Frequently Asked Questions – Arrow Energy EA amendment application
What is an environmental authority?
Under the Environmental Protection Act 1994 (EP Act), resource activities such as coal seam gas (CSG) must be issued with an environmental authority (EA) by the Department of Environment and Science (department) before starting operations.
An EA regulates how an operator manages the potential environmental risks and impacts that may be caused by their activities. The department is responsible for managing and monitoring these activities in Queensland and assessing new or amended EA applications.
What is a major amendment?
When making an assessment level decision, the department considers whether an EA application is a minor or major amendment based on risks of environmental harm and the scale or intensity of activities. Major amendments may trigger a public notification period allowing the public to gain access to the application and make a submission.
A major amendment to an EA requires a high level of assessment due to an increased risk to environmental values or significant increase of the scale or intensity of the proposed activities. An application that seeks to increase the surface area of the proposed activity by 10% or more is also considered a major amendment.
Arrow’s EA amendment application was considered a major amendment as it proposed to increase the surface area of its existing activities by more than 10% (55 wells), and may pose an increased risk to environmental values, such as the risk of groundwater contamination.
What was Arrow’s application for?
In October 2021, Arrow applied to amend its existing EA to increase the number of wells from 6 to 61 (an additional 55 wells), including the addition of gathering pipeline and associated activities on their tenure, PL253, in the Hopeland region. PL253 is in close proximity to the former Linc Energy site, which is not included in the EA tenure.
Arrow had previously submitted an amendment application for this tenure. On 6 October 2021, Arrow withdrew this application and submitted this new application for the same tenure.
On 17 February 2023, Arrow’s amendment application was approved with a number of strict conditions.
What are the changes to Arrow’s environmental authority?
Arrow’s amended application will authorise the addition of 55 gas wells (previously 6 wells, bringing the total authorised to 61).
Key amendments to Arrow’s EA are the inclusion of a number of stringent groundwater conditions.
These groundwater conditions have been applied to carefully mitigate the impact of new activities on groundwater in the area, and particularly in relation to previous contamination events at the former Linc Energy site, adjacent to tenure PL253.
When will the new environmental authority come into effect?
The amended EA will not take effect until Arrow are able to obtain the required statutory authorisations to access the former Linc Energy site to undertake the monitoring, investigation and reporting requirements associated with their groundwater conditions. Access to the site will enable Arrow to inform updates to their groundwater model and predict any changes to the groundwater regime.
What did the assessment process involve?
New and amended EA applications submitted to the department undergo a rigorous assessment process before a decision is made. This process involved considering the proposed activities, impacts from the proposed activities on the environment (e.g. for any impacts to air, land, water, acoustics, waste etc), any measures to mitigate these impacts and public submissions.
EA and EA amendment applications must include an assessment of the likely impact of each relevant activity on the environmental values and information about how impacts to the environment will be managed. Site-specific considerations and environmental modelling (e.g. groundwater modelling) was analysed to identify any risks to the environment and/or to determine the efficacy of proposed mitigation measures.
The department carefully considered and assessed data and environmental modelling provided by Arrow.
The department also sought expert technical advice from CSIRO in relation to Arrow’s groundwater modelling, the groundwater monitoring network and any potential migration of contaminants offsite.
In addition, the department sought advice from Queensland’s Independent Office of Groundwater Impact Assessment on the groundwater model developed by Arrow.
This advice as well as the groundwater monitoring data for the 15 bores installed by the department on and near the former Linc site was considered as part of the assessment process.
Stringent groundwater monitoring and reporting conditions were applied to manage risks to the environment, to avoid or minimise movement of contaminants.
What did the expert advice say about the groundwater impacts of Arrow’s proposal?
The expert advice found that:
- Arrow’s key conclusion that ‘… the potential for this development scenario to significantly affect the site contamination is low’ is reasonably supported by the information and modelling presented by Arrow.
- Arrow’s groundwater modelling forms a good basis to represent current and predicted groundwater movement in and around the Linc site, provided that a supporting simple conceptual model is developed and regularly updated as additional monitoring data becomes available.
- A number of improvements could be made to Arrow’s groundwater modelling and the way outputs are presented going forward.
- Expansion of the groundwater monitoring network (i.e. additional monitoring bores) could better characterise the residual contamination from the Linc site and help manage any mobilised contaminant movement should that occur.
Read the advice from CSIRO and OGIA .
Read a summary of the external expert advice and access the reports.
How did the department apply the expert advice in its decision?
In response to the expert advice, the department included additional groundwater management conditions that provide for the expansion of the existing groundwater monitoring network to enhance data collection and modelling, and implement the improvements to groundwater modelling and reporting.
How will impacts to groundwater be mitigated?
Under the new EA, Arrow is required to comply with a number of conditions to minimise the impact of activities on groundwater.
These include a requirement to undertake the following:
- Expansion of the existing groundwater monitoring network with four (4) new groundwater monitoring bores targeting the Springbok Sandstone in the vicinity of the former Linc Energy Site to measure and predict changes in contaminant movement, groundwater flow direction and drawdown
- Incorporating monitoring data from the four (4) new bores into the groundwater model
- Submission of an interim annual review which analyses all groundwater monitoring results and assesses short-term and longer term data trends
- Developing and submitting a Groundwater Monitoring Plan (GMP), that is prepared by a qualified hydrogeologist, that assesses the potential for the activity to impact the current groundwater conditions of aquifers in the area
- The implementation of a monitoring program for the early detection of any changes in groundwater pressure, level, bore gas pressure, flow direction and ground water quality in all aquifers monitored by groundwater monitoring bores
- Monitoring of all groundwater points on a quarterly basis at identified locations Investigation requirements for exceedances of groundwater parameter investigation limits.
- A requirement to cease production of water for these authorised activities (i.e. the 55 new wells), where an investigation report indicates that the activities have resulted in a change in the direction of groundwater flow on the former Linc Energy site and the migration of contaminants from the former Linc Energy Site
- Annual reporting that requires the submission of all raw data and an assessment of long-term and short-term trends as well as requiring an independent review by a suitably qualified person.
A full list of groundwater conditions is included in the amended EA, which will be made available on the department’s public register portal. A copy of the EA is also available .
What happens if contaminants associated with the former Linc Energy site are found to have moved off site?
Arrow is required to undertake monitoring and reporting against a number of groundwater parameters.
If any exceedances of groundwater parameters are detected (such as contaminants like benzene) Arrow must immediately notify the department, conduct a full investigation into the exceedance/s and submit this to the department.
If exceedances are found to result from Arrow activities, this will result in the activation of a ‘cease producing water or take certain action’ condition, which means that Arrow is required to immediately stop drawing groundwater until a full investigation is complete, and any necessary further actions are taken.
Will the department be undertaking compliance?
Arrow is required to adhere to the requirements and conditions outlined in its EA, or be subject to compliance and enforcement actions under the EP Act.
The department undertakes regular compliance of resource operators to ensure they understand and comply with their obligations under theEP Act. This may involve planned and unplanned site inspections, reviewing monitoring data or undertaking investigations where necessary.
Under Queensland law, the department can take enforcement action where the EP Act has been contravened or there is the potential for environmental harm.
Why did the decision stage take so long?
When assessing complex EA applications, extensions (requested by either the applicant or the department) are often required to allow more time to adequately assess the proposed activities and impacts to the environment.
This application underwent a number of extensions to allow the department to acquire the necessary information required to assess the potential impacts to the environment and seek independent expert advice from CSIRO and the Independent Office of Groundwater Impact Assessment (OGIA) on Arrow’s proposal.
Under the EP Act, the department can extend a decision by 20 business days once without the applicant’s agreement, and any further extensions need to be agreed upon by both parties.
Was the public able to have their say on this application?
Community members were able to provide feedback on Arrow’s EA amendment application during the public notification period, which closed on 12 May 2022.
A number of submissions were received and were considered in the assessment process.
Can I appeal this decision?
Under the EP Act, original decisions made by the department may undergo an internal review or appeal when an application is made by a dissatisfied person. Aside from applicant/s, a dissatisfied person must be someone who provided a proper submission during the public notification stage for the application.
Members of the public are unable to apply for an appeal or internal review, unless they are submitters for the application.
Submitters have been engaged regularly by the department throughout the assessment process and have been notified about their right to appeal.
What other activities does Arrow currently undertake in the Chinchilla area?
Arrow also currently holds an EA for petroleum lease PL493 located north-east of PL253. Arrow’s EA for PL493 does not currently authorise any production wells within 10km of the former Linc Energy site.
Like any other petroleum and gas company, Arrow may apply to the department with additional information to support production activities in this area and the department would consider this through a statutory EA amendment process.
The constraint on production wells within 10km of the former Linc Energy site, on Arrow’s EA for PL493, does not apply to the EA for PL253.
Can Arrow apply for further amendments?
Like any other petroleum and gas company, Arrow may apply for future amendments to their EA.
All applications received by the department undergo the same application and assessment process, and any public notification stages that may apply. As with all applications, site-specific information and potential cumulative impacts are strongly considered.
Any new or amendment EA applications are published on the department’s website.
Is the Queensland Government still undertaking monitoring and remediation activities in the Hopeland area?
Since 2015, the department has undertaken extensive environmental monitoring to manage impacts to the site, including an onsite perimeter groundwater monitoring network to monitor the potential for contaminant migration. This included the installation of 15 monitoring bores on and near the former Linc Energy site.
View the departmental Hopelands groundwater sampling results.
In July 2022, the department transferred the 15 monitoring bores into the custodianship of the Department of Resources, which took operational control of the former Linc Energy site after it was disclaimed by liquidators in July 2016.
Since 2016, the Department of Resources has completed a number of significant steps in the remediation of the site including: decommissioning and removal of the surface gas gathering networks and gas to liquid plant; removal of the process water ponds and residues; and plugging and decommissioning of 42 high risk petroleum wells.
For more information about the former Linc Energy site remediation project please visit the Department of Resource webpage or contact the Department of Resources on 13 QGOV (13 74 68).