-General. However, it is worth noting that many of the legislative requirements referred to by the Coordinator-General came into force after the preparation of the EIS was complete and submitted to the Coordinator-General for evaluation. Therefore, the Coordinator-General has imposed further assessment requirements on the proponents to be provided at particular future stages of the approvals process. The proponent has indicated that it will be providing all information as required by the Co-ordinator General.

Further Required Information

Within three months following final investment decision and prior to petroleum activities taking place, the proponent must provide to the Coordinator-General for review a gas field cumulative impacts assessment report addressing: regional impacts on terrestrial flora and fauna, biodiversity values, listed species and ecosystems; riparian habitats; surface and groundwater environmental values; and soils, including the ability to support ongoing agricultural production.

The Coordinator-General also required the following reports to be provided to him for review:

  • ecological constraints planning report (prior to the issue of the environmental authorities)
  • CWMP (prior to the issue of the environmental authorities)
  • Brine Management Strategy (within 90 days of the issue of the Coordinator-General's Report), and
  • Environmental Offsets Program.

Prior to the commencement of the gas field activities, the Coordinator-General also requires the following:

  • water quality monitoring program
  • regional groundwater model
  • groundwater and springs impact assessment
  • operational plans, and
  • water quality and soil monitoring plan.

The Coordinator-General referred to the Model Conditions in his evaluation report and stated that they must be used as a guide as to environmental authority conditions that may be imposed. He qualifies this by saying that the actual conditions imposed by DERM as a result of the assessment of the EM Plan may be different.

Similar conditions were imposed by the Coordinator-General on the Queensland Curtis LNG Project.

On 11 July 2010, the (then) Federal Minister for the Environment, Peter Garrett delayed assessment of both projects until 11 October 2010 to provide 'a chance for further information to be provide, including the areas indentified as deficient in the Queensland Coordinator-General's report'.32 At the time of writing, the new Minister for the Environment, Tony Burke, had announced he would be in a position to meet this deadline33. Further, it will be interesting to assess the impact of the minority Federal Government's agreement with the Greens on CSG activities in Queensland given that party's policy position on such activities.


The past 12 months have seen many changes in the way the environmental impacts of CSG activities are regulated. The important task of balancing stakeholder interests in this area has required careful management by State and Federal Governments alike. Environmental impacts are but one aspect of the issues confronting those involved in the industry. It is beyond the scope of this paper to discuss issues arising from the protection of strategic cropping land, overlapping tenures and land access. However, these are all critical and are also subject to significant legislative and policy developments. The "girly gas" is the centre of attention and will be for some time to come. It is now for the proponents and their consultants to navigate their way through the regulatory mine and come through the other side with their approvals and relationships with the government and community in tact.

1. 'More gas mergers in the pipeline' by Mathew Murphy (The Age, 10 March 2010)

2. Extract from the Department of Environment and Resource Management website (13 August 2010).3 Arrow Energy Factsheet entitled 'Fraccing' dated June 2010.

4. Environmental Protection Act 1994 (Qld) (EP Act), s 310D(7).

5. Queensland Government Fact sheet entitled 'Coal Seam Gas Water'.

6. Groundwater connections between the Walloon Coal Measures and the Alluvium of the Condamine River, John R Hillier, August 2010.

7. Media Release of the Honourable Stephen Robertson, Tough CSG approval process will protect the environment, 2 September 2010.

8. EP Act, s 310D(5).

9. Matters of national environmental significance include such matters as listed threatened species or ecological communities; RAMSAR wetlands and world and national heritage places.10 Corresponding petroleum authorities must also be obtained under the Petroleum and Gas (Production and Safety) Act 2004 (Qld) referred to in the EP Act as the "relevant resource authority".

11. EP Act, s 310C(c)(1).

12. EP Act, ss 310C(c)(ii); 310C(c)(iii).

13. EP Act, s 310C(d)(i).

14. EP Act, s 310C(d)(ii).

15. Queensland Government Factsheet, 'Adaptive environmental management regime for the coal seam gas industry'.

16. EP Act, s 310D(1).

17. EP Act, s 662.

18. EP Act, s 310D(5).

19. EP Act, s 316A.

20. EP Act, s 663.

21. EP Act, s 310D(6).

22. EP Act, s 310D(7).

23. DERM's Guideline Approval of coal seam gas water for beneficial use provides more information in this regard.

24. Media Release, Bligh Government to closely monitor gas industry in Surat Basin, 21 July 2010

25. Media Release, New environmental squad to crack down on coal seam gas industry, 4 August 2010

26. Media Release, Government bans BTEX use in coal seam gas section, 4 August 2010

27. Media Release, Minister for Climate Change and Sustainability, 19 October 2010

28. At the time of writing, none of the projects had reached the stage of financial investment decision.

29. On 9 September 2010, Santos announced that it had sold a 15 per cent stake in this project to French oil and gas company Total for $650 million. At the same time, Petronas announced that it had sold 5 per cent to Total. Therefore, Santos owns 45 per cent, Petronas owns $35 per cent and Total owns 20 per cent of the GLNG Project.

30. Only the LNG facility itself has been declared a significant project. The CSG fields component will be assessed by EIS under the EP Act, with Arrow Energy as the designated proponent. The gas produced as part of this component will provide potential gas supply for the LNG facility. In August 2010, CS CSG (Australia) Pty Ltd, a 50/50 joint venture company owned by Shell Energy Holdings Australia Limited and a subsidiary of PetroChina Company Limited acquired all of the shares in Arrow and therefore owns the CSG tenement. This aspect of the project has also been referred under the EPBC Act and declared to be a controlled action 26 March 2010.

31. This refers to the LNG facility only.

32. 'Garrett stalls Queensland's coal seam gas prospects' (ABC News, 14 July 2010).

33. 'LNG projects count Burke' by Angela Macdonald Smith (Australian Financial Review, 24 September 2010) and 'Coal seam gas decision close' (Queensland Country Life, 24 September 2010)

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.