On Friday, as one of hundreds of people to object to the Narrabri Gas Project on top of over 20,000 written submissions, I expressed pity at the difficult and nearly impossible task facing the @IPC_NSW due to the poor assessment done by DPIE. Here's why: (1/x) #PeopleVNarrabriGas

By law, decision-making bodies like the IPC must consider certain things in the planning laws and regulations: these are called "mandatory relevant considerations" and if they are not considered, the decision is legally unsafe and can be appealed. (2/x) #PeopleVNarrabriGas

These considerations include the principles of ecologically sustainable development, including the precautionary principle and the principle of intergenerational equity, they include things like biodiversity and water impacts and greenhouse emissions, and public submissions (3/x)

Unfortunately, the Department didn't really address all the mandatory relevant considerations in their review, which was largely a response to matters raised in submissions, and some discussion of hydrogeological impacts (4/x)

It's important to consider matters raised in submissions, and as the Land and Environment Court has ruled, this must involve an active consideration of those issues, but they are not the only mandatory consideration (5/x) http://www.lec.justice.nsw.gov.au/Documents/Speeches%20and%20Papers/PrestonCJ/PrestonCJThe%20adequacy%20of%20the%20law221014.pdf

The review used some dismissive language about community concerns that were undermined by the detailed expert material that found that risks to groundwater were potentially significant, with a lot of uncertainty surrounding them, but mitigating conditions not fully proposed (6/x)

Likewise, the social impact assessment was reviewed with a scathing review by a third-party academic, whose research was then misconstrued by the Department itself. Air quality impacts that would pose harm to human health were barely assessed at all (7/x)

Even worse, greenhouse emissions were not properly calculated, with outdated formulas used to estimate climate impacts and no real discussion of the effects. This is a clear requirement in state planning policy: how can a determination be made without assessment of impacts? (8/x)

Even the project justification was not supported by the material, which found the project would lead to a net decline in manufacturing employment and would not affect gas prices. Dep't Head David Kitto conceded this on day one of hearings, adding more gas was not necessary (9/x)

In reality, we are currently dealing with a gas oversupply crisis, with the industry running out of refrigerated ships in the ocean to store gas without a big enough demand market and wondering whether they should start trying to switch off producing wells (10/x)

Even though bilateral assessments are now in place, there was really no attempt to create conditions that would meet the standards in federal environmental law, which is a neat illustration why handing down approval powers now would be a disaster (11/x)

Stunningly, the Department was unable to properly point to where they had discussed the precautionary principle, which says that where there is the risk of significant or irreversible harm, full scientific certainty is no excuse to try to avoid harm (12/x)

This beggars the question of whether Santos really wants an approval at all, and whether the Department is trying to make it impossible for the project to be approved. It also highlights why independent bodies like @IPC_NSW are so critical (13/x)

It also shows why access to justice is so critical: flawed assessments and decisions can have consequences that last for centuries. In the case of the Narrabri Gas Project, it's agreed that the water table would not return to balance until at least the year 3525 (14/x)

For all these reasons and more, the Narrabri Gas Project is in the wrong place at the wrong time and should not be approved - all power to the #PeopleVNarrabriGas ! (15/15 - end of thread)